Privacy Policy

Last Updated: March 28, 2024.

This Privacy Policy describes how Nutraceutical Wellness, Inc. (“Nutrafol”, “we”, “us”, or “our”) or our service providers collect, protect, share and use your information, including, without limitation, our company websites, web pages, mobile sites and mobile apps (collectively, the “Sites”), by email, phone, or other offline mechanisms, or anywhere else we display this Privacy Policy (collectively with the Sites, the “Platform”). Your use of the Platform constitutes your acceptance of this Privacy Policy and the practices described.

When we use the term “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could be linked directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you or a particular household or publicly available information from government records.

1. Information Collected, Use of Information, How We Share It, and Sources of Information

We collect personal information you provide to us through the Platform and we also automatically collect certain personal information when you interact with the Platform.

The list below describes our data practices in the last 12 months. We have collected each of the categories of personal information noted in the list below, how each category of personal information may be used by us or our service providers or contractors on our behalf, how we disclosed it, for a business purpose, to the categories of recipients listed below, and when we have sold or shared the category of personal information to third parties in the last 12 months, and to what categories of third parties. For purposes of this Privacy Policy, when we use the term “third party” we mean entities that are not service providers or contractors providing services on our behalf and that are not entities with whom you interact with directly.

• Identifiers, such as name, email address, online identifiers and other information.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate and payment information.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

• Protected Classification Characteristics under California or US Law.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests, to determine your eligibility; for marketing purposes; for interest-based advertising; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• Commercial Information, such as products or services purchased, obtained or considered, and other information relating to your hobbies, interests and shopping behavior.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• Internet/Network Activity Information, such as browsing history, search history, IP address, Device Information, and log and analytics data.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• Geolocation Data, such as location information from your device or estimated based on your IP address.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• Sensory Information, such as audio, electronic, visual, thermal, olfactory, or similar information.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Quality Assurance vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

• Other Personal Information, such as information you post on our Platform or on social media pages, and information you submit to us.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• Job Applicant Information, such as professional or employment-related information, including first and last name, email address, telephone number, gender, ethnicity, disability and veteran status, educational history, professional references, job history and any other information you choose to provide as part of your resume or application for employment.
  • Use Cases: We collect and maintain this information to determine eligibility for employment, including verification of references and qualifications; assessing qualifications for a particular job; complying with applicable laws, regulations, and statutes, or for such other purposes as are reasonably required by us as otherwise set forth in this Privacy Policy; or to communicate with you about your application for employment or potential job openings. We may share this information with our service providers as necessary for the purposes of determining your eligibility and qualifications.
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Employment Screening Vendors, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

• Inferences, such as predictions about your interests and preferences drawn to create a profile.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers and Contractors, such as: Marketing/Advertising/Media Agencies, Analytics Vendors, Fulfillment Partners, Payment Processing Vendors, Data Management Platforms, Social Networks, Law Enforcement, Affiliates, Regulatory Bodies, Government Authorities, Government Agencies
  • Sold or shared with third parties in the following categories for targeted or behavioral advertising: Marketing/Advertising/Media Partners and Platforms; Data Analytics Providers

• Categories of Sensitive Personal Information: Account Credentials Allowing Access to An Account
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to respond to your requests or questions; to communicate with you; to determine your eligibility; for marketing purposes; for interest-based advertising; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers or Contractors; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

• Categories of Sensitive Personal Information: Health-Related Information, such as when you choose to use our wellness coaches, consulting services, customer service, or respond to surveys and questionnaires, you may choose to provide information about your health, lifestyle activities, and related information. We may also create limited health information from analyzing your submitted hair sample when you participate in our hair mineral analysis testing.
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to provide product or service recommendations; to respond to your requests or questions; to communicate with you; for short-term, transient use, including, without limitation, nonpersonalized advertising; to verify or maintain the quality or safety of a product, service or device sold by us; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers or Contractors; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

• Categories of Sensitive Personal Information: Personal information revealing race, ethnicity, religious or philosophical beliefs, sexual orientation, citizenship, immigration status, citizenship status
  • Use Cases: To provide our products and services; to improve our products and services; to understand your interests; to determine your eligibility; for marketing purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers or Contractors; Platform Users; Research Organizations or Agencies; Marketing / Advertising / Media Agencies; Analytics Vendors; Retail Merchandising Vendors; Fulfillment Partners; Marketing Mix Measurement Providers; Payment Processing Vendors; Data Management Platforms; Social Networks; Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

• Categories of Sensitive Personal Information: Precise Geolocation from Your Device
  • Use Cases: To provide our products and services; to improve our products and services; to respond to your requests or questions; to determine your eligibility; for marketing purposes; for security purposes; to comply with law or to protect ourselves or third parties; for internal business purposes; as otherwise permitted by law or as we may notify you
  • Disclosed for business purposes with recipients in the following categories: Service Providers or Contractors; Research Organizations or Agencies; Data Management Platforms; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
  • Not sold or shared with third parties for targeted or behavioral advertising.

We will only process your Sensitive Personal Information in accordance with applicable law, such as obtaining your consent prior to processing. If you are a resident of a state with a law governing “consumer health data”, we provide details about our consumer health data practices in our Consumer Health Data Privacy Policy.

Sources of Information

We collect the types of personal information listed above in the following ways:

• Directly From You. When you interact with us on our Platform (including one of our Sites, sending us an email, visiting us at an in-person promotional event, or calling our customer service team) or interacting with our social media pages, we may collect the personal information you share with us.
• Automatically When You Interact with our Platform, Our Emails, or Advertisements. Subject to your device settings, we will automatically collect certain personal information when you interact with our Platform on any device, when you click on sponsored links or third-party ads to visit our Platform, and we may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, beacons, pixels, flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.
• From Our Affiliates. We may collect personal information about you from our affiliates.
• From Third Parties. We may receive information about you from third parties that feature our products or promotional offers if you opt-in to receive information from us. You may also choose to participate in a third party application or social media site through which you allow us to collect (or the third party to share) information about you, including Usage Information and personal information. We may also receive information about you via a refer a friend program. We may also receive information about you from outside records from third parties, such as marketing related or demographic information to enhance our ability to tailor our content, products and services that we believe may be of interest to you. We may supplement the information we collect about you through our Platform with such information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you. If we combine such data with information we collect through our Platform, such information is subject to this Privacy Policy unless we have disclosed otherwise.
• By Combining Personal Information. For example, we may combine personal information that we collect offline with personal information we collect through our Platform, combine personal information we collect about you from the different devices you use to access our Platform, or combine personal information we get from third parties with personal information we already have about you.

2. Your Privacy Choices

You may direct us not to share your Personal Information with third parties, not to use your personal information to provide you with information or offers, or not to send you newsletters, e-mails or other communications by: (i) modifying your registered user information on the Sites; (ii) filling out our Privacy Rights Request Form; or (iii) following the removal instructions in the communication that you receive.

If you wish to modify, verify, correct, delete, or update any of your personal information collected through the Sites, you may edit your profile preferences or fill out our Privacy Rights Request Form. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted through the Sites. We are under no obligation to store such personal information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups, legal obligations, and other reasons.

We do not control certain privacy settings and preferences maintained by our social media partners like Facebook, Instagram, TikTok and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site.

Mobile Application and Location Based Services:

You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.

You may completely opt out of all location-based information collection by us if you uninstall all of our mobile apps from your devices.

How to Exercise Choice for Interest-Based Advertising

Advertising Industry Opt-Outs

To exercise choice with respect to interest-based advertising, you can use the opt-out mechanism provided by the Digital Advertising Alliance by visiting https://optout.aboutads.info/?c=2&lang=EN (for browsers) or https://youradchoices.com/appchoices (for apps).

You can also use the Network Advertising Initiative’s tool that allows consumers to opt out of certain interest-based advertising delivered by NAI members’ ad networks: http://www.networkadvertising.org/choices/.

To opt-out of Unified ID 2.0 globally visit: https://www.transparentadvertising.com/.

Even if you opt-out of certain kinds of interest-based ads, you may continue to receive other ads. And opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you. This will affect services provided by the applicable DAA / NAI members but does not mean you will no longer receive any targeted content and/or ads from non-participating parties. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different Device or web browser(s), or use a non-browser-based method of access, your DAA / NAI browser-based opt-out may not, or may no longer, be effective. Mobile device opt-outs will not affect browser-based Interest-based ads even on the same device, and you must opt-out separately for each device. We are not responsible for the effectiveness of, or compliance with, any third party opt-out options or programs or the accuracy of their statements regarding their programs.

You can also prevent or reduce getting interest-based ads on websites by declining cookies in your browser(s), or on mobile devices by declining the “access to data” requests that apps usually present when you install them or by adjusting the ad tracking settings on your device.

You will still see “contextual” ads even if you opt out of interest-based ads. Even if we stop sending you interest-based ads, you will still get ads from our brands on your computer or mobile devices. These ads, however, are based on the context of the sites you visit and are called contextual ads. Unlike interest-based ads which are based on pages you visit on your mobile phone or computer viewing activities over time and across unrelated services, contextual ads are ads shown to you based on the context of the specific site you are visiting. You should also know that we may still collect information from your computer or devices and use it for other purposes like evaluating how our websites work, for consumer research, or detecting fraud, pursuant to applicable laws.

How You Can Control Cookies

Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can visit macromedia.com. Why? Because flash cookies cannot be controlled through your browser settings.

If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.

When you opt out of interest-based advertising, an opt-out cookie is sent to your browser that indicates you no longer want to receive interest-based ads. Your opt-out cookie will be deleted if you decide to delete all cookies on your browser. You will need to opt out again on each browser when you clear or delete cookies if you do not want to receive interest-based advertising.

PRIVACY RIGHTS

We offer certain privacy rights as stated below, subject to certain limitations at law.

HOW TO EXERCISE YOUR PRIVACY RIGHTS

To Exercise Your Rights to Know, Access/Data Portability, Correct, Delete and/or “Shine the Light”

Please submit a request by filling out our Privacy Rights Request Form or by calling 1-888-508-3471 (Monday through Friday, 9 AM – 6 PM ET).

We may need to verify your identity and confirm your state residency before processing most requests, which may require us to obtain additional personal information from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address and mailing address in the original request, as well as an explanation of the rights you wish to exercise. We will only use the personal information provided in connection with a Privacy Rights Request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.

If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. Please see the “Authorized Agents” section below for more information.

In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.

To Exercise Your Right to Limit Use of Your Sensitive Personal Information

To exercise your Right to Limit Use of Sensitive Personal Information, please submit a request by clicking the button below:

LIMIT USE OF MY SENSITIVE PERSONAL INFORMATION

We may ask you to provide additional personal information (including your name, email address and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Once you make limit request, you may change your mind and permit other uses of your sensitive personal information at any time by contacting us at privacy@nutrafol.com.

To Exercise Your Right to Opt Out of Personal Information Sales or Sharing for Cross-Contextual Advertising

As is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third-party businesses to collect personal information directly from your browser or device through cookies or similar online tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, geolocation data, commercial information, and inferences or consumer profiles generated from your browsing history and interactions with our service as well as other sites and services. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell or share that information to other businesses for advertising and other purposes.

We have two separate sets of instructions for exercising your Right to Opt Out: for Tracking Technology personal information (such as cookie ID, IP address, online IDs or electronic activity information) (“tracking PI”) and for information that we have previously collected directly from you or otherwise about you (such as your email address) (“non-tracking PI”). In either case, you do not need to create an account with us to exercise your Right to Opt Out.

How to Opt Out of non-tracking PI: To exercise your Right to Opt Out of non-tracking PI, please submit a request by clicking the button below:

DO NOT SELL OR SHARE MY PERSONAL INFORMATION

We may ask you to provide additional personal information (including your name, email address and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at privacy@nutrafol.com.

How to Opt Out of tracking PI: To exercise your Right to Opt Out of tracking PI, visit the bottom of our homepage that links to this Notice and click on “AdChoices – Do Not Sell or Share” at the bottom of the page. You will be taken to our cookie management tool with instructions for using the toggle to enable certain cookie preferences on your device. Some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, the options you select relating to interest-based advertising are browser and device specific. If you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again. Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control (“GPC”). You may need to use a specific browser or an extension that supports these tools and universal signals. When detected, we will process such a signal as Right to Opt Out of tracking PI request.

Personal Information of Children Under Age 16

We do not “sell” or “share” for targeted or cross-context behavioral advertising personal information of consumers we know to be less than 16 years of age unless we receive affirmative authorization from the child who is between 13 and 16 years of age, or the parent or guardian of a child less than 13 years of age. The parent or the child who has opted into personal information sales or sharing may opt out of future sales at any time. If a parent, guardian or child has provided affirmative authorization, they may opt out of future processing at any time by contacting us at privacy@nutrafol.com.

Authorized Agents

In certain circumstances, you are permitted to use an authorized agent to submit privacy rights requests on your behalf. We may verify the authorized agent’s authority to act on your behalf as follows:

For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Policy, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of personal information “sales” or “sharing” for cross-contextual advertising of personal information we may ask you to provide a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

Privacy Rights Metrics

Click here to see request metrics.

Financial Incentives

From time to time, we may offer you certain financial incentives permitted by law (such as offers, coupons, samples, loyalty programs and sweepstakes or contest rewards) in exchange for the collection, retention, use or share, or sale of certain personal information about you. Each financial incentive related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business. When necessary, we will provide information about the specific terms of the financial incentive, such as the type of personal information required to be disclosed, retained or sold in exchange for the benefit you may receive, and instructions on how to opt in or opt out, on the webpage or form where the financial incentive is made available.

Right to Know Specific Third Parties

In certain circumstances, you may have a right to request information about specific third parties with whom we share personal information. You may make this request by contacting us at privacy@nutrafol.com.

Right to Revoke Consent

Where we are processing your personal information based on your consent, you have the right to revoke such consent. You may make this request by contacting us at privacy@nutrafol.com.

Right to Appeal

In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at privacy@nutrafol.com.

Nondiscrimination

We do not discriminate against you for requesting any of the rights noted above. We are permitted to deny or limit your request in accordance with applicable laws.

3. Retention of Personal Information

We will retain your personal information for as long as your account is active or as needed to provide you services, or as otherwise required by law or to fulfill the purposes for which it was collected and received. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The duration is limited to the time necessary to fulfill the purposes for which it was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.

4. Advertising/Targeted Advertising and Online Tracking; How to Opt-Out

Cookies & Other Tracking Technologies: We automatically collect certain types of usage and device information when you visit our Platform, read our emails or otherwise engage with us. We typically collect this information through use cookies (a small text file sent from a website and stored on your device), web beacons or pixels and similar tracking technologies, and we may utilize third party services to collect this information. For example, these tracking technologies may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID, and about the way you engage with our Platform, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, how frequently you access our Platform, whether you open emails or click the links contained in emails, whether you access our Platform from multiple devices, the products you view and click on, and similar actions you take. You can learn more about how to control cookies in our “Your Privacy Choices” section above.

We use this information collected through tracking technologies to allow you to browse our Platform and use its features, to provide custom, personalized content and information, including targeted content and advertising, to measure the effectiveness of our advertising, to recognize you across multiple devices, to remember your preferences, to monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, to identify errors and resolve them, to analyze Platform performance, to improve our Platform, and otherwise enhance our Platform and your user experience.

Interest-Based Advertising:

We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. This means that we permit third party online advertising networks, social media companies, and other third-party services to collect information about your use of our websites and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. To learn more about your choices regarding interest-based advertising, visit the “Your Privacy Choices” section above.

We learn from groups of consumers sharing similar interests. We may place you in a group of consumers who show the same interests (sometimes these are called “look alike audiences”). We may infer these things about you based on your activity on certain webpages, links you click on our Platform and other websites you visit, mobile applications you use, or our brand emails you view and links you click in the emails, and based on other information we have collected, such as from retail partners and other third parties. We group together information to help us learn about general trends, habits or characteristics about a group of consumers who act similarly online or offline and use this information to send this group information we believe will be relevant product offers or information.

We link information to your cookie ID or device ID. This information may be supplemented with information such as products you buy offline or information you provide directly to us on our Platform. We generally do this in ways that will not directly personally identify you (they are “masked” by a number identifier instead of associated with information like your name), but if we personally identify you we will do so in accordance with applicable laws.

We may know you across your devices, such as computers, phones, tablets because we associate cookie and device IDs. We assume that the same person owns certain devices based on certain activities, such as connecting the devices to the same WiFi network.

We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

Google Analytics and Advertising:

We use Google Analytics to better understand how our users interact with our Platform. Our ability to use and share information collected by Google Analytics about your visits to our sites is restricted by the Google Analytics Terms of Use (https://marketingplatform.google.com/about/analytics/terms/us/) and the Google Privacy Policy (https://policies.google.com/privacy). To understand how Google uses data when you use our partners' sites or apps, visit https://policies.google.com/technologies/partner-sites. You may opt out of Google Analytics at any time by visiting https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visiting NAI’s online resources at https://optout.networkadvertising.org/?c=1.

Pixels: Pixels are small objects embedded into a web page but are not visible. They are also known as “tags,” “web bugs,” or "pixel gifs." We use pixels to deliver cookies to your computer, monitor our website activity, make logging into our sites easier, and for online marketing activities including personalized advertising on social media sites. We also include pixels in our email messages or newsletters to determine whether you open them and click on their links. This helps us understand whether you are an active user. It also helps us measure the effectiveness of our marketing efforts, and derive insights and analysis, that we will use to personalize the content of our communication and to guide our marketing decisions and strategy.

Do-Not-Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as the Global Privacy Control (“GPC”). You may need to use a specific browser or an extension that supports these tools and universal signals. When detected, we will process such a signal as a request to opt out of tracking PI and as a request to opt out of “sale” or “sharing” of your data as explained in the “Your Privacy Choices” section below. You can also opt-out of such tracking directly on our Platform by following the steps noted in the Interest-Based Advertising section above. If you have questions, please contact us via one of the methods listed in the “How to Contact Us” section at the end of this Privacy Policy.

5. Children

The Sites are not directed to children under 13. We do not knowingly collect, use or disclose personal information from anyone under 13 years of age. If we become aware that we have unknowingly collected personal information from a child under the age of 13, we will make reasonable efforts to delete such information from our records. If you believe we may have inadvertently collected personal information from a child under 13, please contact us at privacy@nutrafol.com.

6. Security of Your Information

Nutrafol maintains reasonable safeguards designed to protect personal information against loss, unauthorized use, disclosure or destruction and when transferring information for processing. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us.

7. Other Sites

The Platform may contain links to third party sites that are not owned or operated by Nutrafol. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies or other tracking devices to your Device, they may independently collect data or solicit personal information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Sites or part of the Platform (including those linked to through an email or social networking page).

8. Storage and Transfer of Personal Information

The Platform is governed by and operated in, and in accordance with the laws of, the United States, and are intended for the use and enjoyment of residents of the United States. Nutrafol makes no representation that the Platform is governed by or operated in accordance with the laws of any other nation. If you are located outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Platform, or providing us with any information, you (a) acknowledge that the Platform is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

9. Changes and Policy Updates

Please note, we may change information on the Platform and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy. We will use your personal information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. We encourage you to periodically review this page for the latest information on our privacy practices.

10. Contact Us

If you have questions regarding this Privacy Policy, please contact us via email at privacy@nutrafol.com or telephone 1-888-508-3471.