Last Updated: June 30, 2023.
1. Information Collected
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.
Information You Provide
The types of personal information we collect may vary depending on your use of the features of the Platform. You can choose not to provide personal information to us; however, some information about you is generally required for us to provide our products and services, respond to your requests, and otherwise communicate with you. The personal information we (ourselves or via our service providers) may collect includes the following, depending on how you interact with the Platform:
Contact, Payment and Demographic Information: We may collect your name, email, telephone number, home address, demographic information (such as zip code, age), details of your purchases and purchase history or payment information (such as account or credit card number) when you make a purchase.
Registration Information: If you register at the Sites, enter a promotion, opt-in to receive emails or other offers or communications, we collect and store the information provided. We may also ask you to provide demographic information such as gender or age, or information about your product preferences and interests.
Health and Wellness Information: 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.
Other Information You Submit: You may provide other personal information when you contact us or submit information through the Platform, including customer service contacts, surveys or quizzes, refer a friend options, and testimonials. The Platform may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information.
Information We Collect Automatically
We may also automatically collect certain personal information when you visit or interact with the Platform, including:
Mobile Apps and Location Data: Some of our mobile apps include opt-in, geo-location services that provide location-based services, such as store locators, local weather, promotional offers and other personalized content. Some of our mobile apps include opt-in “push notifications.” Most mobile devices allow you to turn off location services or push notifications. The mobile apps may also collect information about your mobile device, its operating system, and usage as further described below.
Usage Information: We or our service providers may also use a variety of technologies that passively or automatically collect information about how the Sites are accessed and used (“Usage Information”), including your browser type, device type, operating system, application version, the pages served to you, the time you browse, preceding page views, and your use of features or applications on the Sites. This statistical data helps us understand what is interesting and relevant to users of the Sites so we can best tailor our content.
Device Identifiers: Nutrafol also automatically collects an IP address or other unique identifier information (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Sites. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Sites, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you and your shopping cart, and gather broad demographic information for aggregate use.
If you would prefer not to accept cookies, you can change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or set your browser to automatically not accept any cookies. However, please be aware that some features and services on our Sites may not work properly because we may not be able to recognize and associate you with your account. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
Pixel Tags or Web Beacons: We also use web beacons or pixel tags, which are transparent graphic images placed on a web page or in an email and indicate that a page or email has been viewed or tell your browser to get content from another server. These may provide confirmation to us when you open an email from us.
2. Information 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.
3. Use of Information
Nutrafol uses the information we collect about you for a variety of business purposes, including:
- providing our products and services, including processing your purchases or other transactions and fulfilling orders;
- responding to your questions and requests;
- to process your job application;
- providing you with access to certain areas and features of the Sites or Platform;
- verifying your identity, securing the Platform and preventing fraud;
- communicating with you, including about your account and activities on the Sites;
- sending notice of changes to any Nutrafol policy;
- tailoring content, advertisements, and offers we provide you and recognizing you across devices;
- improving the Sites, our products and services, and for internal business purposes;
- allowing you to share activities on your social media pages, such as Facebook;
- sending marketing emails. You can manage your email preferences from your account settings; or
- sending text messages (with your consent).
We may share non-personal information, such as aggregate information that is not linked or reasonably linkable to any consumer or household, including via a device.
4. How We Share Personal Information
Service Providers: We may share your personal information with service providers that perform functions on our behalf (or on behalf of our business partners) such as service providers that host or operate our Platform, analyze data, process transactions and payments, fulfill orders or provide customer service; advertisers; sponsors or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance.
Business Partners and Internal Transfers: Your personal information may also be used by us or shared with our subsidiaries, affiliates, co-sponsors, and business partners to provide you with product information and promotional and other product and service offers. We may share your personal information with our parent company, subsidiaries and affiliates for internal reasons, primarily for business and operational purposes.
Business Transfers or Transactions: for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the Sites, personal information, Usage Information, and any other information that we have collected about the users of the Sites may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
5. Your Privacy Rights, Choice and Access
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.
6. 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.
7. Advertising/Targeted Advertising and Online Tracking; How to Opt-Out
Targeted and Interest-Based Advertising: Nutrafol licenses technology to serve advertisements on its own Sites and within its content as that content is served across the Internet. In addition, Nutrafol may use third-party network advertisers to serve advertisements and third-party analytics vendors to evaluate and provide us with information about the use of the Sites and viewing of our content. Ad network providers, the advertisers, the sponsors, and/or analytics service providers may set and access their own cookies, pixel tags and similar technologies on your Device and they may otherwise collect or have access to information about you, including Usage Information. We and our network advertisers may target advertisements for products and services in which you might be interested based on your visits to both the Sites and other web sites. We may use a variety of companies to serve advertisements.
If you prefer to not receive targeted advertising, you can opt out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page: https://www.networkadvertising.org/managing/opt_out.asp. Please note that even if you choose to remove your information (opt out), you will still see advertisements while you’re browsing online. However the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies. Please note, however, that 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 visit a different website or delete the opt-out cookies, you may need to perform the opt-out task again.
You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt out of interest-based ads" (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting https://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Google Analytics and Advertising: We use Google Analytics to better understand how our users interact with our Sites and such data is shared with Google. For information on how Google Analytics collects, uses and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies and third-party cookies or other third party cookies together to inform, optimize, and display ads based on your past visits to the Platform. 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 http://www.networkadvertising.org/choices.
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 email@example.com.
9. State-Specific Disclosures
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:
- California. If you are a California resident, please click here for additional California-specific privacy disclosures.
- Colorado. If you are a Colorado resident, please click here for additional Colorado-specific privacy disclosures.
- Connecticut. If you are a Connecticut resident, please click here for additional Connecticut-specific privacy disclosures.
- Virginia. If you are a Virginia resident, please click here for additional Virginia-specific privacy disclosures.
- Nevada. Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at firstname.lastname@example.org with the subject line of “Nevada opt-out”.
10. 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.
11. 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).
12. 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.
13. Changes and Policy Updates