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    The collection, use and protection of personal information we all provide to companies with online presences are very important issues. All of us who work at NutraFocusMD.com (the “Website”) expect online companies we patronize to take this issue seriously, and we know that our customers expect the same of us.   We at NutraFocus, Inc. (“NutraFocus”, “Company”, “we”, “us”, “our”), the operators of NutraFocusMD.com, have created this privacy policy (the “Privacy Policy”) to explain how we may process, collect, store, disclose, share and use (collectively, “use”) your personal information that we collect from you or from others in connection with your use of our website or purchase of products, content or other services from us (collectively, our “Services”). This Privacy Policy also identifies your rights with respect to your personal information, all as described in more detail below.

    By using NutraFocusMD.com, you agree to the data practices described in this Privacy Policy and give explicit and informed consent to the collection, use and processing of your personal information according to this Privacy Policy. If you do not agree, please do not use the Website.

    Capitalized terms not defined in the Privacy Policy are defined in the Terms of Use and share the same definition.

    1. The information we collect about you:
    A. Personal information

    Personal Information is information relating to an identified or identifiable person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person. Personal information does not include information that can no longer be used to identify a specific person, whether in combination with other information or otherwise.

    We collect information from you both when you provide it voluntarily and also automatically when you use our Services. We may also collect personal information from other sources, as described below.

    We collect personal information from you and any devices you use to: use our Services, register for an account with us, make a purchase, provide us information on a web form, engage or connect with us through one of our social media pages, update or add information to your account, chat with a customer support specialist, or when you otherwise correspond with us.

    Advertising providers

    For more information about the types of your personal information we may use, see the detailed descriptions below.

    B. General Personal Data

    C. Special Categories of Data

    Information about your health, including any medical conditions, diagnoses and/or injuries

    We never request or require this type of information. But if you decide to share it with us, our business partners who provide tools to support our chat and customer service interactions generally maintain a copy of transcripts and recordings for all customer service transactions, but we do not use or disclose it for any purposes other than resolving or analyzing complaints, suggestions or issues brought to our attention by you.

    D. Other Information We Collect About You

    Pixels, Web Beacons. We or third party ad servers may use invisible pixels or beacons on the Services to count how many users visit certain pages or content. This information is collected and reported in the aggregate. We may use this information to improve our marketing programs and content, and to target advertisements to you.

    2. How we may use information about you

    We will only use your personal information for the purposes identified below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Some of your personal information, such as a way to identify you, is necessary to enter into our Terms of Service  or other agreement we have with you. The provision of all other personal information is voluntary, but may be necessary in order to use our Services, such as receiving support and customer service through customer support chat.

    A. General Personal Data

    In general, your personal information may be used for the following purposes:

    Managing your rewards account

    For us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using customer order information in the aggregate, including revenues generated in connection with our regulatory tax requirements).

    For our other legitimate interests to make available and highlight content and opportunities that are relevant to you, improve our Services, maintain our relationship with you, and protect users of our Services and customers, where your rights and freedoms do not outweigh these interests. We both benefit when we use your information to:

      Where it is needed in the public interest.

    B. Special Categories of Data

    Notwithstanding the above, we will only use the “special categories” of data described in Section 1 above in very limited circumstances and only with your express consent or, less commonly, we may use this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

    We will never ask you for such special categories of information, but if you provide it to us in your communications with us, such as, for instance, in customer support chats, we and our third party service providers who we employ to assist us manage customer- and visitor-provided requests and communications will store, but not otherwise use or disclose, such information in accordance with our standard data retention policies.

    If you do not wish for us to have such special categories of personal information, please do not disclose it to us.

    C. Other Information We Collect About You

    We use cookies and other tracking technologies to assist you navigating and using our Services, analyzing your use of our Services, and assisting with our promotional and marketing efforts (including advertising to you based upon your interests).

    We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

    Usage Information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services. When analyzed, Usage Information helps us determine how our Services are used, such as what types of visitors arrive at the Services, what type of content is most popular, what type of content you may find most relevant and what type of visitors are interested in particular kinds of content and advertising. We may associate your Usage Information with the personal information you provide, but we will treat the combined information as personal information.

    3. Who we may share your personal information with

    Additionally, we will share your personal information with third parties where required by law, where it is necessary in connection with our Services or where we have another legitimate interest in doing so.

    Most, if not all, of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States.

    If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction. Should such an event occur, we will require that the new combined or acquiring entity follow this Privacy Policy with respect to your personal information.

    4. How we safeguard your personal information

    We store your personal information in the United States or other countries outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

    We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Other than third parties with whom we share personal information in connection with our performance of Services, third parties we engage in our business who may have access to your personal information will only process your personal information on our instructions and they are required to only use your data as necessary to perform their contract with us.

    5. How long we store your personal information

    We may retain your Information for as long as your account is active, as needed to provide you Services or until such time as we receive a request for deletion from you. Nevertheless, we may retain your Information where retention is necessary for compliance with a legal, accounting or reporting obligation to which we are subject, or in order to protect your vital interests or the vital interests of another person. Additionally, we may continue to store your personal information contained in our standard back-ups.

    6. Your rights and options regarding your personal information

    Contacting us as described at the end of the Privacy Policy

    The right to lodge a complaint with the supervising authority of your country.

    If you want to exercise any of the rights listed above, please contact us through one of the methods listed at the end of the Privacy Policy, below.  

    Your mobile device lets you choose how and whether your location, advertising identifiers and other data is shared with us.

    7. Children under 18:

    Protecting the privacy of young children is especially important. Consequently, we do not knowingly collect or maintain personally-identifiable or non-personally-identifiable information on the Website from persons under 18 years of age, and no part of our Website is directed to persons under 18. If you are under 18 years of age, please do not use or access the Website at any time or in any manner. If we learn that personally identifiable information of any person under 18 years of age has been collected on the Website without verified parental consent, we will take the appropriate step to delete this information.

    8. California users

    Under California Civil Code Section 1798.83, California residents who have an established business relationship with NutraFocus may choose to opt out of our sharing their Personal Information with third parties for direct marketing purposes. California law requires us to inform you, at your request, (1) the categories of Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. COPPA further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email (to support@nutrafocusmd.com, with “California Customer Choice Notice” in the subject line) or physical mail to the address found below. When contacting us, please indicate your name, address, email address, and what Information you do not want us to share with our marketing partners. A request by mail should be labeled “California Customer Choice Notice.” Please allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your Personally Identifiable Information or requesting this notice. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

    At this time, NutraFocus does not respond to browser ‘do not track’ signals, as there are not yet standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our website.

    9. Changes to Privacy Policy

    We may update this Privacy Policy at any time, by posting the amended version on this site including the effective date of the updated version. If we make material changes to this Privacy Policy, we will notify you here and/or via email that it has been updated, so that you are aware. We may also provide other privacy notices on specific occasions when we are using your personal information in ways that differ from what we have described here, so that you are aware of how and why we are using such information and what your rights are with respect to such use.

    10. Links

    When you click on links on our Website, they may direct you away from our site. We are not responsible for the content or the privacy practices of other sites, nor do we have any control over how these websites may collect and use your information and no liability for their practices, policies and security measures. We encourage you to read their privacy policies before you submit your information to them.

    11. Questions or concerns

    If you have questions, comments, concerns or feedback regarding this Privacy Policy, or you wish to exercise any of your rights or options regarding how we use your personal information, please contact us in writing at:

    Or by email at support@nutrafocusmd.com, including “Attn: Data Protection Officer” in the email subject line.

    Last updated July 21, 2018