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.
- In addition, we also collect personal information about you from third parties in connection with our Services, including from the following sources:
- E-commerce service providers
- Social media platforms
- Email, chat and other communications service providers
- Customer service providers
- Data analytics service providers
For more information about the types of your personal information we may use, see the detailed descriptions below.
B. General Personal Data
- We may use the following categories of personal information in connection with your use of our Services:
- Personal contact details, such as name, title, addresses, telephone numbers, and personal email addresses
- Date of birth
- Social media account information
- Account preferences
- Financial information, such as credit card numbers
- Location information
- Device ID or unique identifier, device type, ID for advertising, order ID, and unique device token
- Computer and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information
C. Special Categories of Data
- Through our chat services and customer services interactions, we know that sometimes customers and users of the Services choose on their own to share the following kinds of personal information with us:
- Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
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
- Non-Personal Information. In addition to personal information you choose to provide us or that is automatically collected by us and our third-party service providers when you use the Services, we and our third-party service providers may use a variety of technologies to automatically collect certain usage information whenever you visit or interact with the Services. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information (collectively, “Usage Information”).
- Cookies. Our Services use “cookies” and similar technologies. Cookies are small text files sent by your computer or device each time you visit our Services, which are unique to your account, browser or device. Cookies make web surfing and browsing easier for you by saving your preferences so that we can use these to improve your next visit to our Services – for example, remembering your login information.
- Cookies are either persistent or temporary (or session) cookies. A persistent cookie retains user preferences for a particular website allowing those preferences to be used in future browsing sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
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:
- Regarding our provision of Services to you, which may include the following:
- Managing and fulfilling your orders
- Payment processing and account management
- Providing customer support and responding to your questions or comments
- Operating and improving our Services
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:
- Improve our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience
- Offer new features, programs and opportunities
- Decide which ads to show you by only showing you those that “match” your past viewing, browsing and shopping activity. Many advertising services collect and use data from your web and mobile app activity both on and off the Services to help show you ads that are more targeted to your interests
- Contact you via email or postal mail in order to offer you coupons, discounts and special promotions, poll your opinions through surveys or questionnaires and inform you about our Services, as authorized by applicable law
- Deliver targeted marketing, service updates, and promotional offers based on your communication preferences
- Measure the performance of our email marketing campaigns (e.g. by analyzing open and click rates)
- Contact you regarding your account or an order, to troubleshoot problems with your account or an order, to resolve a dispute, to collect fees or monies owed or as otherwise necessary to provide you customer service
- Monitor and improve the information security of our websites
- Keeping our Services safe, secure and operational
- Prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities
- Customizing content that includes items and services that you may like in response to actions that you take
- Provide other services requested by you as described when we collect the information
- Conduct analytics on who is using the Services and what they are doing. For example, by reviewing how often people read certain content, we can learn and understand which content is most valuable and helpful to you and others
- Use your geo-location to provide location based services
- With your consent, we may use your personal information to:
- Provide you with marketing via telephone calls, email, SMS or text
- Provide you with marketing from third parties
- We may also use your personal information in the following situations, which are likely to be rare:
- Where we need to protect your interests (or someone else’s interests).
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
- Cookies and Tracking Technologies.
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
- Regarding our services, we may share your personal information with the following types of recipients:
- Our service providers, who we engage to help us run our business and perform the Services, including:
- Software and service providers we use to manage and process your information (e.g., payment processing software)
- Software and service providers we use to communicate with you (e.g., e-mail marketing service providers)
- Advertising service providers we use to assist us in providing personalized advertising
- Hosting providers that provide database storage for our business
- Shipping providers for purposes of shipping products you have ordered
- Internally, among different departments and with our investors and trusted advisors
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.
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
- Your data belongs to you, not us. Therefore, you have choices about how we use your personal information to communicate with you and send you marketing information. You can opt out from receiving future marketing communications from us at any time by:
- Using the unsubscribe function in the email you receive from us; or
- In addition, if you live in the European Union, you may have the following rights with respect to your data under certain circumstances:
- The right to request access to your personal information and the following information regarding our use of your personal information:
- The purpose of such use
- The categories of your personal information that we have used
- Who we have disclosed your personal information to
- The right to request us to correct any inaccurate personal information concerning you.
- The right to request us to erase your personal information when we no longer need such data in connection with our services or, with respect to “special categories” of personal information, if you withdraw consent to our use of such information.
- The right to withdraw consent to our use of “special categories” of personal information.
- The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
- The right to object to our use of your personal information where we are not using it to perform Services you have requested from us.
- The right to receive a copy of your personal information.
The right to lodge a complaint with the supervising authority of your country.
- In addition, regardless of where you live, you have choices available to you through the device or browser you use to access the Services. For example:
- The browser you use lets you control cookies or other types of local data storage.
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 firstname.lastname@example.org, 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.
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
- NutraFocus, Inc.
- Attn: Data Protection Officer
- 2601 W Lake Ave
- A6 – Suite 226
- Peoria, IL 61615
Or by email at email@example.com, including “Attn: Data Protection Officer” in the email subject line.
Last updated July 21, 2018