CONSUMER HEALTH DATA PRIVACY POLICY
Last Updated Date: March 31, 2024
This Consumer Health Policy applies to personal information defined as “consumer health data” under US state privacy laws, including Washington’s My Health My Data Act and Nevada’s consumer health privacy law.
SCOPE
This Consumer Health Data Privacy Policy (this “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 Policy (collectively with the Sites, the “Platform”). Your use of the Platform constitutes your acceptance of this Policy and the practices described. This Policy is not, however, a contract and does not create any legal rights or obligations.
Consumer Health Data We Collect, Use Cases, Data Sharing
The consumer health data we collect about you may vary depending on how you interact with our Platform and consents you may provide. The table below describes the categories of consumer health data collected and the purpose for which the data is collected and purpose for which it will be used or shared; the categories of such data that are shared; and the categories of third parties and specific affiliates with whom we share consumer health data. We do not “sell” consumer health data.
Category of Consumer Health Data
1. Information about your health-related conditions, treatments, diseases or diagnoses, diagnostic testing, health measurements, symptoms, medication
2. Information that identifies an individual seeking health-related services
3. Information derived or inferred from nonhealth information
Purposes for Collection, Use or Sharing & Manner of Processing
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
Categories of Third Parties or Affiliates With Whom Consumer Health Data Is Shared
Third-Party Health Care Providers at your direction (such as naturopathic doctors, dermatologist or plastic surgeon); our Affiliates; Law Enforcement; Regulatory Bodies; Government Authorities; Government Agencies
We may also collect, use, or disclose consumer health data to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal; to preserve the integrity or security of systems; or investigate, report, or prosecute those responsible for any such action that is illegal.
Sources of Consumer Health Data
Sources of consumer health data we collect and use are:
Directly From You. When you interact with us on our Platform (including one of our websites through our quiz experiences or surveys, interacting with a chatbot, responding to an email, visiting us at an in-person promotional event, or calling our Consumer Services Team), we (or our service providers) may collect the consumer health data you choose to share with us.
From Our Affiliates. We may collect via our affiliates, subject to your consent.
From Third Parties. We may receive consumer health data about you from third-party sources from companies that provide personal information to supplement what we already know about you, including data aggregators, subject to those third parties’ compliance with legal requirements, including legally-required consent.
Inferences. We may infer certain information about you based on information provided from any of the sources listed above.
Consumer Health Data Rights
We offer certain privacy rights regarding your consumer health data as stated below, subject to certain limitations at law.
Right to Confirm Processing of Consumer Health Data | The right to confirm if we are collecting, sharing, or selling consumer health data concerning you. |
Right to Access Consumer Health Data | The right to access and obtain a copy of the specific pieces of consumer health information we have collected about you, including a list of all third parties and affiliates with whom we have shared or sold the consumer health data and an active email address or other online mechanism that you may use to contact these third parties. |
Right to Withdraw Consent to Collect and Share Consumer Health Data | The right to withdraw consent from our collection (i.e., use) and sharing (with third parties and affiliates) of consumer health data concerning you. |
Right to Delete Consumer Health Data | The right to request deletion of the consumer health data concerning you. |
How to Exercise Your Privacy Choices Regarding Consumer Health Data
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 authenticate your identity and request before processing it, which may require us to obtain additional personal information from you. In order to authenticate your identity, we will generally require either the successful authentication of your existing 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. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
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. If your appeal is unsuccessful, Washington residents can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.
Additional Information for Nevada Residents
We do not permit third parties to collect consumer health data over time and across different websites while you use our Platform. Where third-party cookies, pixels or tracking technologies are enabled on our Platform and where consumer health data is collected, such third parties are required to agree to act as our service providers. However, third parties may still be able to collect consumer health data from you over time and across different websites depending on your browser, browser add-ons, and permissions you set on your device used to access the Platform. Such collection by third parties is not related to Nutrafol’s collection of consumer health data from you. We encourage you to view the privacy notices of those third parties for more information about their data practices and your privacy choices with regard to those activities.
If you would like to review and request changes to any of your consumer health data collected by us, you can submit a Right to Correct request by filling out our Privacy Rights Request Form or by calling 1-888-508-3471 (Monday through Friday, 9 AM – 6 PM ET).
If you appeal a denied request and your appeal is unsuccessful, Nevada residents can raise a concern or lodge a complaint with the Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.
Changes in Policy
From time to time, we may change this Policy. We will notify you of any material changes to this Policy as required by law. We will also post an updated copy of this Policy on the Platform. Please check the Platform periodically for updates.