Privacy Policy - December 2022

Privacy Policy

Last modified: December 23, 2022

Please read these terms carefully before using this website. Your use of this website is your acceptance of these terms.

Please click here to view the previous version of our Privacy Policy.

California Notice at Collection/State Law Privacy Rights: see the State Law Privacy Rights section below for important information about your rights under applicable state privacy laws in California and other states.

You can download a printable copy of this Privacy Policy here.

 Internet Privacy Policy

It is the policy of JDS Therapeutics, LLC, and its subsidiary Bonafide Health, LLC (the “Company”), to respect your privacy, and the privacy of all visitors to our websites (“Site”), including hellobonafide.com. This policy statement has been established to help you understand our commitment to protecting your privacy when accessing and viewing information on the Company’s Site and providing information to the Company.  This policy applies to information we collect on the Site, in email, text, social media, or other electronic messages between you and this Site.  This policy will also apply if you participate in our events, surveys, research activities or other activities where this Privacy Policy is posted. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  This policy may change from time to time.  Your continued use of this Site after we make changes is deemed to be an acceptance of those changes, so please check the policy periodically for any updates.  It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Site home page.

What Information Do We Collect From You?

General

We may receive and store any information you enter on our Site or give to us any other way. This includes information that identifies you (“personal information”), and may include: 

• Contact data, such as your first and last name, telephone number, postal and email addresses.
• Demographic data, such as your country or state of residence, age, and gender.
• Profile data, such as your professional title and organizational affiliation, biographic details, and username(s) and password(s).
• Communications data, such as your communication needs and preferences and information based on our exchanges with you, including when you contact us with questions, feedback, survey responses or otherwise communicate with us via chat features or social media. You can choose not to provide information, but we may require some information about you to use our Site as intended. 
• Transactional and payment data, such as the information needed to complete your orders on or through the Site (including name, credit card information, billing and shipping information), and information about payments to and from you and other details of products you have purchased from us.
• Medical data, such as information about your medical conditions, your doctor’s information, or other information that you choose to provide. We also may require some personal information to answer your questions or conduct other transactions on our Site.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User generated content, such as posts you submit to be published or displayed on public areas of the Site (“Posts”), or transmitted to other users of the Site or third parties. If your Posts are chosen to be published or displayed on the Site, they are posted and transmitted to others at your own risk.
• Other data, not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic Information

We may automatically collect some information about your computer or mobile device when you visit our Site. For example, we may collect: 

• Device data, such as your computer or mobile device operating system, manufacturer/model, browser type, screen resolution, session data, including your IP address, unique identifiers, web browser software, and referring website, and general location information. 
• Online activity, such as content viewed, length of time on each website, and pages visited. We collect this automatic information to help us understand the interests of our customers and visitors and customize your user experience, among other things.

Cookies, Other Web Technologies, Use of Google Analytics and Other Analytic Tools

Google Analytics

We have enabled the following Google Analytics Advertising Features: Remarketing; Network Impressions Reporting; and Demographic and Interest Reporting.  We may enable other remarketing tools.

Cookies are small data text files that, if your web browser permits, can be stored on your computer’s hard drive. We use cookies:

• To help us recognize your web browser as a previous visitor and save and remember any preferences set while your web browser visited our Site. For example, if you register on our Site, we may use cookies to remember your registration information so you do not need to log into our Site each time you visit.
• To help us customize the content, Site experience, and advertisements, we may provide to you on our Site and on other websites across the Internet. For example, when you access a webpage, a cookie automatically recognizes your web browser as you navigate on the Internet and may present you with information and advertising based on your apparent interests.
• To help measure and research the effectiveness of the features, offerings, advertisements, and email communications (by determining which emails you open and act upon) of our Site.

The settings of your web browser and the Help portion of the toolbar on most web browsers will tell you how to prevent your web browser from accepting new cookies, have the web browser notify you when you receive a new cookie, or disable most cookies. However, you may not be able to access some tools and features offered on our Site if you refuse to accept cookies.

Web beacons, also known as clear gifs, pixel tags or web bugs, are tiny graphics with a unique identifier, similar in function to cookies, which we place in the code of a webpage. Web beacons allow us to monitor the traffic patterns of users from one page within our Site to another, deliver or communicate with cookies, understand whether you have come to our Site from an online advertisement displayed on a third-party website, and improve the performance of our Site. We also may allow our service providers to use web beacons to help us understand which emails recipients have opened and track the visitor traffic on our Sites.

Session-replay technologies, such as those provided by FullStory, that employ software code to record users’ interactions with the Services in a manner that allows us to watch and analyze visual reconstructions of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls, and keystrokes/key touches  during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about FullStory at https://www.fullstory.com/legal/privacy-policy and you can opt-out of session recording by FullStory at https://www.fullstory.com/optout/. 

Chat technologies, such as those provided by Gladly that employ cookies and software code to operate the chat features that you can use to communicate with us through the Site. Gladly and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

Visitors can opt-out of Google Analytics using Google’s Ads Preferences Manager. Third-party vendors, including Google, may show our ads on sites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on someone’s past visits to our Site. You also can opt-out of Google Analytics by using Google Analytics’ Opt-out Browser Add-on, which can be found at: https://tools.google.com/dlpage/gaoptout/ 

Information from Other Sources

We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and third parties and add it to other information about you. For example, if you visit our Site by “clicking-through” from a site operated by one of our business partners, or from a social media platform, and you have registered with that partner, then the partner may share with us information about you that you have provided to that partner. For example, we may receive your contact information and demographic information. If you access third party services, such as social media services, through our Site, we also may collect information such as your user name, password, and other information made available to us through those third party services.

Information About Others

If you have the opportunity to provide contact information for other people or businesses through our Site, you should obtain their consent before you provide their personal information to us.

Display of Advertising and Your Choices

We want to provide you with relevant content and information across our Site. We may collect information about your communications-related searches and use this information to serve you with advertisements on our Site (or elsewhere on the Internet) that match your apparent communications-related interests.

Many of the advertisements you see on our Site are served by us or our service providers. However, we may also allow third parties to collect information about your online activities through cookies and other technologies. These third parties may include (i) advertising networks, who collect information about your interests when you view or interact with one of the advertisements they place on many different websites on the Internet; and (ii) our business partners, who collect information when you view or interact with one of their advertisements on our Site. These third parties gather this information to predict your characteristics, interests or preferences and to display advertisements on our Site (and across the Internet) tailored to your apparent interests.

We do not have access to or control cookies or other technologies these third parties may use to collect information about your interests; our Privacy Policy does not cover either these third parties or their information practices.

How do we use your information?

We may use the information we collect about you for a variety of purposes, including: the registration and management of your account, including the facilitation of your access to and use of our Site; communication with you, including to provide information about us and invitations from us; responses to your questions and comments; the measurement of your interest in our products, services, and Site, as well as the improvement of our products, services, and Site; marketing and direct or internet-based advertisements, such as notifications about special offers and products or services available from us or our partners that may interest you (you may opt out of our direct marketing communications or internet-based advertisements as described below); the customization of your experience with us; the solicitation of information from you, including through surveys; the resolution of disputes and troubleshooting of other problems; the prevention of potentially prohibited or illegal activities; the enforcement of our Terms of Use; and as otherwise described to you at the point of collection.
As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business.

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• to obtain a credit report;
• complete a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy
• enforce the terms and conditions that govern the Site; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

You will not give, lend or otherwise disclose any passwords or other similar user identifications to any unauthorized person, or permit any unauthorized person to use your account(s) or related passwords or user identifications. Any loss of control of passwords or other similar user identifications may result in the loss of control over your information. You will be responsible for any actions taken on your behalf or any person using your passwords or other similar user identifications. You must immediately change any passwords or other similar user identifications and notify us immediately if any passwords or other similar user identifications provided to us have been compromised.

How do we use any feedback you may provide?

Any anonymized data that you send to us such as your questions, suggestions, ideas or other creative material belongs to us and we will not treat it as confidential. We may adapt, disclose, display, distribute, reproduce, use, or create derivative works from any such information without acknowledgment of you or compensation to you.

How do we share your information?

We may share your personal information with other parties and as otherwise described in this Privacy Policy or at the time of collection. The following parties may have access to your information, as described in more detail below: affiliates, service providers, advertising partners, third party partners, direct mail co-op, professional advisors, authorities and other law enforcement, or business transferees. 

• Affiliates. Our corporate parent, subsidiaries, and affiliates for purposes and use consistent with this Privacy Policy. 
• Advertising partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our products (including, through interest-based advertising), and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms. 
• Third parties designated by you. You can tell when a third party is involved in a product or service you have requested because their name will appear either with ours or separately. If you choose to use these products or services, we may share information about you, including your personal information, with those business partners. We do not control the privacy practices of these third-party business partners and our Privacy Policy does not cover either these third parties or their information practices.
• Third party partners. If you were referred to one of our Sites from a third party’s website, we may share your registration information, such as your name, email address, mailing address, telephone number and preferences, about you with that referring website. We have not placed limitations on the referring websites’ use of personal information, and we encourage you to review the privacy policies of any website that referred you to one of our Site. Our Privacy Policy does not cover either these third parties or their information practices.
• Linked third-party services. You can choose to access certain third party social media websites and services through our Site. When you do so, you share information with those sites and their privacy policies will govern the information you share with them. Our Privacy Policy does not cover either these third parties or their information practices. You may be able to modify your privacy settings with these third party social media websites.
• Service providers. We may use third party vendors to provide various services or functions on our behalf, including Site hosting, business analytics, customer service, marketing, mailings, distribution of surveys, online chat functionality providers, and fraud prevention.  These third party vendors may be located in other countries. We may also authorize third-party vendors to collect information on our behalf to operate features of our Site or facilitate the delivery of online advertising tailored to your interests, among other reasons. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose.
• Direct mail co-op. We use a third-party co-op to manage marketing mailings and other third parties for media buying.  As a member of a co-op and partner with media buyers we comply with all applicable laws, rules, and regulations covering the sharing of personal information where contributor may not be directly sharing with the end marketer.  You may opt-out of this information sharing by emailing us at support@hellobonafide.com.
• Payment processors. We use a third-party intermediary to manage certain credit card processing. This intermediary is not permitted to store, retain, or use billing information, including your billing name and address and credit card number, except for the sole purpose of credit card processing on our behalf.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in the Company, financing of the Company, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of the Company as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Site receive. This information does not contain any personal information and is used to develop content and services we hope you will find of interest. 

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties on our Site, that information can be seen, collected and used by others besides us. We are not responsible for any unauthorized third-party use of such information.

How can you update and revise your information?

We take reasonable steps to ensure that your information is relevant, accurate, and complete. Your use of our services available through our Site may permit you to update or revise your personal information through our Site. If you remove certain information from your account(s), we only will retain those copies of such information as necessary for us to comply with governmental orders, resolve disputes, troubleshoot problems, enforce any agreement that you have entered into with us, and as we otherwise deem reasonably necessary.

What choices do you have regarding the collection and use of your information?

Privacy rights. Residents of certain states can exercise privacy rights with respect to the personal information we collect, as described in the State Law Privacy Rights section below.

• You can choose not to provide us with any information, although it may be needed to take advantage of certain features offered on our Site.
• You also can revise or update information as described above.
• Whether registered as a customer or not, you also may unsubscribe from promotional messages in any email we send or by contacting us at support@hellobonafide.com. We reserve the right to send you other non-marketing communications, including service announcements, administrative messages, and surveys relating to your account, without offering you the opportunity to opt out of receiving them.
• You may opt-out of sharing of your personal information with our direct mail marketing co-op as described above by emailing us at support@hellobonafide.com.
• We want to make it easy for you to take advantage of opportunities on our Site and through third parties. We do this is by sending you email messages that contain information about your apparent communications-related interests. We believe these email messages will provide you with useful information about special offers available through our Site or available from various third parties. You will have the opportunity to choose not to receive these email messages in any email we send by selecting to unsubscribe from receiving future email messages, for which we will remove you from our email list within 10 days of your request.
• The Help portion of the toolbar on most browsers will tell you how to prevent your web browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if you refuse to accept cookies, you may not be able to access portions of our Site.  We use Google Analytics to help us understand user activity and patterns on the Site. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.You can limit use of your information for interest-based advertising by blocking third party cookies in your browser settings, by using privacy browsers or ad-blocking browser plug-ins, by using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes, or by utilizing Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising:

• Google: https://adssettings.google.com/

• Facebook: https://www.facebook.com/about/ads
• You can also opt out of interest-based ads from companies participating in the following industry opt-out programs:
• Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
• Digital Advertising Alliance: optout.aboutads.info. 
• AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

Not all companies that serve interest-based ads participate in these opt-out programs, so even after opting-out, you may still receive some cookies and interest-based ads from other companies.  If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

• Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track”.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
• If you choose to connect to the Site through your social media account or other third party platforms, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

How do we protect your information?

We want you to feel confident about using our Site, and we commit to protecting the information we collect. While no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect the personal information you provide to us. For example, we permit only authorized personnel to access personal information, and they only may do so for permitted business functions. We also use encryption when transmitting your personal information between your system and ours. We also employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information. However, we make no guarantee, representation or warranty that use of our Site is protected from all security threats, viruses, or other vulnerabilities or that your information always will be secure.

How do we protect children’s privacy?

Our Site is not intended for children under 16 years of age; no one under age 16 may provide any information to or on the Site.  We do not offer services directed to children. Should an individual whom we know to be a child under age 16 send personal information to us, we will delete or destroy such information as soon as reasonably possible. 

Does our Privacy Policy apply to external links?

If any part of our Site links you to other websites, those external websites do not operate under this Privacy Policy. We recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.  These links or integrations are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

How does our Privacy Policy apply if you visit our Web sites from outside the United States?

If you visit our Site from outside the United States, your information may be transferred to, stored, and processed in the United States where our servers are located and where we operate our databases. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. However, we take steps pursuant to laws in the United States to protect your privacy. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

How can you contact us?

If you have any questions or comments about this Privacy Policy, the practices of the Company, or our products or services please send them to us via the “Contact Us” section of the Company Site or by email to: support@hellobonafide.com.

State Law Privacy Rights

Scope: Except as otherwise provided, this section applies to residents of California, Virginia, and other states where privacy laws applicable to us grant their residents the rights described below, including the California Consumer Privacy Act (“CCPA”). 

For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside.  Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the relevant states, you may not be able to exercise these rights.

In some cases, we may provide a different privacy notice to certain categories of residents of these states in which case that notice will apply with respect to the activities it describes instead of this section.  

Your Privacy Rights. You have the rights listed below. However, these rights are not absolute and in certain cases, we may decline your request as permitted by law. 

• Information/know. You can request whether we have collected your personal information, and in certain cases, information about how we use and share it. For example, if you are a California resident, you can request information about the categories of personal information that we have collected; the categories of sources from which we collected personal information; the business or commercial purpose for collecting, sharing and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared or disclosed for a business purpose.

• Access. You can request a copy of the personal information that we have collected about you.
• Correction. You can request that we correct inaccurate personal information that we have collected about you.
• Deletion. You can request that we delete your personal information. Please note that once we process a deletion request, we will be unable to provide any online or digital services to you or support for past products or services that you may have purchased.
• Opt-out.
• Opt-out of tracking for targeted advertising purposes. You can opt-out of certain tracking activities for targeted advertising purposes as described in the interest-based advertising section above. 
• Opt-out of sales of personal information. You can opt-out of sales of your personal information.
• Opt-out of profiling. You can request to opt-out of certain “profiling” as defined in applicable privacy laws, which may include automated processing to analyze or predict your interests or other behavior.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by applicable privacy laws.

How to Exercise Your Rights.

• Information/know, access, correction, and deletion. You may submit requests to exercise these rights HERE, by calling us toll free at 1-833-266-2343, or via email to support@hellobonafide.com.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.  You can ask to appeal any denial of your request in the same manner through which you may submit a request.  
• Opt-out of tracking for targeted advertising purposes.  Like many companies, we use services that help deliver interest-based ads to you as described above.  You can submit requests to opt-out of tracking for targeted advertising purposes here: Do Not Sell or Share My Personal Information.  Your request to opt-out of sharing will apply only to the browser and the device from which you submit the request. 

Verification of Identity. We may need to verify your identity in order to process your information/know, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require authentication into your account, government identification, a declaration under penalty of perjury, personal identifiers we can match against information we may have collected from you previously, confirmation of your request using the email address or telephone number associated with your account, or a declaration under penalty of perjury, where permitted by law.

Authorized Agents. Your authorized agent may be able to make a request on your behalf.  However, we may need to verify your authorized agent’s identity and authority to act on your behalf.  We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Additional Information for California residents.  The following describes our practices currently and during the past 12 months:

• Sales/sharing. Our participation in a direct mail marketing co-op as described above may constitute a “sale” of your personal information from which you have the right to opt-out by emailing us at support@hellobonafide.com. California law also classifies our use of some of the services that help deliver interest-based ads to you as “sharing” your personal information with the advertising partners that provide the services from which you have the right to opt-out.  You can broadcast the Global Privacy Control (GPC) to opt-out for each participating browser system that you use; learn more at the Global Privacy Control   We do not have actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.
• Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the California Consumer Privacy Act.
• We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention).  Whether the retention period is sufficient to fulfill such purposes is the primary criteria for determining the duration of the retention period.  
• We do not to attempt to reidentify deidentified information derived from personal information, except that we may do so to test whether our deidentification processes comply with applicable law.
• Personal Information that we Collect, Use and Disclose. In the list below, we describe our personal information practices by reference to the categories in the “What Information Do We Collect From You?” section above and the categories described in the CCPA (Cal. Civ. Code Section 1798.140(v)). Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to business transferees, authorities and others, and professional advisors as described above in the “How do we share your information?” section of this Privacy Policy. For information about the categories of sources of this information, see the section above entitled “What Information Do We Collect From You?” For information about the purposes for collecting, using, and disclosing personal information, see the section above entitled “How do we use your information?”.

• Your California Privacy Rights under the Shine the Light Law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to support@hellobonafide.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
• Notice of financial incentive. We offer various programs that may constitute a “financial incentive” under the CCPA, such as our marketing text messages program and our email marketing campaign. The details of these financial incentives are described in the chart below and are subject to change.
  • You have the right to withdraw from these programs at any time and may do so by following the instructions in the “How to withdraw from the program” column.
  • The value of each incentive is reasonably related to the value of your data, including as applicable: the benefit and insights that we realize and expect to realize from your participation in our programs (such as shopping preferences and habits); the quantity and quality of information that you provide to us through your participation; sales directly or indirectly generated from your participation in the relevant program; and any increased goodwill towards us.