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Privacy Policy January 1, 2020

Privacy Policy

Last modified: January 1, 2020

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

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 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”), including your first and last name, telephone number, postal and email addresses, residence, professional title and organizational affiliation, age, gender, biographic details, user name(s) and password(s), if applicable. We also may request information about your communications needs and preferences. You may provide us with questions, feedback, survey responses or otherwise. You can choose not to provide information, but we may require some information about you to use our Site as intended. We will also collect transactional 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. You may also choose to provide us with medical data, such as information about your medical conditions or your doctor’s information. We also may require some personal information to answer your questions or conduct other transactions on our Site.

You also may provide information (“Posts”) to be published or displayed on public areas of the Site, 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.

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

Our Site also may use web beacons (also known as clear gifs, pixel tags or web bugs). These web beacons 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 Site.

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: Affiliates, service providers, advertising partners, third party partners, direct mail co-op, professional advisors, authorities and other law enforcement, or business transferees.

  • 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.
  • If you were referred to one of our Site 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.
  • 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.
  • 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, 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.
  • We use a third-party co-op to manage marketing mailings and other third parties for media buying. 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. 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 [email protected].
  • 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.

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 Services, 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 you can 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?

  • 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 [email protected]. 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 [email protected].
  • 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” or similar signals. 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: [email protected].

 

Important information for California residents

Scope. This section applies to you only if you are a California resident. It describes how we collect, use and share your Personal Information online and offline when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and your rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In addition, this section does not apply to information we collect from you in the course of providing services to you or receiving services from you where you are an employee, controlling owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. In some cases we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.


Your California privacy rights. You have the following rights under the CCPA:

  • Information. To request the following information about how we have collected and used your Personal Information during the past 12 months:
    • 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 and/or selling Personal Information.
    • The categories of third parties with whom we share Personal Information.
    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient. 
  • Access. To request a copy of the Personal Information that we have collected about you during the past 12 months.
  • Deletion. To request that we delete the Personal Information that we have collected from you.
  • Opt-out. To opt-out of any sales of your Personal Information.
  • Nondiscrimination. You are entitled to exercise the rights described above free from legally prohibited price increases or service quality decreases or other discrimination prohibited by the CCPA.


How to exercise your information, access and deletion rights. You may submit a request to exercise your information, access or deletion rights by visiting this form, calling 1-833-266-2343, or emailing [email protected]. We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. Government identification may be required. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide valid power of attorney or other proof of authority acceptable to us in our reasonable discretion. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.


How to opt out of disclosures to third party marketers. California’s “shine the light” law (California Civil Code § 1798.83) allows California residents to ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to opt out of companies’ sharing of certain personal information with third parties for their direct marketing purposes during the preceding year. You can submit such a request by sending an email to [email protected] with “shine the light” in the subject line. The request must include your current name, street address, city, state, and zip code and attest to the fact that you are a California resident.


California “Do Not Sell My Info” Notice. Like many companies online, we work with third party advertising and social media companies like Google and Facebook that collect your device data and online activity data from individuals who visit our website to help deliver interest-based ads to you, as described above. Our use of these services may constitute a “sale” of your Personal Information as defined under the CCPA. Information about how you can opt-out of use of your information for interest-based advertising is described in the section above. Our participation in a direct mail marketing co-op described above may also constitute a “sale” as defined under the CCPA. You may opt-out of this information sharing by emailing us at [email protected] or filling out the web form here.


Personal Information that we collect, use and disclose. We are required to explain the categories of Personal Information we collect by reference to the categories specified by the CCPA (in bold) in California Civil Code § 1798.140(o), which are described in the list below. For each category, we list the type of data we collect and the source of that data as described in the section above entitled Personal information we collect.

  • Identifiers (general)
    • What we collect: Contact data, Profile data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Commercial information
    • What we collect: Transactional data, Marketing data, Communications
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Financial information
    • What we collect: Transactional data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Identifiers (online)
    • What we collect: Device data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Internet or network information
    • What we collect: Online activity data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Professional or employment information
    • What we collect: Contact data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Medical information
    • What we collect: Research data, Medical data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Protected classification characteristics
    • What we collect: Research data, Medical data
    • Sources: Affiliated entities, business partners, third party platforms, data providers, public sources
  • Inferences drawn from any of the above information to create a profile reflecting your preferences, characteristics, and behavior.


The business/commercial purposes for which we use each category of Personal Information above are described above. The categories of third parties to which we disclose each category of Personal Information above of Personal Information for business purposes are also described above.

The above summary of how we collect, use and share Personal Information and our use of interest-based ads describes our practices for the 12 months preceding the effective date at the top of this Privacy Policy. Information that you choose to provide to us may include other categories of information.