The Synergy Company™
Privacy and Cookies Notice

Effective Date: July 1, 2026

1. Introduction

Welcome. You have arrived at a website provided by ("The Synergy Company," “Synergy,” “Company,” “we,” “our” or “us”). The Synergy Company™ is a health and wellness company that offers organic dietary supplements and related wellness products under the Pure Synergy brand.

Synergy is committed to protecting and respecting your privacy and personal information. We believe in providing transparency around our privacy practices, including how we collect, use, and share personal information, and your related privacy rights. If you have questions about this Policy after you review it, feel free to contact us at [email protected].

This Privacy Notice applies to personal information we collect in connection with your purchase our products or use our services, your use of or interaction with our website www.thesynergycompany.com (the “Website”), and any other interaction or communication with us through any means, including submitting forms, corresponding via email or postal mail, contacting us by phone, or communicating with us through our social media pages and accounts, such as Instagram, Facebook, and YouTube (all of the foregoing, collectively, the "Services").

This Privacy Notice describes what we do with your personal information, your choices and rights, and how to contact us with any questions. Please read it carefully so you can make an informed decision about your use of our Services.

Please note that the interactions occurring on third-party social media platforms, websites, or applications are also subject to the privacy policies of those respective platform operators.

2. Scope

This Privacy Notice applies to anyone who interacts with us in any way in relation to our Services (for example, providing us personal information through our Website’s online forms when purchasing a product, sending us information by email, or calling our support number). This Privacy Notice provides details about the personal information we collect about you, how we use it as a personal information “controller” (i.e., a company that determines the purposes of and means for data collection, use, and sharing), and how we protect and safeguard your personal information. This Privacy Notice also provides information about your rights as an individual, in relation to this personal information that we collect from you. These rights may commonly be referred to as your “Consumer Rights” which may apply under the California Consumer Privacy Act (“CCPA”) or other state laws, depending on where you reside.

We may also provide you with further legal information and/or privacy notices as necessary, depending on the way we interact with you and the services we provide to you. These may also apply to you, for example, when you consent to them or where they apply to the performance of a contractual arrangement with us.

By using our Site and Services (as defined in the Terms of Use), you acknowledge this policy and agree to our Terms of Use.

3. How We Collect Personal Information

We may collect personal information about you from various sources and channels, including when you use or interact with our Services. This typically includes through your contact with us by phone, physical mail, email, and through interactions with our Website, including any online web forms or chat messages you complete and submit to us. Other interactions may include signing up for newsletters or other marketing materials, and through your contact and interaction with us on social media, blogs, surveys, and/or product feedback communications.

We may also occasionally collect personal information from third party service providers where we have legal basis to do so, for example obtaining credit reporting background check results in relation to our business-to-business relationships with you if you are a wholesale partner, verifying your identity and eligibility for our discount programs, for fraud prevention services, or using our service providers (for example, payment processors).

In connection with our Services, we and our service providers automatically collect and/or store certain information when you visit or interact with Us (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) automatically whenever you visit or interact with our Services.

Usage Information may include:

  • Data and online identifiers we collect through our Website (e.g., through cookies and other tracking technologies) such as IP addresses or other unique identifiers;

  • Your preferences;

  • Web pages visited prior to coming to our Website and after leaving our Website;

  • Name and/or user identification values of third-party platforms or social media sites;

  • Information about browser, network or device (such as browser type and version, operating system, internet service provider, preference settings, unique device IDs and language and other regional settings);

  • Your Device location or other location information, including the zip code, state, or country from which you accessed the Website;

  • Information about how you interact with our Websites (such as pages visited, timestamps, clicks, scrolling, browsing times and load times); and

  • Your engagement with our emails, SMS messages, or other communications.

For location information, some of our Services include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). If you have enabled location services on the Device on which you access our Site, we and our service providers may collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information comes from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used.

If you do not wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

Information Collected from Third Parties

The Site includes functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, our store is hosted by Shopify Inc., which provides the e-commerce platform that enables us to sell our products. Shopify may process your information on our behalf as a service provider, or you may have an existing Shopify account that allows Shopify to provide certain information to us when you create a Synergy account within Shopify. Similarly, we might obtain information about the traffic and usage of Synergy from third parties. We might also provide links to make it easier to send a communication from the Site, or we may use third parties to make it easier to send emails or post to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Synergy.

Synergy does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Information We Infer

We derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchases, we may infer your gender, your interest in certain products or brands, or information about your purchasing activities over time.

4. Categories of Personal Information We Collect

We collect various categories of personal information from you.

We may collect, and may have collected during the previous 12 months, the following categories of personal information:

  • Contact information, such as your name, address, email address, and phone numbers;

  • Marketing and contact consents and preferences, such as consent to receive marketing and/or newsletters, product updates and promotions by email;

  • Certain information that is defined as “Health Information” under applicable Nevada or Washington law, which is detailed in the separate Health Data Notice.

  • Any personal information you send to us in emails, attachments, and other communications that you send us or otherwise contribute (such as product feedback communications or use of our Website chat functionality);

  • Financial details, such as details about your credit or payment card or payment account (including PayPal account), including details of account numbers, payment details, billing addresses, or contact information associated with an account (e.g., email address associated with a PayPal account);

  • Commercial and transaction history such as your purchase history;

  • Relevant personal information for regulatory, contractual, or other legal reasons when you are purchasing our products, using our products or services, or in relation to employment. For example, in the event of any adverse physical reaction when using our products, we request further information and relevant details if required by the Food and Drug Administration (“FDA”) or other relevant third parties;

  • Background check results, which may include credit reporting personal information in relation to our business-to-business relationships with you if you are a wholesale trader;

  • Professional or employment-related information for job applicants, which may include, for example, your job search criteria and preferences, employment and educational history, qualifications and skills, reference information, background check information, compensation or compensation expectations, ability to work in the United States or other countries, languages spoken, and other information contained in your resume;

  • Audio recordings when you contact our customer service helpline to prevent, investigate, and prosecute fraud and other criminal activities; and

  • Inferences or information used to create a profile about you and your preferences to provide a more tailored experience and Services that are aligned with your interests.

Some of these personal information categories we collect may be defined as “sensitive” under differing laws and regulations and require special protections. Such sensitive personal information you provide us with will only be collected where we have a legal basis to do so, such as with your consent or to fulfill a legal obligation and will be protected appropriately as described herein.”

5. How We Use Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

We use your personal information to:

  • Fulfill your orders and provide our services. Process and fulfill orders, manage your account, verify payment, provide customer service, respond to your inquiries and communications (including through our website chat functionality and customer service channels), and confirm shipping and delivery status.

  • Provide product safety information. Send you important product safety notices, product recall information, and other safety-related required communications.

  • Communicate with you about your relationship with us. Respond to questions or requests you submit to us, send you service-related announcements, and maintain records of our interactions and transactions with you.

  • Create Profiles. To create profiles that allows us to send communications and/or advertisements that may be more appropriate for or interesting to you

  • Send you marketing and promotional communications. With appropriate consent or as otherwise permitted by applicable law, send you personalized promotions, special offers, product news, and other marketing content about our brand and products. You may opt out of marketing communications at any time as described in the "Your Privacy Rights" section of this Privacy Notice.

  • Administer promotions and incentive programs. Manage contests, sweepstakes, discount programs, and other promotional offerings you choose to participate in.

  • Publish your content. With your permission, post reviews, comments, or other content you submit through our website.

  • Improve our products and services. Conduct research, trend analysis, and quality improvement activities, including acting on feedback you provide through surveys, product feedback submissions, or other communications.

  • Manage our business relationships. Manage and administer our relationships with affiliates, authorized resellers, distributors, and other business partners, including evaluating applications, proposals, and agreements, and verifying information in connection with business-to-business transactions and contracts.

  • Evaluate employment and business applications. Review and process job applications, vendor proposals, and similar business inquiries.

  • Protect security and prevent fraud. Detect, investigate, and address physical security incidents, information security incidents, fraud, and other illegal or unauthorized activity. Ensure the security and integrity of our services, systems, and data.

  • Comply with legal and regulatory obligations. Meet our obligations under applicable law and regulation, including reporting to the FDA and other regulatory bodies, responding to lawful governmental or law enforcement requests, and complying with applicable industry standards and contractual obligations.

  • Establish, exercise, or defend legal claims. Enforce our legal rights and obligations, defend against claims, perform identity verification where required, and enforce our terms of use and other company policies.

  • Conduct background and credit checks. For business-to-business transactions and contracts, obtain and review credit reports and conduct background checks to the extent permitted by applicable law.

  • Corporate transactions. In connection with or in anticipation of a merger, acquisition, restructuring, sale of assets, or similar corporate transaction involving all or part of our business. Where appropriate, we will take steps to require those parties to protect the information and use it only for the purposes of evaluating or completing the transaction. If the transaction is completed, Personal Information may be transferred to the buyer or successor or affiliate as part of the transferred assets or ongoing business operations.

  • As you direct or with your consent. Fulfill any other purpose at your specific direction or with your express consent.

Finally, we may aggregate, de-identify, and/or anonymize any information collected through the Services such that such information is no longer linked to your personal information. We may use and share this aggregated and anonymized information (non-personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.

6. Use of Cookies and Other Tracking Technologies

We use cookies and other tools (“Tracking Technologies”) to recognize your browser or device, to understand how people use our Site, to make it work correctly, and to improve your experience. These Tracking Technologies store and collect Usage Information. Tracking Technologies may set, change, alter or modify settings or configurations on your Device. By using this Site, you consent to our use of Tracking Technologies – where required by law, we will collect your affirmative consent before using these Tracking Technologies.

What are Cookies?

Cookies are small files that your browser stores on your Device. They help the website remember things like your preferences or whether you’ve logged in. Some cookies are placed by us (“first-party cookies”), and some are placed by our partners (“third-party cookies”) such as companies that provide analytics, video, or advertising. Third-party cookies we use may include Google (AdSense, Analytics, DoubleClick, YouTube), Meta, Microsoft (Bing), or others.

We may use Tracking Technologies for a variety of purposes, including:

  • To allow you to use and access the Website.

  • To prevent fraudulent activity and improve security.

  • To facilitate navigation, display data more effectively, collect statistical data, personalize your experience while using the Website, and recognize your computer to assist your use of the Website.

  • To assess the performance of the Website, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Website.

  • To offer you enhanced functionality when accessing the Website or Services, including keeping track of your specified preferences or to track your online activities over time and across third-party sites.

  • To deliver content relevant to your interests on our Website and third‑party sites based on how you interact with our content.

Do Cookies Contain Personal Information?

Cookies and similar technologies do not always directly identify you, but many laws treat them as “Personal Information” or “Personal Data” when the information collected, alone or combined with other data, can be linked to you or your Device. For example, if you log in to an account, we may associate cookie data with your account

Other Technologies We Use

In addition to cookies, we may use other Tracking Technologies, including:

  • HTML5 local or session storage: browser-based storage used to remember certain settings or behaviors;

  • Pixel tags, clear GIFs and web beacons: small images or snippets of code that load when you visit a page or open an email, telling us or partners that you have engaged with content;

  • Tags, scripts and containers (e.g., tag managers): snippets of code provided by analytics or marketing vendors to measure behavior or deliver functionality, or tools used to deploy and manage other tags (like Google Tag Manager);

  • Software Development Kits (SDKs): a set of tools or code provided by a third party that developers add into an app or website to enable certain features, such analytics, advertising, or login, and that may also collect information from users’ Devices.

  • Embedded Scripts: snippets of code that are designed to collect information about your interactions with the Site, such as the links you click on;

  • Click Identifiers and URL parameters: short tags added to the end of a URL that help track where website traffic comes from, including UTM parameters, such as which email, ad, or social media post a visitor clicked before landing on a page.

  • Device Identifiers and probabilistic identifiers: Identifiers unique to your Device (e.g., mobile advertising IDs), or technology that creates an identifier by analyzing characteristics of your Device or browser.

  • Server-Side Tracking and APIs: technologies that transmit interaction or event data directly from our servers to analytics, advertising or measurement partners (like conversion APIs or server-side tag management);

  • Analytics and Session Replay Technologies: tools that help us understand how users interact with our Services, which may record page views, clicks, scrolling, or other usage activity for analytics and service improvement purposes;

  • Social Media Plugins and Embedded Controls: Features such as “Like” or “Share” buttons, embedded videos, or other third-party content that may collect information when you interact with our Services;

  • Log Files and Network-Level Data Collection: Automatic collection of technical information when you access our Services, including IP Address, browser type, device type, operating system, referring URLs, and timestamps; and

  • Other data technologies may be used that collect comparable information for security and fraud detection purposes.

We may also engage third parties, such as Google Analytics or Meta, to track and analyze non-personally and personally identifiable website data and to serve advertisements. To do so, we may permit third parties to place cookies on devices of users of our Sites, where permitted by law, and subject to your right to opt out through the Sites. We use the data collected to help us administer and improve the quality of the Sites and to analyze the Site’s usage. Such third parties may combine the information that we provide about you with other information that they have collected. These third parties are required to use your information in accordance with this Privacy Policy. We will record all such disclosures and will use reasonable efforts to ensure that such third parties do not use your Personal Information for any purpose that is not expressly provided for herein.

We classify our cookies into the following categories:

  • Essential/Strictly Necessary Cookies. These cookies are need for the Site to work (for example, keeping you logged in or letting the Site load properly). You cannot disable this type of cookie on our Site.

  • Functionality Cookies. Also known as “preference cookies,” these cookies allow the Sites to remember choices you have made in the past, like what language you prefer, or what your username and password are so you can automatically log in. Disabling these cookies can cause some parts of the Site to not work properly, so we discourage you from disabling these cookies.

  • Performance and Analytics Cookies. These cookies collect information about how you use a website, like which pages you visited and which links you clicked on. Their purpose is to improve website functions. In some jurisdictions, you may be able to turn these cookies off.

  • Targeting and Advertising Cookies. These are used by us or our partners to deliver more relevant advertising, measure our marketing, or prevent you from seeing the same ad too many times. These cookies can share that information with other organizations or advertisers. In some jurisdictions, you may be able to turn these cookies off. This recognition is used to serve relevant adverts, links, or other information about our Services to users visiting other websites after having previously visited our Website or interacted with our Services. If you consent to these cookies, you may experience targeted advertising.

Depending on your browser settings or your location, you may be able to:

  • Adjust your cookie preferences through our cookie banner;

  • Block or delete cookies in your browser;

  • Opt out of certain analytics or advertising tools; or

  • Change your Device settings to limit tracking.

If you block some cookies, certain features on our Site may not work as intended.

Advertising Tools We Use

We use Google (AdSense, Analytics, DoubleClick, YouTube), Meta (Facebook), HubSpot, Klaviyo, Microsoft (Clarity and Bing), and other companies’ tools to help us understand how people use our website and to show ads that may be more relevant to you. These tools may use cookies or other identifiers to measure how effective our ads are, learn what content is useful to visitors, or show ads based on your activity on our Site or other sites.

7. Links

For your convenience, the Site and this Policy may contain links to other websites. Synergy is not responsible for the privacy practices, advertising, products, services, or the content of such other websites. None of the links on the Site should be deemed to imply that Synergy endorses or has any affiliation with the links.

8. Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information.

9. Your Choices About the Information We Collect

Updating Your Personal Information

We prefer to keep your personal information accurate and up to date. If you would like to change your contact information and you have a login with us, please make any changes within your account. If you do not have an account with us, please provide any changes or requests regarding your personal information using the information in the Contact Us section below. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).

Communications Preferences

In addition, you can opt out of receiving marketing emails or SMS/Texts from us at any time. You will still receive transactional messages from us. To manage your email preferences with us, please click on the Unsubscribe link in any email you receive from us or contact us using the information in the Contact Us section below. Your choice will not affect our ability to share information in the other ways described in this Privacy Notice.

To opt out of text messages from us, text “STOP” the number that sent you the message at any time. For more information on SMS and text messaging, please see our Terms.

For information on how to control and adjust your cookie settings, please see the information within this policy.

Residents of the jurisdictions below may have additional choices regarding their Personal Information.

Do Not Track Disclosure

Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

Controlling Your Cookies

In some jurisdictions, you can opt-out of cookies by enabling an opt-out preference signal (“OOPS”) or Global Privacy Control (“GPC”) on your browser or opting-out of cookies in our Sites’ cookie preference centers. You may also make individual selections on your Device or browser. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers:

Note that if you turn cookies off, you may be unable to access certain parts or benefit from the full functionality of the Site(s). To learn more about cookies and similar technologies or to opt-out of targeted advertising cookies, visit resources from the Digital Advertising Alliance (“DAA”). We do not control these opt-out links or whether any organization chooses to participate in these opt-out programs.

The first time you visit our Website and depending on your jurisdiction, you may be displayed a banner providing you with information about the use of cookies on our Website, and options for how to opt in or opt out of certain cookies when you visit. This opting in or opting out can be done using our cookie consent center, which is accessed through the cookie banner you are presented. The cookie consent center is accessible by clicking on "Your Privacy Choices" in our Website's Footer. Through the cookie consent center, you can opt in or out of certain categories of non-essential cookies.

You may also opt out of third-party use of cookies and device identifiers in some instances with the relevant third-party directly (see links to our third-party marketing service provider websites below). Alternatively, you may be able to opt out of a third-party service provider's use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your specific device and/or web browser’s settings to block or clear certain cookies, however, note that if you block certain cookies some parts of our Website may not work correctly.

Please note that even if you exercise the opt-out choices above, you may continue to receive advertisements, for example, ads based on the website you are viewing (e.g., contextually based ads), or ads that are not targeted at you and may be less relevant. Also, if your browser (like some Safari browsers) is configured to reject opt-out cookies when you opt out on the DAA or NAI websites, your opt-out may not be effective. We always do our best to honor your choices, but because some choices are set at the browser or device level, you may have to make these choices multiple times if you use different browsers or different Devices.

Google Tools

We use Google Analytics and Google Tag Manager to better understand your use of our Website and Services. Google Analytics collects information such as how often users visit our Website, what pages are visited, and what other sites may have been used prior to visiting. Google uses the data collected to track and examine websites usage, to prepare reports on its activities and share them with other Google services, and to contextualize and personalize the ads of its own advertising network. More information about how Google Analytics collects and processes data can be found here.

Google’s ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can also opt out of and manage your preferences for Google’s use of personalized advertising and related cookies by visiting Google’s Ad Settings, and Google Analytics also offers an opt-out mechanism for the web available here.

Meta

We use Meta Pixel, through which Meta may use information about your activity on our Website to personalize ads you see on Facebook, Instagram, and other Meta services. You can control your ad preferences directly with Meta:

  • Meta Ad Preferences – You can view or change your Facebook Ad Preferences here.

Your Choices for Microsoft (Bing Ads, UET Tag) Tools

If we use Microsoft Tracking Technologies, you can control your ad preferences directly with Microsoft:

  • Microsoft Link to Opt-Out of Targeted Advertising – You can view or change Microsoft Personalized ads and offers settings here.

10. Why We Collect Information

We use the information we collect about you in a variety of ways, including the following:

  • Service providers. We share personal information with third-party service providers who perform functions and services on our behalf, including supporting our information technology systems, Website operations, analytics, marketing and advertising, payment processing, customer service, and fraud detection and prevention.

  • Distributors or affiliates. We may share personal information with our authorized distributors and affiliates where it is necessary to manage our commercial relationships or respond to product or service inquiries.

  • Regulatory and government authorities. We may share personal information with regulatory bodies, governmental authorities, law enforcement, or courts wherever legally required or if we reasonably believe that such disclosure is necessary to protect the safety, rights or property of the Company, our employees, our customers, our service providers, or the general public.

  • Advertising and analytics partners. We may share certain personal information with your consent with advertising networks and website analytics providers for targeted advertising and analytics purposes.

  • Corporate transaction counterparties. In connection with a merger, acquisition, restructuring, or sale of assets, we may share personal information with relevant counterparties and advisors, subject to appropriate confidentiality obligations.

While we do not sell personal information in exchange for monetary consideration, we do share, and over the preceding twelve months may have shared, personal information for other benefits that could be deemed a “Sale,” as defined by the CCPA. This includes sharing of identifiers, commercial information, and internet or other electronic network activity usage data with advertising partners and networks, and website analytics companies. You have the right to direct us not to sell your personal information. Please see the “Your California Privacy Rights” section below for further details on how to exercise this right.

11. Visitors to the Site Outside of the United States

Our Site is not intended for visitors outside of the United States and we do not direct our activities at users outside of the United States. If you are visiting the Site from a location outside of the U.S., your connection will be through and to servers located in the U.S. All information you receive from the Site will be created on servers located in the U.S., and all information you provide will be maintained on web servers and systems located within the U.S. The data protection laws in the United States may differ from those of the country in which you are located, and your information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the United States and in other countries, as set forth in this Policy.

12. Collection of Personal Information From Minors

Our Services are not designed or intended to attract children under 16 years of age, and we are committed to complying with the Children’s Online Privacy Protection Act (“COPPA”). Should we ever need to collect information about children under the age of 16, this will be done only with legal basis such as opt-in consent or consent from the child’s parent or legal guardian. We do not collect any personal information directly from any person if we know that such a person is a child under the age of 16. By accessing our Services, you represent that you are 16 years of age or older. If you believe we have collected Personal Information from a child under the age of 16 without consent, please contact us at [email protected] to request the deletion of such information.

13. Automated Decision Making

We may use Automated Decision-Making Technology (“ADMT”) to support certain aspects of our Services. ADMT refers to systems, software or processes (including algorithms and artificial intelligence) that make a decision or facilitate human decision-making based on the automated processing of your Personal Information. We may use ADMT for security reasons, such as to detect fraudulent or illegal actions, or to protect consumer safety. When we do so, you cannot opt out of the use of the decision-making technology. Depending on how you interact with our Services, the use of ADMT may affect the content, recommendations, or advertisements you see, the security or monitoring applied to your activity, whether certain transactions require additional verification, your access to certain features or service tiers, or automated responses or suggestions provided to you. We do not use ADMT to make decisions that produce legal or similarly significant effects about you.

14. Marketing and Preferences

We or our service providers on our behalf may use your personal information to send you marketing that may be of interest to you through various channels (such as by mail, phone, online, social media, email, or text), however, we only use or share your personal information to send you marketing material if we have your permission (“consent”) or a legitimate interest as described within this policy. Where we rely on consent, you may withdraw it at any time.

To out or update your marketing preferences, click on the unsubscribe link in any marketing email or contact us at [email protected]. For cookie and tracking technology preferences, please see the “Use of Cookies and Other Tracking Technologies” Section. For California-specific rights, please see the “Notice of California Privacy Rights” Section below.

15. Protection of Personal Information

We use reasonable administrative, technical, and physical safeguards to protect your personal information, taking care of its integrity and availability and avoiding its damage, loss, alteration, destruction, or unauthorized use. Personal information collected about you will be handled only by authorized personnel and in compliance with applicable laws and regulations to ensure it is appropriately safeguarded and not inappropriately disclosed.

Ordering through our Website is secure. Our Website has Extended Validation SSL certification, which provides the highest level of assurance that all communication between our order page and your computer browser is securely encrypted. Your credit card payment and accompanying information is submitted by you, in this secure mode, and is encrypted for your privacy. No unauthorized parties may view your personal information while it is in transit to us over the internet.

However, no safeguards can be guaranteed 100% effective in securing all personal information all the time, and across all the environments in which personal information is collected and stored. This includes both internally at the Company, and at our service providers and other third parties. If you have reason to believe that your or others’ personal information is no longer secured appropriately, please immediately notify us at [email protected].

16. How Long We Keep Your Personal Information

Whenever we collect, use, or store your personal data, we’ll keep it for as long as is necessary for the purpose for which it was collected, unless there are or are anticipated to be legal or regulatory compliance, reasons for retaining the personal information for a longer period of time.

We utilize the following criteria to determine the length of time for which we retain Personal Information:

  • How long we have had a relationship with you or provided our Services to you;

  • The business purposes for which the information is used, and the length of time for which the information is required to achieve those purposes;

  • Whether we are required to retain the information, or the information is otherwise necessary, in order to: comply with legal obligations or contractual commitments; defend against potential legal claims; detect or prevent potential illegal activity or actions in violation of our policies and procedures; secure our systems and online environment; or protect health and safety;

  • The privacy impact on individuals of ongoing retention; and

  • The manner in which information is maintained and flows through our systems, and how best to manage the lifecycle of information in light of the volume and complexity of the systems in our infrastructure.

Once we determine that personal information is no longer needed to be retained, it will either be deleted or otherwise rendered into a format that does not allow it to be identified to your Personal Information.

17. Your California Privacy Rights

This section of the Policy applies solely to California residents. We adopt this Section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”). Any terms defined in the CCPA or CPRA have the same meaning when used in this Section.

Notice at Collection of Personal Information We Collect and Purposes For Use

We will collect Personal Information for the business and commercial purposes outlined below. The categories of Personal Information we intend to collect and the purposes for which we use each category are set forth in the table below. We do not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing notice at or before the time the information is collected.

Under the CCPA, “sell” means to disclose, make available, or otherwise communicate Personal Information to a third party for monetary or other valuable consideration. This may include certain disclosures made in connection with advertising or marketing relationships, depending on how the recipient uses the information. “Share” means to disclose Personal Information to a third party for cross-context behavioral advertising. We disclose Personal Information to our service providers and contractors for business purposes (such as analytics, security, support, or website hosting), which is not considered a sale or sharing under the CCPA when the recipient is contractually restricted from using the information for its own purposes. Under the CCPA, a “third party” is an entity that is not a service provider or contractor and that is not controlled by or controlling the business.

We will retain each category of Personal Information for the period reasonably necessary to fulfill the purposes described below unless a longer retention period is required or permitted by law. Please see our "How Long We Keep Your Personal Information" above.

If we sell or share Personal Information or use or disclose Sensitive Personal Information (“SPI”), we indicate that in the table below.

Categories of personal information, business purpose for collection, whether sold or shared, and retention period
Category of Personal Information Business Purpose for Collection Sold/Shared Retention Period
Identifiers: such as name, email, phone number,
postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, or other similar identifiers.

To provide, improve

and market our Services

To provide information you requested

To identify potential customers

To verify identity

To prevent fraud

To comply with law

Yes/Yes Duration of customer relationship with you and/or legal retention periods
Customer Records: such as billing information, account credentials

To provide, improve

and market our Services

To provide information you requested

To identify potential customers

To verify identity

To prevent fraud

To comply with law

No/No 7 years or life of account
Protected Classifications: such as age, race, marital status, gender, veteran’s status

To comply with law

To provide employment benefits

No/No During period of employment (if needed to administer benefits);
Commercial information: such as purchases, transaction history

To provide, improve and market our Services

To provide information you requested or track products/services you have purchased from us

To identify potential customers

To verify identity

To prevent fraud

To comply with law

Yes/Yes Duration of customer relationship with you and/or legal retention periods
Internet or other electronic network activity information: such as browsing history, information regarding interaction with a website

To provide, improve and market our Services

To provide information you requested

To complete a transaction with you

For analytics purposes

To identify potential customers

To verify identity

To prevent fraud

To comply with law

Yes/Yes 2 years or per cookie lifecycle
Non-Precise Geolocation data

To provide, improve and market our Services

To personalize your experience

For analytics and advertising

To prevent fraud

Yes/Yes 2 years or per cookie lifecycle
Sensory data: audio recordings of calls to our customer service line

To improve our Services

To prevent fraud

To comply with law

No/No Duration of customer relationship with you and/or legal retention periods
Professional or employment related information: such as current or past job history and evaluations

To provide benefits

To prevent fraud

To comply with law

No/No During period of employment
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)

To provide benefits

To prevent fraud

To comply with law

No/No During period of employment
Inferences: information used to create a profile about you, such as preferences or likes

To provide, improve and market our Services

To personalize your experience

For analytics and advertising

To prevent fraud

Yes/Yes Duration of customer relationship with you and/or legal retention periods
Sensitive Personal Information: like social security number, precise geolocation (within 1850 sq ft), religious beliefs, contents of emails

To provide Services

To enforce agreements

For account management

To prevent fraud

To comply with law

No/No During period of employment (if needed to administer benefits); during customer relationship for tax or other regulatory purposes

Notice of California Privacy Rights

In addition to the rights set forth in the “Your Choices About the Information We Collect” section above, California residents have the following additional privacy rights:

  • Right to Know (Categories): To know the categories of Personal Information being collected about you, the purposes for which the categories of Personal Information are collected or used, and whether that information is sold or shared;

  • Right to Know (Retention): To know the length of time we intend to retain each category of Personal Information;

  • Right to Know (Specific Pieces): To access the specific pieces of Personal Information we have collected about you;

  • Right to Delete: To request deletion of the Personal Information you have provided to us, with certain exceptions;

  • Right to Correct: To request that we correct inaccurate Personal Information that we maintain about you;

  • Right to Opt-Out of Sale of Personal Information: To direct us not to sell your Personal Information;

  • Right to Opt-Out of Sharing: To direct us not to share your Personal Information for cross-contextual behavioral advertising;

  • Right to Know About Sensitive Personal Information: To know whether we collect Sensitive Personal Information (“SPI”), the categories of SPI being collected, the purposes for which the categories of SPI are collected or used, and whether the SPI is sold or shared;

  • Right to Limit the Use and Disclosure of Sensitive Personal Information: To request that we limit our use and disclosure of your SPI to the purposes permitted by the CCPA; and

  • Right to Non-Discrimination: Not to receive discriminatory treatment for exercising any of your CCPA privacy rights.

Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.

Request to Know, Correct, or Delete

California residents have the right to request, under certain circumstances, that a business that collects Personal Information about them disclose the information listed below for the preceding 12 months:

  • The categories of Personal Information collected about you;

  • The categories of sources from which the Personal Information is collected;

  • The business or commercial purpose for collecting, disclosing, selling or sharing Personal Information;

  • The categories of third parties to whom the business discloses Personal Information;

  • The categories of Personal Information that we sold or shared;

  • The categories of third parties to whom we sold or shared Personal Information; and

  • The specific pieces of Personal Information collected, disclosed, or sold or shared about you.

  • Whether we collected Sensitive Personal Information about you and whether such information is sold or shared, subject to applicable exceptions.

You can also request that we correct or delete your Personal Information. There may be certain exceptions to our obligation to correct or delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Personal Information Collected Within Last Twelve (12) Months

We have collected, used and disclosed the following categories of Personal Information from consumers within the last twelve (12) months:

Categories of personal information collected in the last twelve months, sources, business purposes, and categories of third parties
Category of Personal Information Sources of Information Business Purpose for Collection, Use or Disclosure Categories of Service Providers or other Third Parties To Whom Information is Provided for a Business Purpose Categories of Third Parties To Whom Information is Sold or Shared
Identifiers: such as name, email, phone number You, Automatically, Third Parties Provide services, communication, enforce agreements, personalization, advertising, analytics, improve services, comply with law, account management, processing transactions, security/fraud prevention Data processing and analytics vendors, payment processors, service providers such as website hosting, security vendors, or customer service vendors Analytics and advertising vendors
Customer Records: such as billing information, account credentials You, Automatically, Third Parties Provide services, communication, enforce agreements, personalization, advertising, analytics, improve services, profiling, comply with law, account management, processing transactions, security/fraud prevention Data processing vendors, payment processors, service providers such as website hosting, security vendors, or customer service vendors None
Protected Classifications: such as age, race, marital status, gender, veteran’s status You For employees only - Provide services, communication, personalization, comply with law, security/fraud prevention; provide employee benefits Employee benefits vendors or other service providers for employment services None
Commercial Information: such as purchases, transaction history You, Automatically Provide services, communication, enforce agreements, personalization, advertising, analytics, improve services, profiling, comply with law, account management, processing transactions, security/fraud prevention Data processing vendors, payment processors, service providers such as website hosting, security vendors, or customer service vendors Analytics and advertising vendors
Internet or Network Activity: such as browsing history, information regarding interaction with a website Automatically, Third Parties Improve services, personalization, advertising, analytics, security/fraud prevention Data processing vendors, service providers such as website hosting, security vendors, or customer service vendors Analytics and advertising vendors
Inferences: information used to create a profile about you, such as preferences or likes You, Automatically, Third Parties Improve services, communication, personalization, profiling, advertising, analytics Data processing vendors, payment processors, service providers such as website hosting, security vendors, or customer service vendors Analytics and advertising vendors
Sensitive Personal Information: like social security number, precise geolocation (within 1850 sq ft) You Comply with law, provide employee benefits, security/fraud prevention Employee benefits or corporate wholesale accounts None

Information related to how long we retain each category of Personal Information is included in the "How Long We Keep Your Personal Information" section above.

Do Not Sell My Personal Information

As a California resident, you also have the right, at any time, to tell us not to sell Personal Information – this is called the “right to opt-out” of the sale of Personal Information. We do not sell Personal Information for monetary value, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit, such as via Google Analytics, may be considered a “sale.” You may exercise this right by using the link to “Your Privacy Choices” in our footer.

You may also exercise this right by writing to us the information in the Contact Us section below or clicking on the Do Not Sell My Data link in the footer of our Sites.

Right to Limit Use of Sensitive Personal Information

If applicable, California residents have the right to limit the use of each type of Sensitive Personal Information for each purpose with each type of third-party partner. We do not provide your Sensitive Personal Information to any third parties other than those service providers that are necessary for us to provide our Services to you.

Right Not to Be Discriminated Against

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by California law, we will not:

  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Notice of Financial Incentives -Subscription Program

We offer a subscription purchasing program that provides customers who enroll in recurring purchases with a discounted price per unit compared to single one-time purchases. This price difference may constitute a financial incentive or price or service difference under the CCPA.

To participate in our subscription program, we collect the following categories of personal information: identifiers such as your name, email address, and shipping address; commercial information including your purchase history and product preferences; and financial information necessary to process recurring payments.

We estimate the value of Personal Information collected through our subscription program based on the difference in revenue and customer acquisition costs between subscription customers and comparable one-time purchasers over a twelve-month period, offset by the discount provided. This estimate reflects the economic value of the ongoing customer relationship to our business.

More information about our free Subscribe & Save program is available here. You may cancel your subscription at any time.

Third Party Marketing (“Shine The Light” Law)

If you are a California resident with an established business relationship with us, you have the right under California Civil Code Section 1798.83 to request information regarding the disclosure of your Personal Information to third parties for their own direct marketing purposes in the preceding calendar year. We provide a cost-free option to exercise your right to prevent disclosure of Personal Information as set forth below in “Exercising Your California Privacy Rights.” Please include “Shine the Light Opt Out” in your request. We do not disclose Personal Information to third parties for their own direct marketing purposes if you have exercised your opt out right.

Exercising Your California Privacy Rights

You or your authorized agent may make a request to access, correct, delete, opt-out of the sale of your Personal Information, or limit the use of your Sensitive Personal Information by contacting us as follows:

If you use an authorized agent to submit your request, we may require proof of the written authorization you have given. We also may require you to confirm your identity and your residency to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

18. Your Privacy Rights Under Other U.S. State Laws

If you live in certain other US states, such as Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have rights under applicable privacy laws. These rights are in addition to those rights set forth in the "Your Choices About the Information We Collect" section above. As other states adopt comprehensive privacy laws (such as those anticipated in Alabama, Louisiana, Oklahoma and Vermont), we will modify or update this policy accordingly, but will always provide applicable rights to residents of states that have an effective privacy law.

Based on the applicable law in the state where you live, you may have the following rights with respect to your personal information:

  • To confirm whether or not a controller is processing your Personal Data and to access such Personal Data;

  • To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold, shared, or disclosed and to whom;

  • To correct inaccuracies in your Personal Data;

  • To delete your Personal Data;

  • To obtain a copy of your Personal Data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;

  • To opt out of the processing of your Personal Data for purposes of (i) targeted advertising, (ii) the sale of Personal Data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer;

  • For Minnesota and Oregon residents, you have the right to request a list of the specific third parties to whom we have disclosed your Personal Data.

  • For Nevada residents, you have the right to request certain information from us regarding the collection and sale of your Personal Information during your visit to our websites or when you otherwise interact with us online. If you have sought or acquired, by purchase or lease, any goods or services for personal, family, or household purposes from us, you may ask us to disclose whether we have sold certain information about you for monetary consideration. We do not sell personal information for monetary consideration as defined under Nevada law.

  • For Texas residents, you have the right to learn whether we sell your biometric data or other sensitive personal information to third parties.  We do not collect or sell this information to third parties.

  • Not to discriminate against you because you have exercised any of these rights, including by:

    • denying you Services;

    • charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;

    • providing you a different level or quality of Services; and/or

    • suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, you may make a privacy request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by using the information in the Contact Us section below. Please include your state of residence.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident.

We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

Right to Opt Out

You may have the right to opt out of the processing of your personal information for purposes of (i) targeted advertising, (ii) the sale of personal information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. To exercise your right, please click on the “Your Privacy Choices” or “Do Not Sell My Data” links on the bottom of the webpage where your information is being collected. You may also submit a request to the information in the “Contact Us” section below.

Appeals of Our Decisions

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

19. Your Canadian Privacy Rights

Canadian laws provide specific privacy rights to our Canadian customers. If you are a resident of Canada, this section applies in addition to all other applicable rights and information contained in this Privacy Notice.

Where applicable, we follow applicable Canadian federal and provincial privacy laws (“Canadian Privacy Law”), including:

  • The Personal Information Protection and Electronic Documents Act (PIPEDA)

  • Alberta’s Personal Information Protection Act (Alberta PIPA)

  • British Columbia’s Personal Information Protection Act (BC PIPA)

  • Québec's Act respecting the protection of Personal Information in the private sector (Québec Act).

Consent

In most cases, we rely on implied consent to collect, use, or disclose your Personal Information. In some circumstances, including those involving sensitive Personal Information, we obtain express consent. Where you have provided your consent to the collection, use, and transfer of your Personal Information (whether orally, in writing, or electronically), you may have the legal right to withdraw your consent under certain circumstances. In addition to the methods described above with respect to your privacy choices, you may withdraw your consent by submitting a request using the information in the “Questions and Contacts” section below. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time of your request to help you with your decision.

Use of Your Personal Information

We will not collect, use, or disclose Personal Information except for the identified purposes identified above (See When We Disclose Information), unless we have received additional consent or the processing is authorized without consent. Where we engage service providers who utilize the Personal Information we provide to them, those relationships are governed by a written agreement regarding the confidentiality of your information.

Marketing Communications

By opting into receiving (“CEMs”) (as defined by Canada’s Anti-Spam Legislation (“CASL”)), you confirm that you consent to receiving CEMs from us and our third-party partners. You may withdraw your consent at any time by clicking the unsubscribe link in the CEM or emailing us at [email protected].

Canadian Access and Challenge Rights

Canadian Privacy Law provides the right to receive information about the existence, use, and disclosure of your Personal Information and be provided access to that information. You may also challenge the accuracy and completeness of your Personal Information and have it amended as appropriate. Depending on the nature of the challenged information, amendment may involve correction, deletion, or addition of information.

Exercising Your Canadian Privacy Rights

If you have an account with us, you may view and update your account information (as noted above) directly by logging into your account. To submit a request for access to information not contained within your account, or to challenge the accuracy or completeness of your Personal Information, you may also submit a written request using the information in the Contact Us section below. When submitting a request, we also may require you to confirm your identity and your residency to obtain the information. For emails, please include “Canadian Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Canadian resident and provide your province of residence. We will begin processing your request once you have completed the verification process and will respond within the timeframe required by law.

If we cannot substantively respond to your request in a timely manner, we will notify you and state the reason for the delay. Under certain circumstances, we may not be able to fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, where we cannot verify your identity, or if your request involves disproportionate cost or effort. However, we will respond to your request within a reasonable time, as required by law, and provide an explanation.

Additional information about how to exercise your rights under Canadian Privacy Law can be found here:

  • Office of the Privacy Commissioner of Canada
    Website
    Phone: 1-800-282-1376
  • Office of the Information and Privacy Commissioner of Alberta
    Website
    Phone: 1-888-878-4044
    Edmonton office: (780) 422-6860
    Calgary office: (403) 297-2728
  • Office of the Information and Privacy Commissioner of British Columbia
    Website
    Vancouver: (604) 660-2421
    Elsewhere in BC: (800) 663-7867
  • Commission d'acces a' l' information du Quebec
    Website
    Phone: 1-888-528-7741

20. Your Rights Under the General Data Protection Regulation

This section of the Policy applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopt this section to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this section.

Under applicable law, we are considered the “data controller” of the Personal Information we handle under this Privacy Notice. In other words, we are responsible for deciding how to collect, use and disclose this information, subject to applicable law.

We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take reasonable steps to ensure that the Personal Information that we process is limited to the Personal Information that are required in connection with the purposes set out in this Privacy Notice.

If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

  • The right to access, update or delete the information we have collected from you.

  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right of erasure. You have the right to request deletion of your Personal Information, with certain exceptions.

  • The right to object. You have the right to object to our processing of your Personal Information.

  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.

  • The right not to be subject to automated decision-making, including profiling, that produces legal or similarly significant effects.

Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

  • Contract: To conclude or perform a contract with you; for example:

    • To manage and fulfill orders, facilitate delivery, and to provide other Services;

    • To manage our accounts and records;

    • To handle your inquiries and requests;

    • When you apply for employment through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you send through our Site.

  • Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:

    • For IT security, logging, and access monitoring;

    • To detect, prevent, or investigate security breaches or fraud;

    • To prevent unauthorized access;

    • To respond to your customer service inquiries and requests for information;

    • To maintain, improve, and analyze our Site and Services we offer;

    • For our strictly necessary cookies;

    • To conduct marketing activities; and

    • To facilitate the functionality of our Site.

  • Legal Compliance: To comply with our legal obligations; for example:

    • For anti-money laundering (AML) or know-your-customer (KYC) checks;

    • For sanctions screening;

    • For fraud detection;

    • To maintain appropriate records for internal administrative purposes and as required by applicable law or agency regulations,

    • For required reporting, such as tax, accounting or financial reporting obligations;

    • To respond to legal process or defend ourselves in legal proceedings;

    • To provide important notices as required by law.

    • To maintain appropriate records for internal administrative purposes and as required by applicable law, and

    • To provide important notices required by law (such as product safety information and notice of product recalls).

  • Consent: We rely on consent when we process your Personal Information for purposes that are not necessary for providing our Services, for fulfilling our legal or regulatory obligations, or for pursuing our legitimate business interests. These include:

    • Sending marketing communications, including newsletters, educational content and information about events or services that may be of interest to you;

    • Using non-essential cookies and tracking technologies, such as for analytics, advertising, cross-site tracking, retargeting and behavioral profiling;

    • Collecting optional information in surveys, webinars, beta programs, or promotional events;

    • Enabling certain personalization features that are not required for delivering our Services;

    • Sharing your Personal Information with third parties for their own marketing purposes (only when you have provided express consent).

You have the right to withdraw your consent at any time without affecting the lawfulness of any processing that occurred before withdrawal.

International Transfers

Your Personal Information may be transferred to and processed in countries outside the EEA (like the United States) that may not have the same data protection laws. Where required, we use Standard Contractual Clauses (SCCs) approved by the European Commission; and additional safeguards, where necessary.

How to Exercise Your Rights Under the GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority- a list of authorities is available at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us.

21. Your Rights Under the UK GDPR

This section applies only to individuals located in the United Kingdom at the time their personal information is collected or processed. It supplements, and should be read together with, the rest of this Privacy Notice.

We process personal information as a “controller” under the UK GDPR and the UK Data Protection Act 2018 based on the same legal bases described in the GDPR section above.

  • Contract

  • Legitimate Interests

  • Legal Obligation

  • Consent

Where UK law requires consent (particularly for marketing or non-essential cookies), we will request it separately and clearly.

Individuals in the UK have the following rights:

  • Right of access

  • Right to rectification

  • Right to erasure

  • Right to restrict processing

  • Right to data portability

  • Right to object

  • Right to withdraw consent

  • Rights relating to automated decision-making.

If we share your personal information within Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal information, such as by entering into the UK International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s SCCs, adopted by the UK Government under section 119A of the Data Protection Act 2018, or another lawful transfer mechanism permitted under UK law.

You have the same data subject rights as those for the EU listed above, except that references to the "GDPR" should be read as references to the "UK GDPR" and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office at https://ico.org.uk/.

22. Changes to Our Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Policy on this page and will indicate at the top of the page the modified policy’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy policy. If required by the applicable law, we will notify you of the changes.

By continuing to use the Site or Services or providing us with information following such a replacement Policy being uploaded, you agree that you will be bound by the Privacy Notice as changed.

23. Contact Us

If you have any questions or suggestions regarding this Policy, please contact us as follows:

The Synergy Company

2279 Resource Blvd.

Moab, UT 84532

Email: [email protected]

Contact number: (800) 723-0277

You can also submit a privacy request using our privacy request webform.