Privacy Policy

THE SYNERGY COMPANY™ PRIVACY POLICY

PRIVACY AND COOKIES NOTICE

Last Updated: February 1, 2025

The Synergy Company™ (herein “Synergy,” “we,” “us” or “our”) 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. As a result, we have laid out the personal information we collect from you when you purchase our products, use our services (including interacting with our website www.thesynergycompany.com, herein “Website”), and make contact or interact with us in any other way.

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 and Website.

Contents

1. Scope of This Privacy Notice

This Privacy Notice applies to anyone who interacts with us in any way in relation to our products and services (for example, providing us personal information through our Website’s online forms when purchasing a product, or when sending us information by email). 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.

2. 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 sole trader, 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 Website, we and our service providers automatically collect and/or store certain information when you visit or interact with the Sites or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Sites. As set forth in more detail below, we may also set cookies or pixels on your web browser or use other tracking technologies when you interact with websites, applications, or advertisements in our network. This allows us to collect certain website usage data and online identifiers. However, such data may be aggregated or anonymized, and while it is not used to identify you as an individual outside of your Device, it may be used for analytics, marketing, and improvement of our products and services. For more information refer to our “Cookies Notice and other Tracking Technologies” section below.

3. Categories of Personal Information We Collect

We may collect various categories of personal information from you, detailed below. We may collect, and may have collected during the previous 12 months:

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);
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.

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 fulfil a legal obligation, and will be protected appropriately as described in the below section entitled “Protection of Personal Information”.

Data and online identifiers we collect through our Website (e.g., through cookies and other tracking technologies) may include IP addresses, preferences, web pages visited prior to coming to our Website and after leaving our Website, 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), and information about how you interact with our Websites (such as pages visited, timestamps, clicks, scrolling, browsing times and load times). For more information refer to our “Cookies Notice” below. We may also collect information about your engagement with our emails, SMS messages, or other communications.

4. What We Use Personal Information for

We use the personal information we obtain about you, and may share it with our service providers or other third parties where we have legal basis to do so, for us to:

Communicate with you, including by sending you updates related to transaction or shipping status, responses to questions or communications you send to us (e.g., via our Website’s online chat functionality, or as a response to communications you have with our Customer Service team), and other relevant service or product-related announcements;
Perform our services, including order fulfilment, maintaining accounts and contracts, providing customer service, fulfilling transactions, or verifying information;
Manage our affiliate, distributor, and customer relationships;
Perform marketing, including providing relevant details and informational updates related to our products, or advertising our products and services online. This could include “remarketing” or “retargeting”, whereby users of our Website may be marketed to on other third-party websites through use of Marketing Cookies – see the “Cookies Notice and other Tracking Technologies” section below for further information. In addition to third-party cookies, remarketing may also involve our use of personal information (such as name and email address) collected from you in prior interactions, which may then be used to provide you with relevant updates, marketing, or other information related to your prior interactions with our products and services;
Administer promotions such as offering product discounts, contests, or other incentives, including sweepstakes, contests, promotions and other offerings;
Undertake research and trend analysis activities to verify, maintain, or improve the quality and types of products and services being provided, including to handle and respond to complaints or questions, analyze your interactions with our products and services, or act on feedback you provide through surveys, product feedback, emails, etc.;
Evaluate job applications and business proposals (e.g., agreements or requests proposed by affiliates and distributors, or prospective affiliates and distributors);
Audit our transactions and interactions, for purposes where we have legal grounds to do so, such as security or for regulatory compliance;
Detect, remediate, and, if applicable, prosecute any physical security or information security-related or criminal incidents, including protecting against any illegal activity such as fraud to ensure the security and integrity of our services;
Enforce our legal rights and obligations (including performance of identity verification to respond to certain requests for information), company policies, and establish, make, or defend legal claims;
Act in the public interest, in line with any laws that apply;
Perform background checks including obtaining and reviewing credit reports for our business-to-business transactions and contracts;
Comply with applicable legal and regulatory requirements, such as reporting to the Food and Drug Administration (“FDA”), and complying with other applicable regulations and industry standards, contracts, and law enforcement requests.

5. Legal Basis for Collecting and Using Your Personal Information

We process your personal information when we have a legal basis to do so. This could include:

You have consented to the use of your personal information in a particular way. When you consent, you can have the right to revoke your consent, however this does not necessarily mean it is possible or that we are obligated to cancel or reverse any previous actions taken based on any consent previously provided. Details of how to exercise your legal rights are set out in the “Your Privacy Rights” section below;

We need your personal information to provide you with services and products, or to respond to your inquiries. In other words, so we can perform our contract or fulfil our obligations as part of any transaction with you or take steps at your request before entering into a contract or transaction;
We have a legal obligation to collect and/or use your personal information, such as to comply with regulatory requirements or to comply with a court order or law enforcement request.

Taking into account applicable laws as well as your individual interests, rights, and freedoms, we may also collect or use personal information for a number of legitimate business interests. These legitimate interests may include:

To manage our relationship with you and any service providers who provide products or services for us. This may include to provide shipping, to check that you have received a service, to validate payment for invoices, and to provide marketing to you;
For research and analysis so that we can monitor and improve our products, services and Websites based on sales trends, Website usage data, and similar;
To enforce or apply our policy terms and conditions or other contracts, or to protect our (or our customers’ or other people’s) rights, property, or safety;
To exercise our rights, to defend ourselves from legal or other claims and to keep to laws and regulations that apply to us and the third parties we work with; and
To take part in, or be the subject of, any sale, purchase, re-structuring, merger or takeover of all or part of our business.

Sometimes we may also request that you provide us with relevant personal information for contractual or legal reasons related to our services, or to enable us to provide our products and services. If you do not provide personal information when requested, this may impact your ability to purchase our products or use our services if that information is necessary to provide you with that product or service.

6. Collection of Personal Information From Minors

Our Websites and 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 Websites, 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 privacy@synergy-co.com.

7. Marketing and Preferences

We or our service providers on our behalf may use your personal information to send you marketing 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 above in the “Legal Basis for Collecting and Using Your Personal Information”, section 5. If you don’t want to receive direct marketing from us, depending on your jurisdiction you may have the right to opt out, withdraw your consent, or object. For example, you may opt out by clicking on the unsubscribe links that appear in emails we send or contacting us at privacy@synergy-co.com to update your contact and marketing preferences and consents. Please also see further details on choices you have relating to cookies in the “Cookies Notice and Other Tracking Technologies” section, and details of other privacy rights you have in the “Your California Privacy Rights” section below.

8. Sharing and Sale of Your Information

We may disclose personal information to service providers and other third parties. Over the last twelve months we may have disclosed to such third parties any of the categories of personal information outlined in the above section “Categories of Personal Information We Collect” as well as in the “Your California Privacy Rights” section below, wherever we have legal basis for such sharing. However, we endeavor to share only the minimum relevant personal information that is required to fulfil the business purpose for sharing such personal information.

We may disclose, and over the previous twelve months may have disclosed, personal information to the following categories of third parties:

Service providers who perform business functions and services on our behalf. This includes service providers who support in the provision, auditing, analytics, management, security of our information technology systems and Website, our marketing and payment processing service providers and partners, and customer service-related service providers (such as those supporting with the hosting and provision of the “Chat” feature of our Website). We also share personal information with service providers for the purposes of fraud detection and prevention.
To distributors or affiliates of our products and services, for example to address inquiries from an affiliate or distributor.
Regulatory authorities, government authorities, courts, or other third parties wherever legally required of us or if we reasonably believe that such action is necessary and can be taken legally to protect the safety, rights or property of Synergy, our employees, our customers, our service providers, any other third parties including distributors or affiliates, or the general public.

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 California Consumer Privacy Act in the California Civil Code 1798.140 section (t)(1). 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 to not sell your personal information. Please see the “Your California Privacy Rights” section below for further details on how to exercise this right.

9. 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 Synergy, 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 privacy@synergy-co.com.

10. 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, regulatory compliance, or legitimate business interests for retaining the personal information for a longer period of time (e.g. to continue to provide relevant product marketing to you, or to maintain records of sales with you to determine future relevant product interests).

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 completely or anonymized. For example, your data can be aggregated with other data so that it can be used in a non-identifiable way for statistical and trend analysis or business planning.

11. Consent to Processing in the United States and Internationally

To provide our services, we deal with a range of third parties including service providers who may be physically located or have technology infrastructure located in the United States of America or other countries around the world. We and these third parties may also rely on global information systems and technologies that transfer data and personal information to other countries. In order to provide you with our products and services (including the functionality available through our Website), and to allow us to process your personal information in line with the purposes set out in this Privacy and Cookies Notice, there may be times where the personal information you provide us with is sent to countries outside those from which you reside or from which you are providing your personal information. This includes information being sent to or from the United States of America and other countries.

By using and accessing our Websites and services, individuals residing or located in or outside of the United States of America agree and consent to the transfer and processing of personal information in the United States of America and other countries. We are committed to protecting the privacy and security of your personal information whenever it is subject to such transfers. We take appropriate steps to make sure that, if we transfer your personal information to another country, appropriate legal basis and security is in place, in line with data protection laws where required. This protection may be set out under a contract with the organization who receives that personal information, or another legal mechanism may be in place that allows us to transfer the personal information.

12. Cookies Notice and Other Tracking Technologies

This Cookies Notice applies when using our Website. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Sites, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):

Cookies. A cookie is a file placed on a Device to uniquely identify your browser or to store information on your Device. Our Sites may use HTTP cookies, HTML5 cookies and other types of cookie technology to store information on local storage.
Pixels: A pixel is a small graphic file that allow us and third parties to monitor the use of the Sites and provide us with information based on your interaction with the Sites. We use the Meta pixel, among others.
Web Beacons. A web beacon is a small tag (that may be invisible to you) that may be placed on our Sites’ pages and messages.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click on.
ETag, or entity tag. An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL.
Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).

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

To allow you to use and access the Sites, including for the prevention of fraudulent activity and improved security functionality;
To facilitate navigation, display data more effectively, collect statistical data, personalize your experience while using the Sites, and recognize your computer to assist your use of the Sites.
To assess the performance of the Sites, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Sites;
To offer you enhanced functionality when accessing the Sites or Services, including keeping track of your specified preferences or to track your online activities over time and across third-party sites; and
To deliver content relevant to your interests on our Sites and third‑party sites based on how you interact with our content.

What is a cookie and how are they used on our Website?

A cookie is a small piece of data that a website – when visited by a user – asks your browser to store on your device to remember preferences and other information, for example previous website or page visits from that device and browser, username or login prompts, or other online behaviors. We use industry standard cookies and other tracking technologies (such as Google Analytics and links to our social media sites like Facebook, Instagram and YouTube) to track your behavior online, assist you in navigation and using intended website functionality (e.g., retaining items in a shopping cart), analytics purposes to gather - and enable your ability to provide - feedback to improve our products and services, or to provide marketing if you visit other websites within our network of marketing service providers.

What choices do you have regarding cookies?

Cookies set by us on our Website are called “first-party” cookies, used to help evaluate and enable performance and functionality of our products and services, including our Website. We also use “third-party” cookies, which are cookies from a website domain other than our Websites. These are used for our website analytics, site functionality, and marketing efforts by sharing usage and device-related data with relevant third parties.

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. For example, you can exercise an opting in or out of certain categories of non-essential cookies (e.g., “Marketing Cookies” as described below), by turning the toggle on or off for these in the cookie consent center. You may update your cookie preferences at any time by accessing our cookie consent center here. 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.

You also can control the use of cookies on most web browsers. Please see the links below to learn how to modify your web browser’s settings on the most popular browsers – on other web browsers, you may need to find a “help” section on the toolbar for more information:

• Apple Safari

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

We may also use pixel tags which are small graphic files that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address from the device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements. You may not be able to disable pixels. If you do not agree to the use of pixels on the Site, please stop using the Site immediately.

Other Tracking Technologies may be used that collect comparable information for security and fraud detection purposes. You cannot disable the Tracking Technologies we use for security and fraud detection.

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 Analytics

In addition to the cookies detailed below, we use Google Analytics 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.

What types of cookies are on our Website and why?

We use the following types of cookies for the following purposes:

• Strictly Necessary Cookies: These cookies are essential for you to browse our Website and use its intended functionality, including accessing secure areas of the Website or moving items to the shopping cart before making a purchase. These cookies cannot be opted in or out of.

• Functional Cookies: These cookies enable the website to provide enhanced functionality. They may be set by us or by third-party service providers whose services we have added to our pages (for example, adding Customer Service Chat support to our site, or allowing you to provide feedback on products and services).

• Performance Cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site.

• Marketing Cookies: These cookies may be set on our Website by our advertising and marketing service providers. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They are based on uniquely identifying your browser and internet device. This recognition is used to serve relevant adverts, links, or other information about our products and services to users visiting other websites after having previously visited our Website or interacted with our products and services. If you consent to these cookies, you may experience targeted advertising.

13. Your Choices About the Information We Collect

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 “Questions and Contacts” 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).

In addition, you can opt out of receiving promotional emails 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 “Questions and Contacts” section below. Your choice will not affect our ability to share information in the other ways described in this Policy.

For information on how to control and adjust your cookie settings, please see the “Cookies Notice and Other Tracking Technologies” section above.

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

14. 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.

California residents have the following rights:

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;
To know the length of time we intend to retain each category of Personal Information;
To know whether your Personal Information is sold or disclosed and to whom;
To access your Personal Information;
To delete the Personal Information you have provided to us, with certain exceptions;
To correct your Personal Information;
To opt out of the sale of Personal Information;
To know if Sensitive Personal Information (“SPI”) is being collected about you, 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;
To limit the use of your SPI if it is used for cross-contextual behavioral advertising or for the purposes of inferring characteristics about you; and
Not to be discriminated against, even if you exercise your privacy rights.

Request for Information, Correction, or Deletion

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, selling or sharing Personal Information;
The categories of third parties to whom the business discloses Personal Information; and
The specific pieces of Personal Information collected about you.

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.

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

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

Category of Personal Information	Examples of this Category	Sources of Personal Information	Business Purpose for Collection
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, Internal Protocol address, email address, account name, social security number, driver’s license number, passport number or other similar identifiers.	You Automatically Third Parties	To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Personal information described in California Civ. Code § 1798.80(e)	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	You Automatically Third Parties	To provide, improve and market our products and Services To provide information you requested To identify potential customers To verify identity To prevent fraud To comply with law
Characteristics of protected classifications under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or credit, marital status, medical condition (AIDS/HIV status, cancer), physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), political activities or affiliations, familial status, source of income status, status as a victim of domestic violence, assault, or stalking.	N/A	N/A
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	You Automatically	To provide, improve and market our products and 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
Biometric information	An individual’s genetic, physiological, biological or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA) or activity patterns that can be used to establish individual identity, including images of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health or exercise data that contain identifying information.	N/A	N/A
Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	Automatically	To provide, improve and market our products and 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
Geolocation data	Physical location and/or movements.	N/A	N/A
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	N/A	N/A
Professional or employment related information	Current or past job history or performance evaluations	N/A	N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	N/A	N/A
Inferences drawn from other Personal Information	Information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	N/A	N/A
Sensitive Personal Information	Social security number, driver’s license number, account log-in, debit, or credit card number in combination with password or PIN, precise geolocation (less than 1850 sf radius), racial/ethnic origins, religious or philosophical beliefs, union membership, contents of e-mails or texts to others, genetic/biometric data, health information, sex life/sexual orientation data	You	Only collected with your express consent to process a transaction with you.

Information related to how long we retain each category of Personal Information is included in the Retention of Personal Information section above.

Personal Information Sold or Shared

We have sold or shared (as those terms are defined in the CCPA) to third parties the following Categories of Personal Information in the last twelve (12) months:

Category of Personal Information	Recipient Categories	Purpose for Sale/Sharing
Identifiers	Advertising, marketing, and analytics providers	Marketing and analytics
Personal information described in California Civ. Code § 1798.80(e)	N/A	N/A
Characteristics of protected classifications under California or federal law	N/A	N/A
Commercial information	Advertising, marketing, and analytics providers	Marketing and analytics
Biometric information	N/A	N/A
Internet or other electronic network activity information	Advertising, marketing, and analytics providers	Marketing and analytics
Geolocation data	N/A	N/A
Sensory data	N/A	N/A
Professional or employment-related information	N/A	N/A
Non-public education information (per the Family Educational Rights and Privacy Act – 20 U.S.C. § 1232g, 34 CFR Part 99)	N/A	N/A
Inferences drawn from other Personal Information	N/A	N/A
Sensitive Personal Information	N/A	N/A

We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age.

Personal Information Disclosed for Business Purposes

We have disclosed the following categories of Personal Information for business purposes in the last twelve (12) months:

Category of Personal Information	Recipient Categories	Business Purpose for Disclosure
Identifiers	Service Providers	Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (not for cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Personal information described in California Civ. Code § 1798.80(e)	Service Providers	Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (not for cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Commercial information	Service Providers	Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services
Internet or other electronic network activity information	Service Providers	Auditing related to ad impressions Helping to ensure the security and integrity of Personal Information Debugging to identify and repair errors Short-term transient use Performing services on behalf of the business Providing advertising and marketing services (other than cross-context behavioral advertising) Internal research for technological development and demonstration Activities to verify or maintain the quality of, improve, upgrade, and/or enhance of our services

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 can opt out of Google Adwords Remarketing here. You can change your Meta/Facebook Ad Preferences here. You can block Google Analytics from accessing your online activity with a browser add-on here. Other options for controlling cookies can be found in the “Cookies and Other Tracking Technologies” section above.

You may also exercise this right by writing to us the information in the “Contact Us” section below, or clicking on our Your Privacy Choices 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. However, we do not collect or provide your Sensitive Personal Information to any third parties.

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.

Third Party Marketing

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. We do not disclose Personal Information protected under this section to third parties for their own direct marketing purposes.

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 using the information in the “Questions and Contacts” section below or by using our webform.

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.

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

We provide the information in this section for compliance with the applicable privacy laws in U.S. States other than California. 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.
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 “Questions and Contacts” section below.

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.

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.

16. 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 Policy.

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.

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 “Questions and Contacts” 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

17. Additional Disclosures About Information

No Automated Decision-Making - We do not use automated decision-making technology to make profiling or behavioral advertising decisions about our users.
No Financial Incentives – We do not provide financial incentives in exchange for any Personal Information provided to us.
No Action Taken For Do Not Track – Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. We do not monitor or take any action with respect to DNT 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. You can learn more about GPC here. Where required by applicable law in certain regions, when we detect such a signal, we will make reasonable efforts to respect your GPC choices.

18. Questions and Contacts

We hope this Privacy Notice has been helpful in explaining the way we handle your personal information and your rights to control it. For any questions or comments in relation to this privacy notice and our privacy practices generally, please contact our Privacy Office who will be pleased to help you by email at privacy@synergy-co.com.

You may also mail requests to The Synergy Company, 2279 Resource Blvd., Moab, UT 84532 or call us toll-free at (800) 723-0277.

To use our webform for privacy requests, please click here.

19. Changes to Our Privacy Notice

We will review and may make updates to our privacy practices from time to time. If we review and/or make any material changes to our privacy practices, we will update this privacy notice and change the effective date at the top of this page. By continuing to use the Website or the Services, you agree to be bound by the new Privacy Policy and Terms of Use.