PRIVACY NOTICE
Last Updated: September 18, 2014
This Privacy Notice applies to the collection, use, and disclosure of personal information in relation to the following Therabotanics (“Therabotanics”) brands:
- WalkFit
- Superthotics
- Ideal Prostate+
- BeFlexible
- Prosvent
- Better Bladder
- Profemin
- Cebria
- Grown American Superfood
- CitraTrim
- Perfect Omega
- Dr. Ho’s Cleanse
UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time-to-time. If we make any material changes, we will revise the date at the top of this Privacy Notice and, in some cases, may provide you with additional notice.
We encourage you to review our Privacy Notice whenever you visit https://therabotanics.com; https://prosvent.com (or https://prosventya.com); https://betterbladder.com; https://trybeflexible.com (or https://beflexibleya.com); https://idealprostate.com (or https://prostataideal.com); https://grownamerican.com (or https://bebidaverde.com) (the “Sites”) or otherwise interact with us to stay informed about our privacy practices.
COLLECTION OF PERSONAL INFORMATION
We may collect or obtain the following categories of personal information through this Sites or by other means, including through any email message, webform, chat box, survey, social media page, event, or other communication or correspondence:
Contact Data | Name, phone number, e-mail, mailing address, and country |
Transaction Data | Purchase and sale information, billing/payment information, shipping and fulfillment information, Customer ID, and details concerning your order |
Message Data | Messages and correspondences, including email, web chat, or web form messages, and any personal information contained therein |
Telephone Recordings | Telephone recordings when you speak with us or our representatives over the telephone, e.g., telephone orders and customer support |
Survey Data | Information you may provide in a survey, poll, or the like, including your responses |
Social Media Data | Information and messages shared with us through our social media pages, including your associated profile information |
Referral Data | Information about you provided to us from other sources, including your email address |
Interaction Data | Information that may be identifiable to you when you access or use the Sites or otherwise interact with us, including: Log Data (e.g., IP addresses, referral URLs, date and time, and crash data); Device Data (e.g., information about your device, including type of device, operating system, application IDs, and unique device identifiers); Browser Data (e.g., information about your browser type and settings, language preferences, and cookie data); and Analytics Data (e.g., approximate geolocation, information about your time of access, session and duration, and your interactions with the Sites) |
Adverse Event Data | Information that you report in relation to an Adverse Event, which may include information about your health, medical history, or treatment |
USES OF PERSONAL INFORMATION
We may use personal information collected about you for the following purposes:
- Presenting the Sites and their contents to you;
- Processing and fulfilling sales orders, including billing and shipment;
- Operating and administering our business;
- Corporate transactions;
- Communicating by email, phone, and other means;
- Providing the product-related mobile applications and features;
- Business insights and product development;
- Sales and marketing, including analytics for tracking and measuring online interactions;
- Detecting and preventing abuse and security threats;
- Reporting Adverse Events;
- Complying with legal and regulatory obligations;
- Providing you with information that you request from us;
- Notifying you about changes to the Sites, our Terms & Conditions, or this Privacy Notice; and
- For any other purpose upon your intention, direction, or consent.
COOKIES AND SIMILAR TECHNOLOGIES
We may use various technologies, including small data files placed on your computer or device when you visit the Sites, such as “Cookies,” “Pixels,” “Web Beacons,” and similar technologies. A Cookie file may contain information that can identify you each time you visit the Sites. The Sites may use Cookies as a way to measure activity and traffic patterns on the Sites in order to improve your experience, monitor usage, compile analytics, and for advertising and marketing purposes.
Your browser can be set to warn you before accepting Cookies and you can choose to refuse Cookies by turning them off in your browser. You do not need to have Cookies turned on to visit the Sites, but you may need them to use certain features of the Sites.
By using this Site, we may share your personal information with Criteo, subject to their privacy policy at: https://www.criteo.com/privacy/
DO NOT TRACK SIGNALS
Under the California Online Privacy Protection Act (“CalOPPA”), we want to inform you about our “Do Not Track” (“DNT”) request policy. DNT is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. While we take all reasonable steps to protect your online privacy, we cannot promise that our current Sites will address every browser setting or preference. Please return to this Privacy Notice for further updates on this topic. You can learn more about DNT here: https://www.eff.org/issues/do-not-track
DISCLOSURE OF PERSONAL INFORMATION
We may disclose any category of personal information and Interaction Data to the following categories of recipients for the purposes described below:
Subsidiaries and Affiliates | We may disclose personal information within the IL family of companies to operate and improve our business and for sales and marketing purposes |
Business Services Providers | We may disclose personal information to our IT services providers, call centers, fulfillment services, and others within our vendor base to operate the Sites and our business and to process and fulfil sales orders |
Specialized Services Providers | We may disclose personal information to specialized services providers, including contractors, business and marketing consultants, security consultants, auditors, information services providers, and professional advisors |
Advertising Services and Networks | We may disclose personal information to our advertising services providers, advertising networks, and social media platforms to deliver advertising and promote our products and brands |
Government and Legal Process | We may disclose personal information to public authorities and third parties as may be required by applicable law, regulation, or legal process, which may include reporting Adverse Event information to the FDA |
Corporate Transaction | We may disclose personal information as part of a corporate transaction e.g., to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of assets, whether as a going concern or as a part of a bankruptcy, liquidation or similar proceeding |
INTERNATIONAL TRANSFER OF PERSONAL INFORMATION
Your personal information may be transferred to countries other than the country from which it originated. Such countries may have different or less protective privacy and data protection laws than the originating country. Where required, IL ensures that international transfers of personal information are subject to an appropriate transfer mechanism or consent.
CALIFORNIA PRIVACY NOTICE
This section supplements the Privacy Notice and applies only to residents of the state of California:
Categories of personal information we collect
We may collect, and have collected in preceding 12-months, the following categories of personal information:
Categories of Personal Information | Purposes for use and disclosure | Source | Disclosed for Business Purpose | Sold or Shared |
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers | Processing and fulling sales orders including billing and shipping; Operating and administering our business; Communicating and providing information requested; Adverse Event reporting; Sales and marketing including analytics; Complying with legal and regulatory obligations; Notifying about changes to the Sites and notices | From you, directly or indirectly, or third-party partners and affiliates | Yes, to Subsidiaries and Affiliates; Business Services Providers; and Specialized Services Providers | Yes, to Advertising Services and Networks |
Personal information described in subdivision (e) of Section 1798.80 (e.g., 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) | Processing and fulling sales orders including billing and shipping; Operating and administering our business; Adverse Event reporting; Complying with legal and regulatory obligations | From you, directly, or third parties | Yes, to Subsidiaries and Affiliates; Business Services Providers; and Specialized Services Providers | No |
Characteristics of protected classifications under California or federal law (e.g., Age 40 years or older, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions, reproductive health decisions, sexual orientation, veteran or military status, genetic information (including familial genetic information) | Adverse Event reporting | From you, directly | Disclosed for legal and compliance purposes | No |
Commercial information including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | Processing and fulling sales orders including billing and shipping; Operating and administering our business; Communicating and providing information requested, Business insights and product development, Sales and marketing including analytics; Adverse Event reporting; Complying with legal and regulatory obligations; Notifying about changes to the Sites and notices | From you, directly or indirectly, or third-party partners and affiliates | Yes, to Subsidiaries and Affiliates; Business Services Providers; and Specialized Services Providers | Yes, to Advertising Services and Networks |
Biometric information | Not collected | Not applicable | No | No |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement | Presenting the Sites and their contents; Business insights and product development; Sales and marketing including analytics; Notifying about changes to the Sites and notices, Detecting and preventing abuse and security threats | From you, indirectly, or third-party partners and affiliates | Yes, to Subsidiaries and Affiliates; Business Services Providers; and Specialized Services Providers | Yes, to Advertising Services and Networks |
Sensory information, such as audio, electronic, visual, thermal, olfactory, or similar information (e.g., recorded meetings and phone calls) | Processing and fulling sales orders including billing and shipping; Operating and administering our business; Adverse Event reporting; Communicating and providing information requested; Complying with legal and regulatory obligations | From you, directly or indirectly, or third parties | Yes, to Subsidiaries and Affiliates; Business Services Providers; and Specialized Services Providers | No |
Professional or employment-related information | Not collected | Not applicable | No | No |
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99) | Not collected | Not applicable | No | No |
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; interaction data collected about you when you interact with us such as websites or mobile apps including log data (information collected when you access our website including IP address, URLs and crash data), device data (information about your device including type, operating system and unique identifiers), browser data (information about your browser type, settings cookie data), | Presenting the Sites and their contents; Operating and administering our business; Communicating and providing information requested; Business insights and product development; Sales and marketing including analytics; Detecting and preventing abuse and security threats | From you, directly or indirectly, or third parties | Yes, to Subsidiaries and Affiliates; Business Services Providers; and Specialized Services Providers | Yes, to Advertising Services and Networks |
Categories of sensitive personal information we collect
From you, directly or indirectly, or from third parties, we may collect, and have collected in preceding 12-months, the following categories of sensitive personal information:
Categories of Sensitive Personal Information | Purposes | Source | Disclosed for Business Purpose | Sold or Shared |
Sensitive identifier (e.g., social security number, driver’s license, state identification card, or passport number) | Adverse Event reporting | From you, directly | Disclosed for legal and compliance purposes | No |
Account information (e.g., account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | Not collected | Not applicable | No | No |
Precise geolocation (within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet) | Not collected | Not applicable | No | No |
Demographic information (e.g., racial or ethnic origin, religious or philosophical beliefs, or union membership) | Not collected | Not applicable | No | No |
Communications content (e.g., mail, email, and text messages unless the business is the intended recipient of the communication) | Not collected | Not applicable | No | No |
Genetic data | Not collected | Not applicable | No | No |
Biometric information processed for the purpose of unique identification | Not collected | Not applicable | No | No |
Personal information collected and analyzed concerning health | Adverse Event report | From you, directly | Disclosed for legal and compliance purposes | No |
Personal information collected and analyzed concerning sex life or sexual orientation | Not collected | Not applicable | No | No |
Retention period or criteria
IL retains personal information for a period commensurate with the purposes for which the personal information was collected or obtained. For example, the criteria used to determine the retention of personal information includes any time necessary to complete a transaction or for legal and compliance purposes or security purposes. Personal information may be retained in archival format (e.g., data backups) beyond its retention period so long as it is not subject to further access.
Sale and sharing of personal information
IL may “sell” or “share” your personal information as described in California Privacy Rights. You may exercise your right to opt-out of the sale and sharing of your personal information by using the methods provided in Opt-out of the sale and sharing of personal information.
Opt-out preference signals
At this time, while we do accept opt-out preference signals, including with respect to global privacy controls, from any platform, technology, or mechanism (e.g., web browsers), we cannot guarantee that our current Sites will address every browser setting or preference.
Personal information of minors
IL has no knowledge of having collected the personal information of minors under 16 years of age.
California Privacy Rights
Under the California Consumer Privacy Act of 2018, as amended, and its respective implementing regulations (the “California Privacy Laws”), eligible California residents may be entitled to certain privacy rights subject to certain limitations, including:
- Right to Know. You may have the right to access the personal information collected about you, the sources from which such information was obtained, the categories of information that have been sold or disclosed for a business purpose, and the commercial purpose for which the information was collected or sold, provided to you in a reasonably portable format.
- Deletion. You may have the right to request that we delete any of the personal information we have collected or maintain about you.
- Correction. You may have the right to correct inaccuracies in your personal information.
- Opt-out of the “Sale” and “Sharing” of Personal Information. You may have a right to opt-out of the “sale” and “sharing” of your personal information.
- Sensitive Personal Information. You may have the right to opt-out of the use and disclosure of your sensitive personal information in certain circumstances.
- Restrict Profiling. You may have the right to restrict the use of your personal information for the purposes of profiling.
- Portability. You may have the right to obtain a copy of certain personal information in portable (e.g., machine readable) format.
- Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
- Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your California privacy rights, such that you will not be denied goods or services, charged a higher rate, or provided with lower quality products or services.
Exercising your rights under the California Privacy Laws
You, or an authorized agent, may exercise your rights by submitting a request here. Unless otherwise required by law, IL will allow two disclosure requests per 12-month period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request.
We respond to legitimate privacy requests within 10 days of receipt and process requests within 45 days unless there is cause for an extension. We will notify you with further information if any extension is necessary. Except with respect to requests to “opt-out” of the sale or sharing of personal information, all privacy requests are subject to proper prior verification before processing. Typically, this means you will be required to verify certain pieces of information we maintain about you, such as name, phone number, date of birth, transaction details, or other information. Requests involving a high risk to personal information may require completion of a Sworn Declaration.
If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity and demonstrate that you can exercise the individual’s rights on their behalf.
Do not sell or share my personal information
IL may “sell” or “share,” and has sold or shared in the preceding 12-months, personal information, such as internet or electronic activity information and unique device identifiers, for cross-context behavioral advertising.
Opt-out of the sale and sharing of personal information
To opt-out of the sale or sharing of your personal information, please visit this link.
Please note that your opt-out choices may apply only to this specific web browser and persist only until the opt-out Cookie is removed or “cleared” from your web browser, e.g., by clearing Cookies in your browser settings.
California “Shine the Light” Law
IL does not share personal information, as defined by Cal. Civ. Code § 1798.83, with third parties for their direct marketing purposes. U.S.
U.S. STATE CONSUMER PRIVACY RIGHTS
Residents of certain U.S. states may have the following rights:
- Access. You may have the right to access the personal information collected about you.
- Deletion. You may have the right to request that we delete any of the personal information we have collected or maintain about you.
- Correction. You may have the right to correct inaccuracies in your personal information.
- Opt-out of the “Sale” of Personal Information, Profiling, and/or Targeted Advertising. You may have a right to opt-out of the “sale” of your personal information, profiling, and/or the use of your personal information for targeted advertising.
- Sensitive Personal Information. You may have the right to consent (opt-in) prior to the use and disclosure of your sensitive personal information in certain circumstances.
- Portability. You may have the right to obtain a copy of certain personal information in portable (e.g., machine readable) format.
- Opt-out of Automated Decision-making. You may have the right to opt-out to certain types of automated decision-making, subject to certain exceptions.
- Non-Discrimination. You may have the right to not be discriminated against in the event you exercise your privacy rights.
Exercising your U.S. state consumer privacy rights
You, or an authorized agent, may exercise your rights by submitting a request here.
Opt-out of the sale of personal information and its use for targeted adverting
To opt-out of the sale of your personal information and targeted advertising, please visit this link.
THIRD-PARTY SITES, BLOGS, AND SOCIAL MEDIA
Our Sites include links to other websites, social media widgets, such as the Facebook “Follow Us” button, and other interactive features, blogs, and videos hosted by third parties whose privacy practices may differ from our own. When you use a link to go from our Sites to an unaffiliated website, or interact with any such features, the privacy policies of those respective third parties will apply to the processing of your personal information.
USE BY MINORS
IL does not knowingly collect personal information from or about minors. Minors should not use the Sites or otherwise provide us their personal information. If we learn that we have collected or received personal information from a minor without parental consent, we will delete that information.
SECURITY OF PERSONAL INFORMATION
Taking into account the nature and scope of the processing and the particular risks to personal information, IL utilizes reasonable technical and organizational measures to help protect personal information. Such measures include, as applicable, the Payment Card Industry Data Security Standards (PCI DSS).
PRIVACY INQUIRIES
For inquiries concerning this Privacy Notice, you may contact:
Ideal Living, LLC
14724 Ventura Blvd, Sherman Oaks, CA 91403
(833) 548-1937
