Privacy Policy Modification Date: May 20, 2019 Hey, it's Louise and Jeremy. We're the co-founders of Nourishing Brands LLC (the "Company"), which owns and operates nourishing.group (the "Website"). Just like you, we care about how our personal information is collected and used online. That's why we want to explain to you the privacy practices we use on the Website and in the Company. Please make sure you read this entire policy to ensure you fully understand our practices. What Information Do We Collect? Most of the information that we collect is not personal to you at all (things like # of total website visitors). However, we also collect some information that is counted as "personal data." On one hand, this can include information that you give us directly – such as when you buy a product from us. That might include: Your name; email address; telephone number; address; your credit or debit card or other payment information; any information you give us when you contact our customer service representatives; and information you give us at other times when you contact us directly. When ordering or registering on our site (or filling out a survey, etc.), you may be asked to enter some of the information above, but you may also choose to visit our site anonymously. We also collect some information indirectly. For example, we might collect your: Internet Protocol (IP) address or other device identifier; Browser type and version; Browsing information, such as pages you view and the links you click, and whether you access our website via a social media site; Time zone setting; Operating system and platform; and Other portable device information. In this second case, as we explain more below, we use this information on an anonymous basis – not to identify you in particular but rather to help us better understand how to optimize the experience for our readers and customers, as well as how to better advertise and market to new and existing customers. This Website also uses "cookies" for a variety of purposes. This is explained more below. When Do We Collect Information? When you visit our website When you purchase products or services from us When you contact our customer service representatives When you engage with us directly on social media How Do We Use the Information We Collect? And What's Our Justification for Collecting It? 1. To Process Transactions and Provide You With Products and Services that You Purchase or Request When you buy a product or service, we use the information you provide (e.g., your email address, shipping address, etc.) to provide you with the information, products, and services that you requested or purchased from us. We also use that information to communicate with you regarding those products and services. When you purchase a product or service from us, you enter into a direct contractual relationship with us, and we rely on that relationship as the lawful basis on which we collect your personal data. We also – in some cases – rely on our legitimate business interests (e.g. to help you with customer service issues). 2. For Internal Business Reasons We use information – both "personal" and otherwise for a bunch of different internal purposes. For example, we might change our website when we see that users aren't finding what they're looking for, or we might improve our products if we get too many refunds. It's in both your interest and also our own business interests to use your personal data in this way, because it allows us to improve our products and services while also making it easier for us to reach users and customers who might benefit from our products and services. 3. For Legal/Security Reasons This really doesn't come up very often, but sometimes we need to use information and personal data to comply with legal obligations. That might mean if a court or government organization requests information, then we'll have to provide it to them. It also means that we have to sometimes use personal information to help do things like detect fraud (e.g. if someone steals your credit card and then uses it on our site). 4. To Personalize Your Interactions With Us One obvious example of personalizing your interaction with us would be using your personal information to look up your order when you email our customer service team. In that case, having access to your particular order lets us answer questions, give refunds, etc. In addition, when we advertise or send out emails and other marketing materials, using personal information allows us to interact with you based on what you want. For example, in the past (and sometimes still), companies would just spam everybody on their email list with the same emails and messages, even if it wasn't relevant to most people. This is one example where we try to use information to provide you with a better, more personalized experience. We also use information and personal data to analyze shopping trends. 5. Other Purposes To administer a contest, promotion, survey or other site feature. 6. General Business Interests We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following: The consent you provide to us at the point of collection of your personal information; The performance of the contract we have with you; The compliance of a legal obligation to which we are subject; or The legitimate interests of Nourishing Brands LLC, a third party, or yourself. "Legitimate interests" for processing your personal information exist where you submit the information with an expectation that it will be processed and there is no undue impact on you. If you disagree or have questions, please contact Jeremy Hendon at support@nourishing.group and we will cease the processing of your data under this legal basis. Who has access to the data we collect? First of all, we don't sell any of your personal data to third parties. It's not profitable for us to do that, and we wouldn't know how to do it if we wanted to (which we don't). However, we do have to share some information and personal data with companies that provide certain services to us. As a quick example, if you order a book from us, we have to share your address with our fulfillment warehouse so that they can ship the book to you, since we don't own the warehouse or the shipping company. That's just one obvious example. Here are a few reasons we might need to share personal information with third parties: 1. To Fulfill Orders This is the example from above. We contract with various service providers for production of products, delivery, processing payments, and other tasks. It is in our legitimate business interests to work with these service providers, since we don't have the ability to provide all of these services ourselves. 2. To Prevent Credit Card Fraud (and Comply with Other Laws) We don't share much information in this respect, but we do need contract with companies to make sure that people aren't committing credit card fraud and other crimes when they buy from us. In that respect, we need to share financial information, including credit card or other payment information with third parties to ensure that payment is safe and secure. 3. Other Services From time to time, we work with other companies that need access to our data – including for our own marketing or advertising interests. This includes using cookies and pixels (see below), which give those third parties what is now considered to be "personal data," even though it's anonymized and doesn't identify you by name, email, or anything like that. We're very careful to make sure these other companies don't get any sensitive information. For instance, we don't even store credit card details, so it's technically impossible for us to share that with anybody. But we also try to provide other companies with as little information as is necessary for them to actually fulfill whatever job they're doing for us. 4. Affiliated Companies We do have other companies that are affiliated with Nourishing Brands LLC or that are under common ownership. In those cases, we may share personal information and data with these other companies for our legitimate business interests. 5. More Generally Here's a broader overview of third-party service providers that help us with processing your personal data, which include, but are not limited to, the following categories: Financial transaction processors (processing your payments) Customer service communication platform Contest and survey platform Email communication manager Marketing funnel providers Website management services Website design and programming services In the course of performing these services, these third-party service providers may have access to your information including your personal information. We will not sell, rent, swap or authorize any third party (except our third-party service providers) to use your email address without your permission. Nothing in this Privacy Policy is intended to restrict our use or sharing of aggregated or de-identified information in any way. Should we sell this website or our business, your personal information will be an asset transferred to the new owner. Other Information Collected Using Technology As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP address, browser type, operating system and other usage information about the use of the Company's services and websites, including a history of the pages you view related to our services. We automatically combine this collected log-information with other information we collect about you. We do this to improve services we offer you, including helping with your customer support requests, sending emails to you at a convenient time, customized recommendations, to improve marketing, and to track access and use of our services. One of the analytics service providers we use is Google Analytics. To learn more about how Google uses data, visit https://policies.google.com/privacy/partners. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. Your Right To Ask For Corrections, Erasure, And Export Of Your Data Depending on where you live and interact with us, you might have different rights. If you want to discuss those rights with us, please contact us. In general, here are some of the rights you might have: The right to be informed: We are informing you now with this policy. The right of access: We'll provide you with the data we have about you. The right to rectification: Request we fix incorrect data about you. The right to erasure: Request we erase certain data about you. The right to restrict processing: Ask us to restrict certain type of processing of your personal information. The right to data portability: Ask us to provide your personal data we have for export. The right to object: Object to how we use your data. Rights in relation to automated decision making and profiling: We don't profile you, but keep in mind you have this right with other sites. If you receive email messages from us, you can use the "unsubscribe" link in each message to withdraw consent and stop the mailings. To exercise any of these rights, please contact Jeremy Hendon at support@nourishing.group with your request. How Long Do We Keep Your Data? Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We will retain your personal data as follows: Opt-ins to our newsletter will be retained for 36 months unless you continue engaging with the newsletters (e.g., by opening the emails or clicking on the links). You may of course at any time unsubscribe and/or ask to have your personal data deleted from our systems. Transactions will be retained for 4 years for tax audit purposes. If a legal claim arises involving your data, we will store and disclose that data until the matter has resolved. Ad Targeting Policy This Ad Targeting Policy describes how we use and share data for online targeted marketing purposes. We may share information about you and other customers collectively (but not specifically identifiable to you) with our parent company, our affiliated companies, and with third parties. This information includes: Demographic information (gender, estimated age, and general geographic location, and your estimated purchase ability); Summarized census information and other publicly available information (estimated education level, homeownership status, and estimated occupation type); and Your inferred and expressed interests, including transactional information and product interests we derive from your visits to some of the sites listed above. The recipients of this information use it to develop and deliver targeted advertising on our websites and on the websites of third parties. The information is used only for marketing purposes. It is not used to make targeted offers that are priced differently based on estimated purchase ability. The targeted advertising resulting from this information sharing is related to common product and service categories, such as magazines, subscriptions, weight-loss programs, supplements, books, events, online summits, and similar categories that you see advertised routinely. These advertisements are not based on data relating to adult content, individual or aggregate health information or records, or information relating to your financial accounts. We use cookies to facilitate the sharing of this information while you are online. Information in these cookies is updated from time to time to ensure that it is up to date and relevant. In order to appropriately safeguard the information in them, as described above, these cookies are encrypted. At this time we do not respond to "do not track" browser signals. We may display various types of advertisements on the sites you visit (including sites such as Facebook and Google) for a variety of reasons. In the same way that we use information about you to customize or personalize the content or services we provide, we may also use information to make the ads you see more relevant for you, and more effective for advertisers. We may also use information from other companies or sites to assist in determining the effectiveness of advertising. In some cases, the ads shown to you are based on your activity on our sites or on other sites or information appended from offline sources. This is often called targeted advertising, behavioral targeting, interest-based advertising, or customized ads. When you visit one of our sites, you may receive a "cookie" or other technology that helps us note, in an anonymized way, that you visited that site. This information is then used to help us display ads that are more relevant, both on our sites and on other sites (including the Google Ad Network, Facebook, Twitter, and other ad networks and social platforms). Note that the information shared with advertising networks is always with a unique identifier, and does not include personally identifiable information such as your name, email address, etc. For example, we use Google to serve advertisements on our websites, which use the Google Doubleclick cookie, and in some cases, a unique device identifier, to show you ads based on your visit to our websites and other sites on the Internet. You may opt out of the use of the Google Doubleclick cookie by visiting the Google ad and content network privacy policy (https://adssettings.google.com/). Your access to our websites should not be affected if you do not accept cookies served by third parties. Consumer Control While it is not possible to turn off all advertising, you can use your browser to control your experience. When you clear the cookies in your browser, you may clear the information used to build a behavioral profile. Depending on the browser you are using, you can also choose to block third-party cookies (such as cookies from ad networks) or browse in a private browsing mode. As new technologies emerge to control your experience, we may provide additional information or instructions to manage your preferences. Many opt-outs are based on a cookie set by your browser that prevents the collection of data connected to a unique anonymous ID. If you opt-out using this method, the opt-out will generally last for 1-5 years. Please note that clearing the cookies in your browser may cancel the opt-out. In conjunction with the Digital Advertising Alliance, we offer the Cookie Protector, which will ensure that your opt-out settings persist regardless of clearing your cookies. If you receive email messages from us, you can use the "unsubscribe" link in each message to withdraw consent and stop the mailings. How do we protect your information? We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. We also protect data by using encryption techniques and other safeguards (such as firewalls and password protection). This means that your data is only accessible to people who need it to carry out their job responsibilities.
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