Privacy Statement

TOPICS:

1) What is “Personal Information”? (Hint: It’s Your Data)
2) What Data Do We Collect?
3) How Do We Collect Your Data?
4) Why Do We Collect Your Personal Information and How Do We Use It?
5) Who Will Have Access to My Personal Information?
6) How Do We Store Your Data and For How Long?
7) Do I Have a Say? (Exercise Your Data Protection Rights)
8) How Do We Protect the Privacy of Children?
9) What Are Cookies and How Do We Use Them?
10) Other Technologies
11) Categories of Recipients
12) Privacy Policies of Other Websites
13) Notice of Financial Incentives
14) Changes to Our Privacy Policy
15) How to Contact Us
16) Contact the Appropriate Authority

We, Iovate Health Sciences International Inc. (together with its affiliates, referred to as “Iovate”, “we”, “us”, “our”) respect and understand your concerns about the privacy of your Personal Information and we commit to treating it in a responsible manner. This Privacy Policy explains what Personal Information we collect about you, why and how we collect that information, how we use and disclose the information, and the choices available to you.

This Privacy Policy describes how we treat Personal Information that visitors (“you”, “your”) provide to us on one of our websites, mobile and social media applications and any other online properties or services that display or link to this Privacy Policy (each or together, the “Site”), or when you otherwise interact with us. Unless otherwise specifically noted, this Privacy Policy does not apply to Personal Information collected from you by third-party web sites or applications to which the Site(s) may link.

Please read this Privacy Policy and our Terms of Use before using the Site and submitting Personal Information to us.

1) What is “Personal Information”? (Hint: It’s Your Data)

“Personal Information” is information that identifies you (or your household) or could be used for such identification, directly or indirectly, alone or in combination, and which is submitted to and/or collected by the Iovate Site. Personal Information may include but is not limited to: name; postal, e-mail or IP address; location data; device identifiers; telephone numbers; biometric data; purchase history; search and browsing history; account information; and cookies collected by this Site in accordance with the Iovate Cookies Settings.

2) What Personal Information Do We Collect?

Iovate may collect various types of Personal Information about you, including but not limited to the following categories:

• Contact and account information. We may collect your name, your telephone number(s), mailing address and e-mail address. We may also collect information you provide to create an account or profile, such as your Site username and password. We may collect your social security or social insurance number(s), including if you are the winner of a contest or sweepstakes.
• Online identifiers and social media information. We may collect online identifiers, such as a social media user identifier if you engage with us through a social media Site.
• Payment information. If you make a purchase from us, we (or our third-party payment processor) may collect and process your billing information, including credit card number and expiration date, and billing address.
• Interest and demographic information. We may collect information such as your age or age range, birth date, gender, favorite products, household or lifestyle information, zip code, hobbies and interests, occupation, income range, religion, ethnicity, dietary preferences, nutrition and exercise habits, or other unique identifiers.
•  Information you submit or otherwise provide or authorize us to collect. We may collect content or information that you post or provide in a public space on the Sites, including but not limited to any comments, videos, photos, personal stories, or product reviews. If applicable, we may collect information such as your height, weight, bodyfat percentage and measurements, areas of interest, fitness goals, exercise patterns, weight-training regimen, eating patterns, experience with diet programs, level of water intake, supplement and other product usage.
• Site usage and device information. We may collect technical information about your device, browser information, mobile carrier, Internet Protocol (IP) addresses or other device identifiers, or Internet Service Provider (ISP) information. We use tracking technologies such as cookies, pixel tags, and other similar technologies to collect information about your use of the Site. This information may include your interaction with the Site, pages viewed, links clicked, app usage, or the websites you accessed before or after using the Site. Our Site uses cookies to help keep track of items you put into your shopping cart, including when you have abandoned your cart, and this information may be used to send you cart reminder SMS messages if you have opted in to SMS notifications. We collect this information to understand how visitors use the Site, improve our services, and enhance your experience on the Site. You may be able to prevent the collection of this information by disabling cookies in your browser settings or by turning off the collection of cookies using our Cookies Settings. 
  
• Location information. We may collect information about the physical location of your device to provide you with location-based services and content, including advertising, promotions and relevant product information. Please note that your location may be detected from your WiFi, Bluetooth, GPS and other device settings, or through information collected by mobile apps or your web browser. You may be able to restrict location sharing by disabling location services within your device settings or preventing certain websites or mobile applications from accessing location information by adjusting your device, app or browser settings. 
• Recruitment and employment-related information. If you apply for a job with us, we may collect information including your education and work history, your skills, and qualifications. If you are employed by us, we may collect additional information, including your social security or social insurance number(s) or banking information.
  
  

3) How Do We Collect Your Personal Information?

Iovate collects information from you that (a) you directly choose to provide when using the Sites or otherwise interacting with us; (b) we automatically collect when you use our Sites; or (c) we receive from third parties.  We collect and process Personal Information in the following ways:

• We collect Personal Information from you directly. For example, when you: purchase goods or receive certain services (e.g., an app); register an account on our Sites; sign up for to receive communications (e.g., newsletters, promotions or SMS messaging notifications); submit a survey or an application; provide content or feedback on a Site (such as giving a product review or posting on a message board); participate in promotions such as contests or sweepstakes; contact Iovate customer service; use or view the Site via your browser’s cookies; or apply for a job.
  
  By providing your Personal Information, you are consenting to the use indicated by Iovate at the time the Personal Information is collected and pursuant to this Privacy Policy, though you may withdraw your consent at any time by contacting us (see Section 15 or click here). If you provide us with any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use such information in accordance with this Privacy Policy.
  
  
• We collect Personal Information about you passively. The Site may collect information about your visits to the Site without you actively submitting such information.  We and our third party service providers may collect Personal Information from you using various automated technologies, such as cookies, pixels and web beacons. We may use these technologies when you use our Site, in emails we send to you, and in media advertising. See the Iovate Cookies Settings for further detail. Generally, information collected through such means cannot be used to identify you without additional identifiable information and Iovate will not connect additional identifiable information with passive information collection technologies in order to identify any individual.
  
  
• We may collect information from third parties. We may collect information about you from our advertising and marketing partners, other business partners or affiliates, public databases that compile information about shoppers and their preferences, or from social media platforms. We may obtain information about your interactions with our ads to improve our services and personalize your experience on the Site.
  
  

4) Why Do We Collect Your Personal Information and How Do We Use It?

We collect your Personal Information to ensure proper functionality of the Sites, so you can:

• Sign up to receive newsletters and other communications from Iovate;
• Contact us (including our Webmaster, customer service representatives, or other employees);
• Complete a registration form, survey or poll;
• Participate in a sweepstakes or contest;
• Make product or service inquiries;
• Purchase products and leave reviews; and
• Participate in interactive portions of the Site.

We collect your Personal Information for business purpose only and, in general, so we can:

• process orders and post reviews;
• communicate with you about your account, orders, purchases, returns, services, promotions, campaigns, programs, contests, or sweepstakes;
• manage your account;
• provide better customer service;
• provide a user-friendly Site experience;
• customize the user experience based on preferences and settings, including customizing the content you see;
• respond to your inquiries and fulfill your requests;
• provide notices regarding Iovate’s products or services (including requested materials, like newsletters and promotions, or product safety information and notice of product recalls);
• allow you to participate in surveys or programs, contests or sweepstakes, and to process rewards or prizes;
• deliver personalized marketing, advertising and promotions with special offers on products and services we think you might like, through channels including email and social media platforms;
• conduct market research, perform analytics, and quality control to determine the effectiveness of our Sites, advertising and promotional campaigns, and to improve our products and services;
• ensure and improve Site functionality (e.g., by compiling statistics, analyzing trends), including managing interactive features of the Site;
• ensure security, including detecting, preventing or investigating potential security incidents or fraud;
• protect our rights, privacy, safety, property, and/or security, and/or that of our affiliates, you or others; and/or
• respond to requests from public and government authorities, including public and government authorities outside of the United States, if applicable.
  
  

Iovate may consolidate the Personal Information of Site users in a non-identifiable form (aggregated and anonymized) to help us better design the Site and Iovate products, to enhance our research activities, and to facilitate other business functions. 

We may combine your Personal Information with information that we collect from other online and offline sources. This information may include, for example: (1) information we receive from visitors when they call us, redeem coupons or complete our surveys or other forms; (2) information visitors submit to us at our retail locations or special events; and (3) updated contact and other information about our visitors that we may receive from third parties.

We will only use your Personal Information if we have a lawful basis: (i) with your consent, freely given, specific, informed and unambiguous; (ii) where necessary for the performance of a contract; (iii) to comply with a legal obligation; (iv) to carry out a task in the public interest; and/or (v) if we have a legitimate interest that outweighs your fundamental rights and interests.

5) Who Will Have Access to My Personal Information?

Iovate does not sell or rent your Personal Information to third parties for money.  
We may share your Personal Information with third parties for the purposes set out in this Privacy Policy as follows:

• with our affiliates, including all direct and indirect subsidiaries or parent companies, and any future related companies;
• with our third party service providers or vendors who provide services to us or on our behalf, including but not limited to website hosting, email delivery services, processing payments, fulfilling orders, helping us deliver products or services, credit reference agencies, data analytics or market research, and advertising and related services (such as running our promotions or marketing campaigns, or providing targeted advertising based on your interests);
• with third party business partners, such as joint promotion partners (including retailers);
• if we believe it is required to comply with legal obligations or protect Iovate (including to respond to a court order, subpoena, or request from a government agency or regulatory body); or
• with any successor to all or part of our business, assets or stock (including one of our brands, product lines or divisions), in the event of any reorganization, sale, merger, joint venture, assignment, transfer or other disposition (including in connection with any bankruptcy proceeding).
  

We may share aggregated or anonymous Personal Information about Site users with its our affiliates, partners and other third parties.
If you have opted-in to receive SMS notifications, we will not share your SMS opt-in information or your SMS consent status with any third party for purposes unrelated to SMS messaging services without your explicit consent, except to comply with legal obligations. We may share your Personal Information with third party service providers including platform providers or phone companies as necessary to provide our SMS messaging notifications.

Your Personal Information will only be accessed for the purpose(s) described in this Privacy Policy, by a restricted number of Iovate or affiliate company employees on a need-to-know basis and in accordance with the instructions of Iovate pursuant to this Privacy Policy.  Iovate trains our employees about the importance of privacy and how to handle and manage customer Personal Information appropriately and securely.

Iovate operates on a global basis and may transfer your Personal Information to a country other than your own. Personal Information stored in another jurisdiction is subject to the laws of that country. For example, Personal Information that is transferred to and stored in the United States may be available to the U.S. government or its agencies under a lawful order made in that country. Iovate reserves the right to disclose your Personal Information to respond to authorized information requests from government authorities, when otherwise required by law, or where necessary to protect the rights, property or personal safety of another individual if such disclosure does not override your rights to the privacy of your Personal Information.

In certain cases, we may give you the option to opt-in to receive marketing, promotional or other information from one of our partners or another third party. If you chose to opt-in for that, we will provide your Personal Information to that third party. BY CHOOSING TO OPT-IN TO A THIRD PARTY DISCLOSURE OF YOUR PERSONAL INFORMATION, YOU ACKNOWLEDGE THAT ONCE YOUR PERSONAL INFORMATION HAS BEEN SHARED WITH THAT THIRD PARTY, THE SUBSEQUENT SAFEGUARDING OF YOUR PERSONAL INFORMATION WILL BE GOVERNED BY THAT THIRD PARTY’S PRIVACY POLICY, AND ANY REQUEST FOR FURTHER INFORMATION WITH RESPECT TO THEIR INTENDED USE AND/OR TO CHANGE YOUR MARKETING PREFERENCES WITH THAT THIRD PARTY SHALL BE DIRECTED TO THAT THIRD PARTY (AND NOT TO IOVATE).

If you have previously opted-in to receive such information from us or a specific third party, declining to opt-in at any future time for us or that third party will not be treated as an opt-out for your marketing preference.

Please remember that if you post any Personal Information in public areas of the Site, such as an online forum or chat room, this Personal Information may be collected and used by others over whom Iovate has no control. Use caution when posting Personal Information in public forums. Iovate is not responsible for the use made by third parties of Personal Information you post or otherwise make available in public areas of the Iovate Site. 

6) How Do We Store Your Personal Infromation and For How Long?

We use reasonable measures including technical, physical, and organizational / administrative safeguards (e.g., encryption, anonymization) to securely store your Personal Information and help protect it from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free, so your use of the Site and the Personal Information you provide is at your own risk.

In general, Iovate will only store your Personal Information for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods imposed upon Iovate by applicable law and any other legitimate legal bases.  Once the purpose for which the Personal Information was collected is fulfilled, we will ensure we securely destroy or overwrite your Personal Information, unless we are required or permitted to retain it by law or regulations (including for tax or record keeping purposes).

To see how long we keep the cookies we collect, refer to the Cookie Settings.

7) Do I Have a Say? (Exercise Your Data Protection Rights)

You may limit the amount and type of Personal Information that Iovate receives about you by choosing not to enter any Personal Information into forms or data fields on the Iovate Site. Some online services can only be provided to you if you provide us with appropriate Personal Information. Other parts of the Iovate Site may ask whether you wish to opt into our contact lists for offers, promotions and additional services that may be of interest to you.

If you have opted in to receive promotional emails, SMS messages or other communications that you no longer wish to receive, please contact us, or follow the instructions of any promotional communication from us (such as clicking “unsubscribe” to emails or “STOP” to SMS messages).  If you have opted-out of receiving communications from Iovate that you previously signed up for, we may still send you non-marketing emails when permitted by law (for example, to confirm or fulfill an order that you place or to respond to you), and any information submitted / collected will still be subject to this Privacy Policy and our Terms of Use, unless and until such time you request the exercise of certain rights (e.g., right to deletion).

You may also be provided with preference questions or preference boxes, allowing you to indicate that you do not want the Site to use tracking technologies, such as cookies, to “remember” your Personal Information, such as user IDs or mailing addresses, on return visits. Some Internet browsers allow you to limit or disable the use of tracking technologies that collect unidentifiable information.

Depending on your state, you may have other choices under applicable laws, which may include the following:

• The Right to Access. You may have the right to make reasonable requests for further details on what Personal Information we collect about you, and how we use, share and retain it (as applicable). Depending on your state, you may also have the right to request the specific categories of information we collect about you, the categories of sources from which that information is collected, and the categories of third parties with whom we have shared that information. You may make one (1) request per year for your Personal Information free of charge; we may charge a small fee to cover administrative costs of responding to any additional requests in the same twelve (12) month period.
• The Right to Correct. You may have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request us to complete the Personal Information you believe is incomplete.  We will also take reasonable steps to ensure that your Personal Information remains accurate and complete.
• The Right to Delete. You may have the right to request that we delete your Personal Information, under certain conditions. We may retain certain Personal Information where permitted by law, such as for tax or other recordkeeping purposes, or to process transactions and facilitate customer requests.
• The Right to Object to, or Restrict / Limit Processing. You may have the right, under certain conditions, to ask us to stop using all or some of your Personal Information (e.g., if you do not believe we have a lawful basis) or to limit our use (e.g., you may wish to permit us to use some but not all of the Personal Information we request).  
• The Right to Data Portability. You may have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions. You may make one (1) request per year for your Personal Information free of charge; we may charge a small fee to cover administrative costs of responding to any additional requests in the same twelve (12) month period.
  

To exercise one of your rights listed above, please click here to submit your request.  All requests will be verified before any Personal Information is disclosed.  We will respond to requests as soon as possible and generally within thirty (30) days.  We will respond in a manner accessible to you, which is typically a format recognizable by most software applications (e.g., email, .xsl).  We will retain a record of all requests for a minimum of twenty-four (24) months.

You will not be discriminated against because you object to or limit our use of your Personal Information and, to the extent possible, we will continue to make our Site and other services available to you. If you are not satisfied with our use of your Personal Information or our response to any exercise of these rights, please let us know so that we have the opportunity to address your concerns.  

8) How Do We Protect the Privacy of Children?

Iovate does not knowingly collect or use any Personal Information from children (we define “children” as persons under the age of 18) or allow children to disclose their Personal Information on the Site. We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent or guardian and become aware that your child has provided us with information, please contact us by clicking here or using one of the methods specified below, and we will work with you to address this issue.

9) What Are Cookies and How Do We Use Them?

Cookies are small text files that are transferred to your computer’s hard disk by a Site. Web beacons (also referred to as GIF files, pixels or Internet tags) help Iovate recognize a unique cookie on your browser. When you visit a Site, we will automatically collect cookies once you consent.  If you do not wish for us to collect your cookies, you can disable the cookies (including Performance, Functional and Targeting Cookies), with the exception of Strictly Necessary cookies, which are necessary to ensure functionality of a Site.  

See our Cookies Settings for further information. 
Keep in mind that cookies allow you to take advantage of some of the features available on a website.  For this reason, we recommend that you leave them turned on. For instance, if you block or otherwise reject our cookies, you will not be able to add items to your Shopping Cart, proceed to Checkout, or use products or services that will require you to Login.  If, at any time, you would like to turn a Cookies setting on or off, you may do so (click here).

10) Other Technologies

Do-Not-Track
“Do-Not-Track” signals (DNT) is a concept that has been promoted by regulatory agencies such as the U.S. Federal Trade Commission (FTC) to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across sites by using browser settings.  The World Wide Web Consortium (W3C) has been working with industry groups, Internet browsers, technology companies, and regulators to develop a DNT technology standard.  While some progress has been made, it has been slow.  No standard has been adopted to this date and, as a result, we do not currently monitor or follow “do not track” signals.

Global Privacy Control
Iovate respects Global Privacy Control preferences in states where it is required by relevant privacy laws.

Automated Decision-Making
We do no use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning or otherwise significantly affecting you.

11) Categories of Recipients

In this section we provide a list of the categories of Personal Information we have collected or used in the preceding 12 months, and the categories of recipients to whom we disclose information for business purposes or cross-context behavioral advertising. 

Category of Personal Information	Categories of Recipient
Identifiers (e.g., name, street address, phone number, IP address, email address)	Affiliates and subsidiaries, advertising networks, marketing partners, data analytics and market research providers, payment processors, fulfilment partners, customer support partners, Internet service providers, operating systems and platforms, other users, fraud prevention partners, cloud service providers, technical maintenance and system security providers
Demographic Information (e.g.,	Affiliates and subsidiaries, advertising networks, marketing partners, data analytics and market research providers, customer feedback platforms, fraud prevention partners, cloud service providers
Commercial Information (e.g., record of your purchases)	Affiliates and subsidiaries, data analytics and market research providers, advertising networks, marketing partners, payment processors, fulfilment partners, customer support partners, and fraud prevention partners, cloud service providers
Biometric Information (e.g., images or information about your physical activities that you provide)	Affiliates and subsidiaries, marketing partners, data analytics providers, Internet service providers, operating systems and platforms, fraud prevention partners, cloud service providers
Internet or other Electronic Network Activity	Affiliates and subsidiaries, advertising networks, marketing partners, data analytics and market research providers, Internet service providers, operating systems and platforms, cloud service providers, fraud prevention partners, cloud service providers, technical maintenance and system security providers
Location Information (including geolocation data)	Affiliates and subsidiaries, advertising networks, marketing partners, data analytics and market research providers, Internet service providers, operating systems and platforms, fraud prevention partners, cloud service providers
Audio, electronic, visual, or similar information	Affiliates and subsidiaries, customer support partners, data analytics and market research providers
Inferences	Affiliates and subsidiaries, advertising and marketing networks, data analytics and market research providers

We do not share your Personal Information with third parties for their own direct marketing purposes.

12) Privacy Policies of Other Websites

The Site may contain links to other third-party websites or applications that we do not control. Our Privacy Policy applies to our Site only, so if you click on a link to an external website or application, please read their privacy policy.  We are not responsible for the information that a third-party website or application may collect about you, even if you accessed the website or application via our Site.

Our Site may also include social media features (e.g., share or like buttons). Such features are provided by third-party social media platforms such as LinkedIn, Twitter, Facebook, Instagram, SnapChat, and Pinterest. Where Personal Information is collected this way, its processing is governed by the privacy policy of the respective social media platforms.

13) Notice of Financial Incentives

We may offer various financial incentives. For example, we may provide discounts or other benefits to customers who sign up to receive our marketing emails. When you participate in a financial incentive, we collect Personal Information from you, such as identifiers like your name and email address. You can opt into a financial incentive by following the sign-up instructions, and you have the ability to opt-out of the incentive by contacting us. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your Personal Information is reasonably related to the value of the offer or discount presented to you.

14) Changes to Our Privacy Policy

Iovate conducts regular reviews of this Privacy Policy and we may update this policy from time to time to reflect technological advancements, legal and regulatory changes and good business practices. We will notify you of such changes by posting the updated Privacy Policy and updating the “Last updated” date at the top of the Privacy Policy.  Please ensure you check the Privacy Policy each time you visit the Site to review any changes. Your continued use of the Site indicates that you accept the revised Privacy Policy. Nevertheless, any time our cookies collection practices change, you will be separately notified and asked to accept or reject the cookies.

15) How to Contact Us

If you have any questions about the Data we collect, this Privacy Policy, or if you would like to make a suggestion, please click here; however, if you wish to exercise one of your specific Data protection rights, you can use any of the following ways to communicate with us. You may complete an on-line request click here or reach out to us:

By Email to: privacy@iovate.com

By Mail to: Iovate Health Sciences International Inc.
Legal Department
Attention: Data Privacy & Security Officer
381 North Service Road West
Oakville, ON L6M 0H4 Canada

By Telephone to: 905-678-3119
1-888-334-4448 (North America only)

16) Contact the Appropriate Authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the relevant data protection / supervisory authority in your area.  We would, however, appreciate the chance to deal with your concerns before you exercise that option.  We will respond to any communications from you in an expedient manner and, in any event, within thirty (30) days.