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CONSUMER RIGHTS UNDER THE U.S. PRIVACY LAWS

Last Updated: December 6, 2023

The information in this Supplemental Privacy Statement describes how we collect, use, disclose and process personal information under the California Consumer Privacy Act, the Virginia Consumer Data Protection Act, the Connecticut Data Privacy Act, the Colorado Privacy Act, and, as of December 31, 2023, the Utah Consumer Privacy Act. We call those laws collectively the “U.S. Privacy Laws.” This section also describes how to exercise your rights under the U.S. Privacy Laws.

Unless otherwise expressly stated, all terms in this Supplemental Privacy Statement have the same meaning as defined in our Privacy Statement or as otherwise defined in the U.S. Privacy Laws.

Categories of personal data we collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”), some of which may be considered sensitive personal data. In particular, we have collected one or more data types in the following categories of personal data from consumers within the twelve (12) months preceding the effective date of this Privacy Statement:

	Category	One or more data types collected?	Disclosed in the past twelve months?
A.	Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Yes	Yes
B.	Any personal data described in Cal. Civ. Code § 1798.80(e), such as name, physical characteristics or description, address, telephone number, credit card number, debit card number, or any other financial information, medical information.	Yes	Yes
C.	Characteristics of protected classifications under state or federal law, such as racial or ethnic origin, or union membership.	Yes	Yes
D.	Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	No
E.	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 web site, application, or advertisement.	Yes	Yes
F.	Geolocation data	Yes	Yes
G.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes	Yes
H.	Professional or employment-related information.	No	No
I.	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.	Yes	Yes

For additional information about the information we collect, see Information We Collect About You.

Categories of sources of personal data

We obtain the categories of personal data listed above from the following categories of sources:

Directly from our consumers (for example, information provided through the Website, or other communications with us).
From consumers’ activity on the Services (for example, Website visit information collected directly or through third-party analytics providers).
From a device’s GPS, Wi-Fi, Bluetooth, or IP address.
From social networks, marketing partners, advertising networks, data analytics providers, internet service providers, operating systems and platforms, data brokers, payment processors, and other sources (for example, affiliates, public and third-party databases, and other third parties, such as business customers/clients).

For additional information, see Information We Collect About You.

Our business and commercial purposes for collecting personal data

We use the personal data we collect for our operational purposes or other purposes set out in our Privacy Statement (See How We Use Your Information). Those purposes may include:

To provide and maintain our Services.
To establish and maintain our business relationship with you.
To notify you about changes to our Services.
To communicate with you about your use of our Services, including to send you reminders, to respond to your inquiries, and for other customer service purposes.
To tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions, and to otherwise personalize your experiences while using the Services. We also leverage the information we collect in aggregate to deliver more relevant advertisements and offers to you on other third-party websites as you navigate the Internet.
To provide you with information that we believe to be of interest to you, including health or wellness-related information or services.
To send you e-mail marketing materials about our products and services.
To send you news and newsletters.
To better understand how users access and use our Services, both on an aggregated and individualized basis.
To handle inquiries and complaints you or other users of our Services submit to us.
To administer surveys and questionnaires, such as for market research or user satisfaction purposes, and for obtaining health and wellness information.
To comply with legal obligations, as part of our general business operations, and for other business administration purposes, such as maintaining customer records, monitoring your compliance with any of your agreements with us, collecting debts owed to us, and safeguarding our business interests.
To verify that you meet the eligibility requirements for purchasing or receiving our Services.
Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, and in situations involving potential threats to the safety of any person or violations of our Terms of Use or our Privacy Statement.
For research and analytics purposes, including analyzing data, identifying trends and issues and creating statistical reports, analyzing the accuracy and effectiveness of our Website and the Services, including administering, troubleshooting, and enhancing and improving the Website and the Services.
For quality assurance and regulatory compliance purposes
To fulfill any other purpose for which you provide the information.
For any other purpose for which we provide you notice, or you provide us with your consent.

We also use the personal data we collect for our commercial or economic purposes, such as attracting consumers to buy, subscribe to, provide, or exchange products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

For information on how we share personal data, see How we share your information.

In the twelve months preceding the effective date of this privacy statement, we have shared information including, identifiers, characteristics, commercial information, and Internet or other electronic network activity information with our business partners in a manner that may constitute a "sale” or “share" under California and similar laws.

In addition, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. For more information about how to opt out of personal information sharing that constitutes a “sale” or “share” under California Law or similar laws, please refer to the Consumer Rights Under the U.S. Privacy Laws’ section below.

Consumer Rights Under the U.S. Privacy Laws

The rights in this section apply only to residents of the states included in the U.S. Privacy Laws. The residents of those states have the following rights:

Right to Know and Access. You have the right to request, free of charge, that we disclose information about our collection and use of your personal information over the past twelve (12) months, including:

The categories of personal information we collect about you;
The categories of sources of the personal information we collect about you;
Our business or commercial purpose for collecting or sharing personal information;
The categories of third parties with whom we share personal information; and
The specific pieces of personal information we collect about you.

Data Portability. You have the right to receive your personal data in an electronic format that allows you to transmit your personal data to another entity without hindrance.

Right to Request Correction or Deletion. You have the right to request the correction or deletion of your personal information that we collected. Once we receive your deletion request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal information not subject to an applicable exception from our records and will direct our service providers to take similar action.

You do not need to create an account with us to exercise your correction or deletion rights. We will only use personal information provided in a deletion request to review and comply with the request.

Right to Request Opt-Out of the Sale or Sharing of Your Personal Information. If you are age 16 or older, you have the right to direct us to not sell your personal information at any time. We do not sell the personal information of consumers we actually know are less than 16 years old. Depending on where you live, you may also have the right to opt out of certain sharing of your personal information for cross-context behavioral advertising purposes or to opt out of the processing of your personal information for targeted advertising.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize the sale or sharing of personal information. However, you may change your mind and opt back in to the sale or sharing of personal information at any time by emailing us.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Right of Non-Discrimination. You have the right to be free from discriminatory adverse treatment for exercising these rights. We will not discriminate against you for exercising any of your rights under the U.S. Privacy Laws.

Right to Withdraw Consent. Where our processing of your personal data is based on consent, you have the right to withdraw consent at any time.

Some of the information we collect and process about you may pertain to your health and your sleep, exercise, or lifestyle habits. To the extent such information is considered sensitive, we only process such information for purposes contemplated by law, such as to provide services you request from us, to conduct analytics, or to verify your information.

Depending on the jurisdiction in which you live, you may have the right to appeal our refusal to take action on your request. You may indicate your intention to appeal in the manner through which your request was originally processed.

To exercise the above rights, you or your authorized representative may submit a request by following the procedures specified in the Submitting a Request under the U.S. Privacy Laws section below.

Submitting a Request Under the U.S. Privacy Laws

Requests to Know and Access, request to Correct or Delete, and request for Data Portability. To exercise your rights described above, you may submit a request by contacting us through one of the following methods:

Online at: https://preferences.takecareof.com/privacy
By phone at 1 (877) 227-3631

Requests to Opt-Out of Sale or Sharing of Your Personal Information. To exercise your right to opt-out of the sale or sharing of your personal information for cross-context behavioral advertising purposes or to opt out of the processing of your personal information for targeted advertising, you may submit a request form via our website at: https://preferences.takecareof.com/dont_sell . You may also submit a request by emailing us at data-privacy@takecareof.com with the subject line “Opt-Out of Sale.” As discussed further in the Privacy Statement, you may also have the ability to reject or toggle off optional cookies through Cookie Settings. We also support the Global Privacy Control, which is described further in the Privacy Statement. Note that because the Global Privacy Control and other choices available to you may be a browser-based mechanism, your opt-out preferences will apply only to the browser from which you exercised that choice.

Right to Withdraw Consent. To exercise your right to withdraw consent, you may send an e-mail to data-privacy@takecareof.com or contact us via the information included in the Contact Us section.

Verification of Requests. Only you, or an individual legally authorized to act on your behalf, may make a request to know, correct, delete, or opt-out related to your personal information. To designate an authorized agent, please contact us by using the contact information above.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, or that the requestor is your authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may request information from you in order to verify your identity. Additionally, we may require that authorized agents provide proof of their authorization. We cannot respond to your request or provide you with personal information if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the personal information relates to you. In general, we will verify your request and your identity by matching certain information you provided with the information we have in our records.

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent, where your identity cannot be confirmed, if applicable, where we must retain your information to comply with legal obligations, or where others provided for under relevant U.S. Privacy Laws. Consumers in some states may also authorize an agent to make data subject requests on their behalf.

You do not need to create an account with us to submit a request to know, or to submit a request to delete your personal information or opt-out of the sale or sharing of your personal information.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

California’s “Shine the Light” Law

California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In order to facilitate these rights, we do not disclose personal information of California residents to third parties for their direct marketing purposes, as defined under California’s “Shine the Light” law, where the resident opts out of such sharing. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, please fill out the following Right to Opt Out form at: https://preferences.takecareof.com/dont_sell, filling in your first name, last name, and email address, which we need in order to process your request and safeguard your data.

PLEASE NOTE: To opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.

Updates to this Supplemental Privacy Statement

We will update this Supplemental Privacy Statement from time to time. When we make changes to this Supplemental Privacy Statement, we will change the "Last Updated" date at the beginning of this Statement. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Supplemental Privacy Statement or other privacy-related matters, please send an email to data-privacy@takecareof.com with “Supplemental Privacy Privacy Statement” in the subject line. Alternatively, inquiries may be addressed to:

NoHo Health Inc.
850 3rd Ave
Suite 601 ATTN: Care/of
Brooklyn, NY 11232

Health Privacy Statement