Last updated: December 1st 2021.

WELLNESS RESEARCH & CONSULTING INC.
PRIVACY PRINCIPLES

Wellness Research and Consulting Inc. takes your privacy seriously. The following principles guide our treatment of your personal information:

1. We value the trust you place in Wellness Research and Consulting Inc. when sharing your personal information with us.

2. We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.

3. We endeavor to work with you to address your concerns about how we use your personal information.

4. We strive to take steps designed to secure your personal information and reduce the risk it will be misused.

DEFINITIONS

For the purposes of this Privacy Policy:

o Account means a unique account created for You to access our Service or parts of our Service.

o Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

o Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Wellness Research and Consulting Inc. group of companies, websites and brands. For the purpose of the GDPR, the Company is the Data Controller.

o Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

o Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

o Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

o Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

o Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

o Facebook Fan Page is a public profile Facebook Fan Page specifically created by the Company on the Facebook social network.

o Personal Data is any information that relates to an identified or identifiable individual. For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

o Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

o Service refers to the Website.

o Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

o Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

o You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

PRIVACY POLICY – YOUR PRIVACY RIGHTS

This Privacy Policy (“Policy”) describes how the Wellness Research and Consulting Inc. group of companies, websites and brands in the United States (“Wellness Research and Consulting Inc, primalforce.net, mypureradiance.com, searsu.com, alsearsmd.com, store.alsearsmd.com, searsinstitute.com, paceexpress.com”, “we,” “us”, or “our”) collect, use, share and otherwise process personal information in connection with our websites, applications, and other online platforms which link to or display this Policy (the “Platform”). This Policy is not, however, a contract and does not create any legal rights or obligations.

When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you. You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

· Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.

· Payment Information. For example, we may collect your credit card number and billing address.

· Shopping History. For example, we may collect personal information about the items you viewed, added to your cart, purchased or returned.

· Information You Post. We may collect personal information you post in a public space on our Platform, such as on our Ratings & Reviews feature.

· Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.

· Employment Information. If you apply for a job through our Platform, we collect the personal information you include in your application. For example, this may include the name and address of your employer and your employment history.

· Information You Submit. We may collect personal information when you send us a message through the “Contact Us” page or similar features on our Platform. We may also collect personal information when you enter a promotion. This may include photos, videos and other user-generated content that you submit.

· Demographic Information. We may collect your birthdate, age, gender and zip code. We may also collect personal information relating to your hobbies, interests and shopping behavior.

· Device Information. We may collect the type of device you use to access our Platform. For example, we may also collect your device identifier, IP address or mobile operating system.

· Location Information. We may collect precise location information from your device. This may include information about your exact location when you use our Platform or may include information that allows us to approximate your location. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the “Choices Regarding Your Information” section below.

· Log and Analytics Data. If you use our website, we may collect information about the browser you are using. We may look at what site you came from, or what site you visit when you leave us. If you use our app, we may look at how often you use the app and where you downloaded it.

We collect your personal information in the following ways:

· Directly From You. For example, when you:

o Register for an account.

o Purchase products or services through our Platform.

o Sign up to receive promotional communications.

o Request a sample.

o Join a loyalty, rewards or similar program or club.

o Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.

o Use the Ratings & Reviews or related services and features.

o Submit a request to our Consumer Service team.

o Interact with Wellness Research and Consulting Inc. social media pages.

o Apply for a job through our Platform.

· Automatically. For example, when you:

o Install and use Wellness Research and Consulting Inc. mobile apps.

o Visit and navigate our Platform on any device.

o Enable location-based features on our Platform.

o Click on sponsored links or third-party advertisements.

We may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, pixels, Flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.

For more information about our use of cookies and other tracking technologies to collect personal information about you automatically, please refer to the section called “Online Advertising and Third Party Tracking” below.

· From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:

o Our business partners, including online advertising networks, analytics vendors, and companies that co-sponsor our promotions.

o Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.

o Third party sites, including those that allow you to integrate your third-party account with your Wellness Research and Consulting Inc. account.

o Family, friends and others who provide your personal information to us because they think you may be interested in our products and services or they want to share a product or service with you.

o Companies that provide personal information to supplement what we already know about you, including data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information.

· By Combining Personal Information. For example, we may:

o Combine personal information that we collect offline with personal information we collect through our Platform.

o Combine personal information we collect about you from the different devices you use to access our Platform.

o Combine personal information we get from third parties with personal information we already have about you.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information in the following ways:

· To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions.

· To Improve Our Products and Services. We may use your personal information to make our Platform, products and services better. We may also use your personal information to customize your experience with us.

· To Understand Your Interests. For example, we may use your personal information to better understand what products interest you.

· To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.

· To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.

· To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our products, services and promotions. For example, this may include verifying your age, date of birth and state of residence. If you apply for a job through our Platform, we may use the personal information you provide to evaluate your application.

· For Marketing Purposes. We may provide you with information about new products and special offers. We might use your personal information to serve you ads about products and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message.

· For Interest-Based Advertising. We and our third party partners may engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Platform or on other sites, services and mobile applications or on other devices you may use. For more information about your choices related to these communications, see the “Online Advertising and Third Party Tracking” section below.

· For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.

· To Send Push Notifications. If you use our mobile apps, we may send you push notifications about new products or special offers.

· As Otherwise Permitted By Law or As We May Notify You.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information in the following ways:

· Internally. We may share your personal information within the Wellness Research and Consulting Inc. group of companies and brands in the United States (“Wellness Research and Consulting Inc, primalforce.net, mypureradiance.com, searsu.com, alsearsmd.com, store.alsearsmd.com, searsinstitute.com, paceexpress.com”).

· On our Platform. For example, we may display personal information you post on our Ratings & Reviews feature. We may also display personal information you submit in connection with a promotion.

· With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. For example, this may include merchandise vendors and payment processors. It may also include companies that send emails on our behalf or help us run our Platform.

· With Our Business Partners. For example, this may include a third party that co-sponsors a contest or promotion. We may also share personal information with data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers.

· With Third Parties for Marketing Purposes. This may include our affiliate companies or brands or third parties whose products or services we believe you may be interested. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.

· For Business Transactions or Reorganizations. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

· To Comply With the Law or To Protect Ourselves or Third Parties. For example, this could include responding to a court order or subpoena. It could also include sharing personal information if a government agency or investigatory body requests. We might share personal information when we are investigating potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.

· For Other Reasons We May Describe to You.

CHILDREN UNDER 13

Our Platform is intended for adults. We do not knowingly collect or solicit any information from anyone under the age of 13 though our Platform. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have collected personal information from a child under 13, please contact us at support@alsearsmd.com.

CHOICES REGARDING YOUR PERSONAL INFORMATION

Marketing Communications:

You can opt out of receiving our marketing communications. Note that you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries. To opt out of receiving our marketing communications, you can contact us as follows:

· Send us an email at support@alsearsmd.com

· Call us at 1-866-895-8555 (Monday through Friday, 9 AM – 5 PM Eastern)

· Send us a letter at:

Wellness Research and Consulting Inc.
11905 Southern Blvd,
Royal Palm Beach, FL 33411
Re: Wellness Research and Consulting Inc. Privacy Policy

· For promotional emails or text messages, follow the instructions included with the marketing communication.

Mobile Application and Location Based Services:

· You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.

ONLINE ADVERTISING AND THIRD-PARTY TRACKING

Cookies & Other Tracking Technologies:

We automatically collect certain types of usage and device information when you visit our Platform, read our emails or otherwise engage with us. We typically collect this information through use cookies (a small text file sent from a website and stored on your device), web beacons or pixels and similar tracking technologies, and we may utilize third party services to collect this information. For example, these tracking technologies may collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, unique device ID., and about the way you engage with our Platform, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, how frequently you access our Platform, whether you open emails or click the links contained in emails, whether you access the Platform from multiple devices, the products you view and click on, and similar actions you take.

· We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Platform and your user experience.

· Your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

· If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.

Interest-Based Advertising:

We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. We permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our websites and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

· Please note, that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, the options you select relating to interest-based advertising are browser and device specific. If you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.

· You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Google Analytics and Advertising:

We use Google Analytics to better understand how our users interact with our Platform. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Matomo Analytics:

We believe in openness, privacy and 100% data ownership. We are in transitioning our analytics using Matomo in our own servers.

Our Do Not Track Policy:

· Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block or reject cookies, not all of the tracking described here will stop.

· Options you select are browser and device specific.

STATE-SPECIFIC DISCLOSURES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:

· California. If you are a California resident, please click here for additional California-specific privacy disclosures.

· Nevada. Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at support@alsearsmd.com with the subject line “Nevada opt-out”.

SECURITY

The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal infromation you provide to us via the Platform. We have, however, taken certain steps designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. We encourage you to use caution when using the Internet. A user id and a password are needed to access certain areas of the Platform. It is your responsibility to protect your username and password.

STORAGE OF INFORMATION

Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Personal Data related to Orders, Accounts, Memberships, Subscriptions, Auto-Renewal Payments, and for internal analysis purposes for as long as is necessary for the purposes set out in this Privacy Policy.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Payments

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Authorize.net

Their Privacy Policy can be viewed at https://www.authorize.net/en-us/about-us/dpa.html

Square

Their Privacy Policy can be viewed at https://squareup.com/us/en/legal/general/privacy

LINKS TO THIRD-PARTY SERVICES

Our Platform may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Policy. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page https://www.facebook.com/privacypolicies, the Company and the operator of the social network Facebook are Joint Controllers.

The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

Facebook Insights

We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

Category A: Identifiers.Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Examples: A 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. Some personal information included in this category may overlap with other categories.Collected: Yes.
Category C: Protected classification characteristics under California or federal law.Examples: 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), sexual orientation, veteran or military status, genetic information (including familial genetic information).Collected: No.
Category D: Commercial information.Examples: Records and history of products or services purchased or considered.Collected: Yes.
Category E: Biometric information.Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.Collected: No.
Category F: Internet or other similar network activity.Examples: Interaction with our Service or advertisement.Collected: Yes.
Category G: Geolocation data.Examples: Approximate physical location based on IP address.Collected: Yes.
Category H: Sensory data.Examples: Audio, electronic, visual, thermal, olfactory, or similar information.Collected: No.
Category I: Professional or employment-related information.Examples: Current or past job history or performance evaluations.Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).Examples: 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.Collected: No.
Category K: Inferences drawn from other personal information.Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Collected: No.

Under CCPA, personal information does not include:

Publicly available information from government records
Deidentified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

To operate our Service and provide You with our Service.
To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories with the following categories of third parties:

Service Providers
Payment processors
Our affiliates
Our business partners
Third party vendors to whom You or Your agents authorize Us to disclose Your personal information in connection with products or services We provide to You

Sale of Personal Information of Minors Under 16 Years of Age

We do not knowingly collect personal information from minors under the age of 16 through our Service, although certain third party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
- The categories of personal information We collected about You
- The categories of sources for the personal information We collected about You
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom We share that personal information
- The specific pieces of personal information We collected about You
- If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  - The categories of personal information categories sold
  - The categories of personal information categories disclosed
The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
- Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

Click here to find how to contact us.

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

Verify Your identity or authority to make the request
And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
“Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at support@alsearsmd.com or by telephone at 1-866-895-8555 (Monday through Friday, 9 AM – 5 PM Eastern). You may also write to us at the following address: