Privacy Policy

Privacy Notice

Our websites are presentation websites designed to improve customer knowledge and be able to read information and chose to purchase health products and/or any other digital or physical products in an online environment. We’ve developed this Privacy Notice (“Notice”) to explain to you how we collect, use, disclose, and store personal data on our website: stimulatingwellness.com

This refers collectively to all our websites, as well as all other websites that we operate or had operated in the pass and may not work or were disabled.

This Notice only applies when our websites is the controller of personal data (example: our websites visitor’s personal data and business-to-business contact data). Our websites are not a controller, of personal data that we process on behalf of our subscribers and viewers when they use our products and services. For clarity, this means that this Notice does not apply to our group of products and services. If you have questions related to how a 3rd party partners/affiliates/service providers/etc. utilizes your personal data, please contact them directly. We are not responsible for the privacy or data security practices of our viewers and subscribers. This Notice also does not apply to personal data about current and former employees, job candidates, or contractors and agents acting in similar roles.

We use the information we collect from you while you are using our websites in a variety of ways, including using the information to customize features; advertising that appear on the site; and, making other offers available to you via email, direct mail or otherwise. We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using our websites in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services. If you do not wish your information to be used for these purposes, you must send an email to our address in the Contact section requesting to be taken off any lists of information that may be used for these purposes or that may be given or sold to third-parties.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Some of our third-party advertisers and ad servers that place and present advertising our site also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure and research the advertisements’ effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third-party’s privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party’s use of cookies or web beacons or use of your information, you should visit that party’s website and review its privacy policy.

The websites also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services.

We may also make some content, products and services available through our websites or by emailing messages to you through cooperative relationships with third-party providers, where the brands of our provider partner appear on the Site in connection with such content, products and/or services.

We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of our provider partner may apply to the provider partner’s use of your information. The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property or safety of users of the Site or the public.

Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.

We share your information with third parties who help us in the delivery of the products and services you have requested.

We share your information with companies and individuals we employ to perform technical functions on our behalf. Examples include third parties who host our website, analyze our data, provide marketing assistance, process credit card payments, and provide customer service.

We share your information with third parties who will provide you with their opportunities, products or services. This includes your personal and non-personal information, and includes your interests and preferences, so they may determine whether you might be interested in their products or services.

We share aggregated anonymous information about you, combined with other persons using our website with third parties, so that they can understand the kinds of visitors that come to our website, and how those visitors use our website. This includes demographic information and behavioral information.

We disclose your information if legally required to do so, or at our discretion, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to (a) conform to legal requirements or comply with legal process; (b) protect our rights or property, or our affiliated companies; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.

Finally, we may disclose and transfer your information to a third party who acquires any or all of our business, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In the event we become the subject of an insolvency proceeding, whether voluntary or involuntary, we or our liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of, such information in a transaction approved by the court.

Google Analytics

We also use Google Analytics Advertiser Features to optimize our business. Advertiser features may include and the list is not exhaustive:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting
•  

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site.

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting their websites.

Facebook

As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook’s Data Use Restrictions.

• Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
• We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
• We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
• We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

Changes to Privacy Policy

We reserve the right to make material changes to the substance of this Privacy Policy. We will post those changes through a prominent notice on the website, so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

When Does This Notice Apply? This Notice only applies to personal data that our group handles as a Controller (meaning where our group controls how and why your personal data is processed). This includes when you:

• Visit or interact with our website,
• Register for or participate in our webinars, events, programs, marketing, and promotional activities;
• Subscribe to our newsletter or access commercials and products that may appear on the website or are presented in our emails.
• Interact with us in person, such as when you visit our offices; and
• Inquire about or engage in commercial transactions with us or our partners.

Changes: We may update this Notice from time to time. Please check back periodically for updates. If you do not agree with any changes we make, you should stop interacting with us. When required under applicable law, we will notify you of any changes to this Notice by posting an update on our site or in another appropriate manner.

2. Personal Data We Collect and Disclose

The below table describes what personal data we collect about you and to whom we disclose personal data. California individuals: This table includes the parties we disclose personal data to for a business or commercial purpose, as defined by California law.

Categories of Personal Data Collected	Disclosures of Personal Data
Identifiers, such as your name, email address, postal address, phone number, and device identifiers (e.g., advertising identifiers and IP address).	Affiliates and subsidiaries, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future Service providers, such as security and platform vendors With third parties that are necessary to complete a transaction, such as credit card processors Business partners who we partner with to jointly market or sell our products and services, such as channel partners With third parties at your direction, such as event sponsors Professional advisors, such as lawyers, accountants, and auditors Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets Companies that operate Cookies and Tracking Technologies, described in Section 5, such as marketing and advertising partners To which you have consented to the disclosure
Commercial information, including preferences, such as purchasing history or tendencies and transactional information, such as banking information.	Affiliates and subsidiaries within our websites, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they will become our partners. Service providers, such as security and platform vendors With third parties that are necessary to complete a transaction, such as credit card processors Professional advisors, such as lawyers, accountants, and auditors Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets To which you have consented to the disclosure
Internet or other electronic network activity information and device information, such as your browsing history, search history, device information, and other information (whether passive browsing or active engagement) regarding your interactions with us and use of our products, Services, emails, and other Digital Properties.	Affiliates and subsidiaries within our websites or are our partners, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they will become our partners. Service providers, such as security and platform vendors Companies that operate Cookies and Tracking Technologies, described in Section 5, such as marketing and advertising partners Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets
Geolocation information, such as approximate location based on your IP address, mobile device location, or information you provide to us (such as city and state you provide through a webform). You may be able to control collection of this data through the settings of your device.	Affiliates and subsidiaries that work with us, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future and will/may become our partners. Service providers, such as security and platform vendors. Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets. Companies that operate Cookies and Tracking Technologies, described in Section 5, such as marketing and advertising partners
Audio, electronic, visual, and other sensory information, such as CCTV recordings of our premises (e.g., if you visit our offices); recordings of your interactions with our sales or advocacy teams (e.g., for quality assurance or training purposes, in accordance with applicable laws); or customer support chat or messaging logs.	Affiliates and subsidiaries that work with us, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they are made part of the Our group Service providers, such as security and platform vendors. Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets
Inferences as defined by California law, such as marketing you are likely to react positively to.	Affiliates and subsidiaries, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they will become our partners. Service providers, such as platform vendors Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets
Sensitive Personal Data, such as proof of vaccination or race and ethnicity (optional) (where permissible under applicable law).	Affiliates and subsidiaries, which includes parent and ultimate holding companies, affiliates, subsidiaries, business units, and other companies that we acquire in the future after they are made part or/will become our partners. Service providers, such as platform vendors or other companies. Entities involved in a corporate transaction, including if we sell, acquire, or merge all or some of our assets To which you have consented to the disclosure

Purpose of Processing	Lawful Basis
To provide our Products, Services, and Digital Properties to you, including processing and fulfilling transactions; enabling you to access the Digital Properties and our Services; operating, maintaining, and improving our Digital Properties and Services; communicating with you, such as by completing your support requests or providing security updates; and diagnosing, repairing, and tracking service and quality issues.	Legitimate interests; Contract; Legal obligations
For our own business purposes, including maintaining internal business records and conducting internal reporting; collecting payments and performing accounting and similar business functions; auditing and managing projects related to our Services; performing IT security management and IT-related tasks, such as administration of our technologies and network; evaluating and improving our business, Services, and Digital Properties; and performing research and development of new products and services; and processing your survey and questionnaire responses.	Legitimate interests; Legal obligations
For legal, safety, or security reasons, including to comply with legal requirements; establish, exercise, or defend against legal claims; protect the safety, security, and integrity of our property and the rights of those who interact with us or others; investigate any content or conduct policy violations; and detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity. These safety purposes may also involve collecting and processing special categories of personal data (i.e., health data), for office visits and events where necessary for public health or as required by applicable law.	Legitimate interests; Legal obligations; Public interest
For marketing our products and services or those of third parties, such as our business partners, Affiliate platforms or any other 3rd party including to solicit or publish testimonials or feedback about our products and services; send you marketing and promotional communications or product recommendations (via email, phone, or other online and offline channels) about our services or those of third parties; facilitate your participation in a contest or event; assess ad impressions or engage in contextual ad customization. You may opt out of marketing communications by clicking the “unsubscribe” link at the bottom of our marketing communications. You may also manage your email preferences. Note that some of our marketing materials and information may use tracking technologies and analytics tools to help us understand your preferences. For further information, please see Section 5 below and our Cookie Notice.	Consent (where required by law); Legitimate interests
To fulfill a referral request when you use our referral service to tell a friend about our Services, including by using the name, email address, title, and company name that you provide us to contact the person you are referring. You must only provide others’ personal data if you have their consent to do so.	Consent (where required by law); Legitimate interests
Diversity, equity, and inclusion, such as promoting diversity, equity, and inclusion initiatives and representation within our business (where authorized by applicable law).	Consent (where required by law); Legitimate interests
Corporate transactions, such as sales, mergers, acquisitions, reorganizations, bankruptcy, and other corporate events.	Legitimate interests; Legal obligations
When you have voluntarily agreed to have your personal data processed.	Consent

We also may provide your information to third parties, such as service providers, contractors and third-party publishers and advertisers for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Site in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services.

3. How We Process Personal Data

We may process your personal data for the below purposes:

Our websites will honor data subject rights to the extent required by law. You may have the right to access, correct, update, and, in some cases, request deletion of your personal data (subject to exceptions). You may submit a request to [email protected]

Our websites use a limited number of third-party service providers to assist us in processing data for certain purposes. These third-party providers help support certain site features, perform database monitoring and other technical operations, assist with the transmission of data, and provide data storage services. These third parties may process or store personal data while providing their services. Our websites maintain contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our obligations under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, including the onward transfer provisions, and remains liable if they fail to meet those obligations and we are not responsible for the event giving rise to damage.

4. Sources of Personal Data

• Information you provide to us directly, including when you register and communicate with us directly through our Digital Properties and Processes, or participate in our events, marketing, and outreach activities.
• Information collected from your employer, coworkers, or friends, including information about representatives or other employees of our current, past, and prospective customers, suppliers, investors, and business partners. We may also receive your information from a friend as part of a referral for our services.
• Information automatically collected, including technical information about your interactions with our Digital Properties (such as IP address, browsing preferences, and purchase history). More information is available in Section 5 below and in our Cookie Notice.
• Information from public sources, including information from public records and information you share in public forums, such as social media.
• Information from other third parties, including information from third-party service and providers, entities with whom we partner to sell or promote products and services, and social media networks (including widgets related to such networks, such as the “Facebook Like” button, LinkedIn, etc).
• We may receive information about you from our parents, subsidiaries, affiliates, service providers, business partners, and other third parties.

We may combine information that we receive from the various sources described in this Notice, including third-party sources and public sources, and use or disclose it for the purposes identified above.

5. Cookies and Tracking Technologies

We use cookies and other tracking technologies and offer you the option to manage these settings as described in our Cookie Notice. Some tracking technologies enable us to track your device activity over time and across devices and websites. While some browsers have incorporated Do Not Track or DNT preferences, we do not honor such signals from web browsers at this time.

Types of Information Collected: The information we collect about you may include, but is not limited to:

• Personal Information: Information that, either alone or in combination with other data, can be used to identify you.
• Demographic Information: General information about you that does not specifically identify you.
• Device Information: Information about the devices you utilize to access our Services.
• Usage Details: Dates, times, and durations of your use of the Services, including whether you are a first-time or repeat visitor.
• User Actions: Information about the actions you take while using our Services.

In general we do not respond to such signals or cookies.

Your web browser may provide options for you to express your preferences regarding the collection of information about your online activities across different websites or online services over time. However, at present, our websites may do not recognize or respond to the preferences you may have set in your web browser regarding such information collection. As a result, our websites may continue to collect information as described in this Privacy Policy.

6. Security and Retention

We maintain security procedures and technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, disclosure, alteration, or use.

Your personal data will be generally retained as long as necessary to fulfill the purposes for which we collected the personal data. Once you and/or your company have terminated the relationship with us or otherwise ended your relationship with us, we may retain your personal data in our systems and records to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to evidence our business practices and contractual obligations, to provide you with information about our products and services, or to comply with applicable legal, tax, or accounting requirements. When we have no ongoing legitimate business need to process your personal data, we will delete, anonymize, or aggregate it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

7. Children’s Privacy

Our websites are not directed to children under the age of 16, and we do not knowingly collect online personal data directly from children. If you are a parent or guardian of a minor child and believe that the child has disclosed online personal data to us, please contact us using the details provided in Section 9 below.

8. External Links

When interacting with us on our websites or on, you may encounter links to external sites or other online services and products, including those embedded in third-party advertisements. We do not control and are not responsible for privacy and data collection policies for such third-party sites and services. You should consult such third parties and their respective privacy notices for more information or if you have any questions about their practices.

9. Contact Information

If you have questions or complaints regarding this Notice or about the other privacy practices, please contact us by email at [email protected]

Stimulatingwellness.com

Attn: Privacy Team
135 Stewart Dr
Franklin, Vermont 23851, United States

10. Supplemental Terms for California Residents

Pursuant to the California Consumer Privacy Act (“CCPA”), this Section 10 applies to certain personal data collected about California individuals where our websites controls how and why the personal data is processed (which the CCPA calls a “business”) and supplements the rest of our Notice above. This Section 10 does not apply to current or former employees, applicants, contractors, or agents.

a. Additional Data Processing Disclosures:
The below table provides the categories of personal data we have sold, shared, or disclosed to third parties, as defined by the California Privacy Rights Act. For reference, this provides the categories of personal data collected and our disclosures of personal data.

Categories of Personal Data We Collect	California Privacy Rights Act Details: Categories of Third Parties to Whom Personal Data is “Sold or Shared”
Identifiers, such as your name, email address, postal address, phone number, and device identifiers (e.g., advertising identifiers and IP address).	Companies that operate Cookies and Tracking Technologies, described in Section 5, such as marketing and advertising partners. Business partners who we partner with to jointly market or sell our products and Services, such as channel partners.
Commercial information, including preferences, such as purchasing history or tendencies and transactional information, such as banking information.	Not applicable
Internet or other electronic network activity information and device information, such as your browsing history, search history, device information, and other information (whether passive browsing or active engagement) regarding your interactions with us and use of our products, Services, emails, and other Digital Properties.	Companies that operate Cookies and Tracking Technologies, described in Section 5, such as marketing and advertising partners.
Geolocation information, such as approximate location based on your IP address, mobile device location, or information you provide to us (such as city and state you provide through a webform). You may be able to control collection of this data through the settings of your device.	Companies that operate Cookies and Tracking Technologies, described in Section 5, such as marketing and advertising partners.
Audio, electronic, visual, and other sensory information, such as CCTV recordings of our premises (e.g., if you visit our offices); recordings of your interactions with our sales or advocacy teams (e.g., for quality assurance or training purposes, in accordance with applicable laws); or customer support chat or messaging logs.	Not applicable
Sensitive Personal Data, such as proof of vaccination or race and ethnicity (optional) (where permissible under applicable law).	Not applicable

Although we have not “sold” or “shared” personal data for money, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” or “sharing” as defined under California law. We do not knowingly sell or share any personal data of minors under the age of 16. We do not collect or process “sensitive personal information,” as defined by California law, to infer characteristics about you. Our websites only uses sensitive personal information consistent with the exceptions to the right to limit sensitive personal information.

Financial Incentives: We may offer a benefit or offering in exchange for you providing personal data, such as a discount or coupon to individuals who respond to a survey. As part of these surveys, we may collect personal data, such as your name, contact information, preferences, experiences, beliefs, opinions, and other responses to the survey questions. Participation in surveys is governed by the applicable terms and conditions for the survey, which will describe any financial incentives associated with that survey and how to participate. The value of your data is the value of the offer presented to you. We have calculated such value by using the expense related to the benefit. You may withdraw from any financial incentive at any time by emailing us. If we offer another type of financial incentive, we will share with you the material terms of each offer when we ask you to participate.

You have the right to request that we delete personal data that we have collected from you by writing us at [email protected]

We do not sell personal data to third parties in exchange for money. However, as we explain in Section 5, we share information with advertising partners and allow advertising partners to collect information from us. This exchange may be considered a “sale” or “sharing” under California law, and you have the right to opt out of this “sale” or “sharing” of personal data by writing us at [email protected].

We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

11. Supplemental Information for Other Regions

• Australia: Personal data collected, stored, used, and/or processed by our websites, as described in this Notice, is collected, stored, used, and/or processed in accordance with the Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles. If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC.
• Brazil: Personal data collected, stored, used, and/or processed by the Our group, as described in this Notice, is collected, stored, used, and/or processed in accordance with Lei Geral de Proteção de Dados (“LGPD”). Those individuals who use or access our Sites or Services expressly consent to the collection, use, storage, and processing of their personal data by us for the purposes described in this Notice.
• Canada: Personal data, as defined in the Personal Information Protection and Electronic Documents Act (“PIPEDA”) will be collected, stored, used, and/or processed by our websites in accordance with obligations under PIPEDA.
• Japan: Personal data collected, stored, used, and/or processed by our websites, as described in this Notice, is collected, stored, used, and/or processed in accordance with Japan’s Act on the Protection of Personal Information (“APPI”).
• Nevada: We do not presently sell personal data as defined under Nevada law. If you are a Nevada resident, you may nevertheless email us using the information above to exercise your right to opt-out of sale under Nevada Revised Statutes §603A et seq.
• New Zealand: Personal data collected, stored, used, and/or processed by the Our websites, as described in this Notice, is collected, stored, used, and/or processed in accordance with New Zealand’s Privacy Act 2020 and its 13 Information Privacy Principles (“NZ IPPs”).
• Singapore: Personal data collected, stored, used and/or processed by the our websites, as described in this Notice, is collected, stored, used, and/or processed in accordance with the obligations under the Personal Data Protection Act 2012 (“PDPA”).
• United Kingdom: Personal data collected, stored, used, and/or processed by our websites, as described in this Privacy Notice, is collected, stored, used, and/or processed in accordance with the obligations under the UK Data Protection Act 2018, as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019, as amended, superseded or replaced (“U.K. GDPR”).

13. English Version Controls

Non-English translations of this notice are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.