Privacy policy

Effective Date: July, 25 2023

Avenir Nutrition Inc. (“Avenir,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites, mobile applications, and related services (collectively, our “Services”). Our privacy policy (our “Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users”, “you”, and/or “your”). By using our Services, you agree to the collection, use, disclosure, and procedures our Privacy Policy describes. Beyond our Privacy Policy, your use of our Services is also subject to our Terms of Service (ttps://avenirnutrition.com/policies/terms-of-service). This Privacy Policy is important and affects your legal rights, so please read carefully. By using our Services and/or submitting or collecting any personal data via the Services, you accept and expressly consent and agree to our practices surrounding the collection, use, and sharing of your personal information in accordance with this Privacy Policy. If you do not consent and agree with the terms of this Privacy Policy, you cannot, and we do not authorize you to, access, browse, or use our Services.

Our processing of personal information, such as your name, address, e-mail address, or telephone number, shall be undertaken consistent with the requirements of applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (“CCPA”), the General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”).

After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to make a complaint, please contact us by e-mail at support@avenirnutrition.com or by mail using the details provided below:

Avenir Nutrition, 152 Cottage Place, Ridgewood, NJ, 07450.

I. Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

When a user visits one of our websites, information that personally identifies the user can be collected and processed by Avenir and its employees. We collect user’s name, business address, mailing address, telephone number, fax number, e-mail address, and professional licensing information when this information is knowingly provided to us. In addition, this information can be collected as a result of the services or the products a user requests information about or purchases from us. Finally, Avenir can collect or process personally identifiable information, such as a user’s Internet domain or IP address, as part of the normal operation of our websites, or during the normal course of a user’s activities on or use of our websites. In nearly all cases this data is collected or processed by, or transferred to, Avenir's corporate headquarters. When a user visits our websites, the user is consenting to the collection, processing, transfer, or use of this information. If a user chooses not to consent to the collection, processing, transfer, or use of this information in this manner, then the user should not visit, or should discontinue visiting, our websites.

Account Information. If you sign up for an account on our Services, then we ask for information about you, such as your name, mailing address, email address, telephone number, and birth date. We may also give you the option to provide additional information, such as your professional licensing information if you are a licensed health-care practitioner.

Communications. If you contact us directly, then we may receive additional information about you. For example, if you contact us for customer support, then we may receive your name, email address, telephone number, the contents of the message, and any attachments you send to us, as well as any other information you choose to provide. If you sign up to receive updates, offers, or other promotional information, then we will collect certain information from you, such as your email address. You can unsubscribe from our promotional emails via the link provided in the emails. Please note that even if you opt out from receiving promotional messages from us, you will continue to receive administrative messages from us.

Payment Information. If you make a purchase through our Services, then we ask for information, such as your name, email address, telephone number, shipping address, and billing address. Your payment information, such as your credit card information or other financial information, will also be collected and processed by a third-party payment processor on our behalf.

Other Content. We also receive other information or content you choose to provide to us through the Services, such as product ratings and reviews you choose to post to the Services. Please see the “User Content” disclosure in the “How We Share the Information We Collect” section, below, for information about how this information or content is viewable by other users of our Services.

Applications. If you submit an application through the Services, such as for an open employment position or to become an Avenir Affiliate, then we collect your name, email address, and address. Applicants are asked, but not required, to share links to their social media profile.

II. Information We Collect Automatically When You Use Our Services

In order to access and use certain areas or features of the Services, you consent to our collection and use of certain information about your use of the Services through the use of tracking technologies or by other passive means. Your consent to our access and use of this “passively collected” information includes, but is not limited to:

Information from Cookies and Similar Tracking Tool Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies to provide Services, advertise to, and better understand our users. Our third-party partners, such as analytics partners and advertising partners, may use these technologies to collect information about your online activities and across different services. “

Cookies: “Cookies” are small computer files transferred to your computing device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Avenir Services. We use Cookies to improve or tailor our Services, customize advertisements by tracking navigation habits, measuring performance, and storing authentication status so re-entering credentials is not required, customize user experiences with our Services, and for analytics and fraud prevention. For more information on Cookies, including how to control your Cookie settings and preferences, visit http://www.allaboutCookies.org. You can manage Cookies in your web browser (for example, Edge, Explorer, Chrome, Safari, etc.) settings, and you always have the choice to change these settings by accepting, rejecting, or deleting Cookies. If you choose to change your settings, you may find that certain functions and features of the Services will not work as intended. Cookie settings are slightly different depending on the browser used, so to manage Cookies, you should refer to the program documentation and the relevant settings within your particular browser. The follow details the types of Cookies we use and why we use them:
- Absolutely necessary Cookies. These Cookies are essential to enable you to move around a website and use its features. Without these Cookies, services you have asked for, like adding items to an online order, cannot be provided.
- Performance Cookies. These Cookies collect information about how you use our Services. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These Cookies do not collect information that personally identifies you and only collect aggregated and anonymous information. Performance Cookies are used to improve the user-friendliness of a website and enhance your experience.
- Functionality Cookies. These Cookies allow the Services to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These Cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these Cookies collect may be anonymized, and they cannot track your browsing activity on other websites.
- Cart Cookies. Avenir uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

Cookies Necessary for the Functioning of the Store

Name	Function	Duration
_ab	Used in connection with access to admin.	2y
_secure_session_id	Used in connection with navigation through a storefront.	24h
_shopify_country	Used in connection with checkout.	session
_shopify_m	Used for managing customer privacy settings.	1y
_shopify_tm	Used for managing customer privacy settings.	30min
_shopify_tw	Used for managing customer privacy settings.	2w
_storefront_u	Used to facilitate updating customer account information.	1min
_tracking_consent	Tracking preferences.	1y
c	Used in connection with checkout.	1y
cart	Used in connection with shopping cart.	2w
cart_currency	Used in connection with shopping cart.	2w
cart_sig	Used in connection with checkout.	2w
cart_ts	Used in connection with checkout.	2w
cart_ver	Used in connection with shopping cart.	2w
checkout	Used in connection with checkout.	4w
checkout_token	Used in connection with checkout.	1y
dynamic_checkout_shown_on_cart	Used in connection with checkout.	30min
hide_shopify_pay_for_checkout	Used in connection with checkout.	session
keep_alive	Used in connection with buyer localization.	2w
master_device_id	Used in connection with merchant login.	2y
previous_step	Used in connection with checkout.	1y
remember_me	Used in connection with checkout.	1y
secure_customer_sig	Used in connection with customer login.	20y
shopify_pay	Used in connection with checkout.	1y
shopify_pay_redirect	Used in connection with checkout.	30 minutes, 3w or 1y depending on value
storefront_digest	Used in connection with customer login.	2y
tracked_start_checkout	Used in connection with checkout.	1y
checkout_one_experiment	Used in connection with checkout.	session

Reporting and Analytics

Name	Function	Duration
_landing_page	Track landing pages.	2w
_orig_referrer	Track landing pages.	2w
_s	Shopify analytics.	30min
_shopify_d	Shopify analytics.	session
_shopify_s	Shopify analytics.	30min
_shopify_sa_p	Shopify analytics relating to marketing & referrals.	30min
_shopify_sa_t	Shopify analytics relating to marketing & referrals.	30min
_shopify_y	Shopify analytics.	1y
_y	Shopify analytics.	1y
_shopify_evids	Shopify analytics.	session
_shopify_ga	Shopify and Google Analytics.	session

Please note that if you delete or choose not to accept cookies from the Services, then you might not be able to utilize the features of the Services to their fullest potential.

Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
Web Service Analytics: We may use third-party analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Services. We use the information collected from these services to help make the Avenir Services easier to use and as otherwise set forth in the How We Use Your Information section. These analytics services generally do not collect personal information unless you voluntarily provide it and generally do not track your browsing habits across web services that do not use their services.
Mobile Device Identifiers: As with other Tracking Tools, mobile device identifiers help Avenir learn more about our users’ demographics and internet behaviors to personalize and improve the Site. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of personal information (such as media access control, address, and location) and Traffic Data.

Location Information. If you choose to use certain features of our Services, then we receive location information you choose to provide to us, such as your city or Zip Code, or, with your permission, we receive your precise location information. We may also infer your general location information; for example, by using your internet protocol (IP) address.

Device Information. We receive information about the device and software you use to access our Services, such as your IP address, web browser type, and operating system version.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, such as the pages or other content you view, the searches you conduct, the products you purchase, your favorites and comments, content you post, and the dates and times of your visits.

Options for Opting Out of Cookies and Mobile Device Identifiers

If we process Cookies based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any point in time by contacting us at support@avenirnutrition.com. Please note that if you exercise this right, you may have to then provide your consent on a case-by-case basis for the use by us or disclosure of certain Cookies, if such use or disclosure is necessary to enable you to utilize some or all of our services.

Some web browsers allow you to reject Cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Avenir’s Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

You may opt out of receiving certain Cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) opt out page, or by installing the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete Cookies on your computer, tablet, or mobile computing device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

Even after opting out of Behavioral Advertising (defined below), you may still see Avenir advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Avenir is no longer using Tracking Tools — Avenir still may collect information about your use of the Services even after you have opted out of Behavioral Advertising and may still serve advertisements to you via the Services based on information it collects.

This Privacy Policy does not cover the use of Cookies and other Tracking Tools by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that some Cookies placed by third parties can continue to track your activities online even after you have left the Services.

How Avenir Responds to Browser “Do Not Track” (DNT) Signals

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have their online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including Avenir, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.

III. HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect:

To provide, maintain, improve, and enhance our Services.
To personalize your experience on our Services, such as by providing tailored content and recommendations.
To understand and analyze how you use our Services and develop new products, services, features, and functionality.
To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support.
To allow you to post content on social networks and other online services.
For marketing and advertising purposes, such as developing and providing promotional and advertising materials that is relevant, valuable, or otherwise of interest to you.
For research and analytics purposes.
To generate de-identified or aggregate data that we share with third parties for their own research and product development purposes.
To facilitate transactions and payments.
To evaluate employment applications.
To find and prevent fraud and respond to trust and safety issues that arise.
For compliance purposes, including enforcing our Terms of Use or other legal rights, or as might be required by applicable laws and regulations or requested by judicial process or a governmental agency.
For other purposes for which we provide specific notice at the time the information is collected.

By providing your e-mail and/or phone number and checking a box, clicking the “complete” button, or some other affirmative act, you are consenting to receive e-mails and/or calls and text messages, including live, prerecorded, and/or automated calls and text messages and alerts, to that phone number. After signing up, you will receive a confirmation e-mail or text message from Avenir on your mobile number. This agreement is not entered into as a term or requirement of any purchase or promotion. Normal message and data rates may apply. Message frequency may vary. Neither we nor the participating carriers guarantee that messages will be delivered. We may discontinue these programs at any time without notice.

Behavioral Advertising

We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools to collect information about a user’s online activities to display Avenir ads to the user based on the user’s interests (“Behavioral Advertising”). Such partners may include third-party service providers, advertisers, advertising networks or platforms, traffic measurement service providers, marketing analytics service providers, and other third-party service providers (collectively, “Advertising Service Providers”). Other Tracking Tools used by our partners may collect information when you use the Site, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help Avenir learn more about our users’ demographics and internet behaviors.

Automatic decision-making

If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.

Using customer data, we engage in fully automated decision-making. Our processor Shopify uses limited automated decision-making to prevent fraud that does not have a legal or otherwise significant effect on you.

Services that include elements of automated decision-making include:

Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.

Iv. How We Share the Information We Collect

In certain circumstances, and in order to perform the Services, we may share certain information that we collect from you, as described in this section:

Affiliates. We may share information we receive with our corporate affiliates for the purposes described in our Privacy Policy.

Vendors and Service Providers. We may share information we receive with vendors and service providers retained in connection with the provision of our Services.

User Content. Our Services allow you to find and share content, such as product ratings and reviews. The content you post to the Services will be displayed on the Services and be viewable by other users by default. Please note that we are not responsible for the other users’ use of available information, so you should carefully consider whether to post and what to post or how you identify yourself on the Services.

Social Networks and Other Online Services. Our Services allow you, on your direction, to share content on social networks and other online services, such as Twitter, Instagram, TikTok, and Facebook. You understand and agree that the use of the content you post by a social networking website or other online service is governed by the privacy policies of these third-party services and your settings on that service. We encourage you to review their privacy policies.

Analytics Partners. We use analytics services, such as Google Analytics, to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

Advertising Partners. We work with third-party advertising partners to show you ads we think might interest you. Some advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, then visit their opt-out pages to learn how you can opt out of receiving web-based personalized ads from member companies. You can access settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn how you can opt out of personalized ads in mobile apps.

Third-party Partners. With your consent, we de-identify or aggregate your Health and Wellness Information and share it, along with your test results and information about products you have purchased, with third parties for their own research and product development purposes. In addition, if you are a customer of one of our third-party partners and you use our Services as part of a promotion with that partner, with your consent, Avenir will share your test results with that third-party partner.

As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information can occur if you post objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We can transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following such an event will be governed by the provisions of our Privacy Policy in effect at the time the applicable information was collected.

Consent. We might also disclose your information with your permission.

V. THIRD PARTIES

Our Services can contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that our Privacy Policy does not apply to your activities on these third-party services nor to information you disclose to these third parties. We encourage you to read their privacy policies before providing information to them.

Third Party Pixels and Cookies

When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Third Party Web Services

The Site contains links to or embedded content from third party web services. A link to or embedded content from a non-Avenir web service does not mean that we endorse that web service, the quality or accuracy of information presented on the non-Avenir web service or the persons or entities associated with the non-Avenir web service. If you decide to visit a third party web service, you are subject to the privacy policy of the third party web service as applicable and we are not responsible for the policies and practices of the third party web service. We encourage you to ask questions before you disclose your information to others.

VI. SECURITY

We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be completely secure, we make no guarantee or warranty as to the security or privacy of your information. Please note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Any information you send us through any means is transmitted at your own risk.

VII. CHILDREN

The Services are not intended for use by children and individuals under the age of 18 are prohibited from using the Services. By accessing, using and/or submitting information to or through the Services, you represent that you are not younger than age 18 We do not knowingly collect, maintain, or use personal information from children younger than 18 years of age, and no part of our Services is directed toward children. If you learn that a child has provided us with personal information in violation of our Privacy Policy, then you can alert us at support@avenirnutrition.com.

VIII. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) requires us to provide Users who reside in California with the additional notice below.

We collect and disclose for a business purpose the following categories of Personal Information about Users to the following categories of third parties (for the purposes of this section of our Privacy Policy, “Personal Information” has the meaning provided in the CCPA):

Category of Personal Information	Third Parties with which we can share Personal Information
Identifiers, such as name, postal address, internet protocol address, email address, or other similar identifiers.	Vendors and service providers. Advertising partners. Analytics partners. Third parties as required by law or similar disclosures.
Categories of Personal Information in California Civil Code Section 1798.80(e), such as name, physical characteristics or description, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other financial information, or medical information.	Vendors and service providers. Third parties as required by law or similar disclosures.
Characteristics of protected classifications under California or federal law, such as race or color, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), or medical condition.	Vendors and service providers. Third parties as required by law or similar disclosures.
Commercial Information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Vendors and service providers. Advertising partners. Analytics partners. Third parties as required by law or similar disclosures.
Internet or other electronic network activity information, such as information regarding your interaction with an internet website, application, or advertisement.	Advertising partners. Third parties as required by law or similar disclosures.
Geolocation data, such as precise physical location.	Advertising partners. Third parties as required by law or similar disclosures.
Professional or employment-related information, such as job application or resume information.	Vendors and service providers. Third parties as required by law or similar disclosures.
Inferences drawn from Personal Information, including consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising partners. Third parties as required by law or similar disclosures.

The “Information We Collect” section of our Privacy Policy describes the categories of sources from which we collect your Personal Information. The “How We Use the Information We Collect” section describes the purposes for which we collect your Personal Information.

If you are a California resident, then you may be able to exercise the following rights:

The right to request a copy of the Personal Information we have collected about you in the previous 12 months.
The right to request details about the categories of Personal Information we collect, the categories of sources, the business or commercial purposes for collecting Personal Information, and the categories of third parties with whom we share Personal Information.
The right to request deletion of the Personal Information we have collected about you, subject to certain exemptions.
The right to opt out of the sale of your Personal Information.

Please note that you have the right to make these requests, but we might not be able to fulfill certain requests if we are unable to verify your identity to the extent required by law. Only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

California residents can submit access and deletion requests online by emailing us at support@avenirnutrition.com or by contacting our customer support team through our support inquiry box. An authorized agent can submit an access or deletion request on your behalf by sending a written authorization signed by you to support@avenirnutrition.com We can still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.

The CCPA defines "selling" Personal Information to include providing it to a third party in exchange for valuable services. We disclose identifiers and other internet activity to certain third parties in exchange for valuable services, such as to advertising partners and analytics partners, which might constitute a "sale" under the CCPA.

You have the right to not receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

IX. Canada, European Union and United Kingdom Privacy Rights

If our processing of your personal information is subject to the European Union General Data Protection Regulation, the UK General Data Protection Regulation, and/or the Canadian Personal Information Protection and Electronic Documents Act, and unless subject to an exemption, you may have the following rights with respect to your personal data as applicable:

The right to request a copy of your personal data which we hold about you and where possible, to transmit that data directly to another data controller;
The right to request that we correct any personal data about you;
The right to request your personal data be erased where it is no longer necessary for us to retain such data;
The right to withdraw your consent at any time to the processing of personal data to which you provided consent for processing;
The right to request that we provide you with a copy of your personal data;
The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing;
The right to object to the processing of personal data (where applicable); and
The right to lodge a complaint with a data supervisory authority.

Please note that we will need to verify your identity before we are able to process any of the requests described in this Section 9, and in our discretion, may deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required.

If you are a resident of the European Economic Area (“EEA”), when we process your personal data, we will only do so in the following situations:

We need to use your personal data to perform our responsibilities under our agreement with you;
We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to the TouchPoint Services, and to provide, secure, and improve the TouchPoint Services;
We have your consent to do so.

INTERNATIONAL TRANSFERS OF DATA

Our Services are hosted in the United States.. If you choose to use the Services from the European Union or another region of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we can transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

If your personal data is subject to the GDPR or UK GDPR, we will transfer personal data from the EEA to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.

If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside of Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.

X. How Long We Retain Your Information

We retain personal information about you for as long as necessary to provide you the Services. In some cases, we retain personal information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, prevent fraud, enforce this Privacy Policy, or as otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a de-identified and/or aggregated form but not in a way that would identify you personally.

XI. ACCESSING/UPDATING YOUR ACCOUNT INFORMATION

You can access and update your account information through your account settings.

XII. CHANGES TO OUR PRIVACY POLICY

We will post adjustments to our Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, then we will notify you through the Services, by email, or other communication.

XIII. Complaints

As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under “Contact” above.

If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authorities in your local area.