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PRIVACY POLICY

THE PALEO DIET, LLC

Last Revised: September 15, 2022

In order to provide our products and services to you, The Paleo Diet, LLC (“Paleo Diet,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) our practices regarding the personal data that The Paleo Diet collects, uses, and shares through any website or application that links to this Policy (each a “Site” or “Application”). Capitalized terms not defined in this Policy shall have the meanings defined in The Paleo Diet Terms of Service.

This Policy covers our processing activities including as a data controller under the EU’s General Data Protection Regulation (“GDPR”).  We do not knowingly or intentionally collect Personal Data (defined below) from children. If you are under 16 years old, please do not submit any Personal Data to us, and tell a parent or guardian to contact us so we may delete your Personal Data. If you are a parent of a child under 16 and believe we have collected Personal Data of a child, please contact us immediately.

  1. Data you provide us. We collect Contact Data, Fitness Data, Special Category Data, and Site User Data (together“Personal Data”). We collect Contact Data, Fitness Data, and Special Category Data (as defined below) when you provide it to us.
    1. You provide Contact Data to us when you use the Site, submit information through the ‘contact us’ feature, participate in marketing, or join our platform.
      1. Contact Data. You may choose to subscribe to our marketing or contact us by providing us with your name and/or email address. Your name, billing address, phone number, and email address to join as a member on the Site. Mandatory information requested during registration must be given in full or registration may be refused. For a paid membership, you will provide your credit card information to a third-party vendor. You will provide The Paleo Diet with Contact Data when you correspond with The Paleo Diet via the Site, register as a member on the Site, or subscribe to receive our marketing.
      1. Fitness Data. You may choose to use certain features of the Site that allow you to provide additional information pertaining to fitness, diet, and exercise. You may supply as much or as little Fitness Data as you choose though some features of the Site may not function if you do not provide Fitness Data.
      1. Special Category Data. You may choose to use certain features of the Site that allow you to provide characteristic, biometric, fitness, health, and other data, some of which may constitute ‘special category data’ as defined by the GDPR.
      1. User Content. You may choose to post on the Site or Application regarding an event or other subjects, such as on our Forums page, or interact with other users or third parties (collectively “Content”). Please do not submit Personal Data as part of your Content. To the extent that you do include Personal Data as part of your Content, we will process it in accordance with this Privacy Policy. If you post Content publicly, such as on a forum, it will be shared with other users that have access to the forum or Site page. We will store Personal Data related to your participation in an event such as your name and participation in the event. If we record an event, we will obtain your consent before such recording; your continued participation in an event after notification will constitute your consent to such recording.
  • Data we collect automatically via technology on our Services.
    • Site User Data. As you use the Site, The Paleo Diet will collect technical data including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits. This Site User Data is collected using cookies or similar technology. These examples are illustrative and subject to change in The Paleo Diet’s sole discretion.
  • Use of your Data.
    • Contact Data. You can provide Contact Data to subscribe to our Newsletter, marketing, through our Contact Form, or to register on our Site to use certain functions. Contact Data is used for the purpose of using the offers and services provided on the Site. If you contact us through customer service or support, we will use your Contact Data to respond to your comments, questions, and to provide customer service. The processing of the data entered in the contact form takes place exclusively on the basis of your implied consent (GDPR Art. 6 Para. 1). You can revoke your consent at any time. An e-mail notification to our address set forth below is sufficient for your revocation. Data transmitted via the contact form will remain with us until you ask us to delete it, you revoke your consent to storage, or there is no longer any need to store data and mandatory statutory retention periods pass, whichever happens first.Fitness Data. We process Fitness Data to fulfill our contract with you for services and for our legitimate business interests. With your prior consent where required by applicable law, Fitness Data may be shared with third parties including include payment service providers, logistics companies, coaches, National Governing Bodies, athlete organizations, physical therapists, medical providers, personal trainers, and other fitness specialists. As required by applicable law, you may be provided with additional privacy notices when providing data to obtain certain services. The basis for data processing is GDPR Article 6(1)(a) which permits the processing of Personal Data where necessary for the performance of a contract or in furtherance of The Paleo Diet’s legitimate business interest.Special Category Data. We process Special Category Data to fulfill our contract with you for services on the Site and for our legitimate business interests. Special Category Data, including, in some instances, special category data as defined by the GDPR, will be transmitted with your explicit consent for the specified purpose of the transmission. Your Special Category Data may be shared with third parties including payment service providers, logistics companies, coaches, National Governing Bodies, athlete organizations, physical therapists, medical providers, personal trainers, and other fitness specialists. As required by applicable law, you may be provided with additional privacy notices when providing data to obtain certain services. Our basis for this data processing is:
      • GDPR Article 6(1)(a) which permits the processing of Personal Data where necessary for the performance of a contract or in furtherance of The Paleo Diet’s legitimate business interests; andGDPR Article 9(2)(c) which permits the processing of special category data with explicit written consent. For information on the treatment of your health information please see our Notice of Privacy Practices below.
      Marketing Communications. We use your Contact Data for promotional marketing if you agree to receive such emails. For example, if you have chosen to provide your Contact Data, we may send you newsletters, surveys, offers, and other promotional materials related to our services, and for other direct marketing purposes.Behavioral Advertising. We, and certain third parties operating on or through our Site, may engage in online behavioral advertising. This form of advertising includes various parties and service providers, including third party data controllers, engaged in the processing of personal data in connection with advertising. We may collect usage data and social media data from you and provide it directly to a third party for targeting on a third party platform. Sometimes, these third parties may collect this information directly (e.g. a Facebook “Like” button). The parties that control the processing of Personal Data for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have seen an ad, or whether you complete a purchase for a good or service you were shown in an advertisement.Support. We use information you give us in connection with your support requests, for example, to help solve issues, troubleshoot the Site or Application, manage your account, or respond to your inquiries. We may use third parties to help provide support to you.
    • Content. When you post Content on our Site or our social media pages, any contact information and Content you give us will be stored on our third-party servers and other users may be able to see it.
  • Rights and Choices. To the extent required by applicable law, you may exercise the below Rights and Choices by emailing our Data Protection Officer at help@thepaleodiet.com with a copy to info@thepaleodiet.com. Our mailing address is set forth below.
    • Access. You may receive a list of your Personal Data that we process by emailing us at help@thepaleodiet.com.Rectification. You may correct any Personal Data that we hold about you to the extent required and permitted by law. You have the right to free information about your stored Personal Data, the origin of the data, their recipients, and the purpose of the data processing and, if necessary, the right to correct or delete this data at any time within the framework of the applicable legal provisions. You can contact us at any time using the contact options listed above if you have any further questions about your Personal Data.Erasure and Objection to Processing. You may request that we delete your Personal Data from our systems by emailing us at help@thepaleodiet.com.Data Export and Portability. We will send you a copy of the Personal Data we hold from you in a common portable format of our choice, such as Microsoft Word, PDFs, Excel, or other such format. If you request the direct transfer of the data to another responsible person, this will only be done if it is technically feasible.Direct Marketing. Residents of California (and others as required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us at the address below, unless otherwise required by applicable law. You may cease direct marketing from us in relation to the Newsletter by emailing help@thepaleodiet.com or by clicking the unsubscribe link in any promotional email we send you.
    • Regulator Contact. You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.
  • Sharing of your Personal Data.
    • Service Companies. We use third-party service companies (“Service Companies”) to help us operate the Site and Applications. To help provide and host the Site we share Personal Data and Site User Data with analytics and web hosting Service Companies. To help with direct marketing we share Contact Data with marketing, social media, scheduling platform, and CMS Service Companies. We use these Service Companies to further our other legitimate business interests. We provide Contact Data to our Service Companies or other trusted businesses or persons to process it for us, based on our instructions and in compliance with this Privacy Policy and other appropriate confidentiality and security measures. If The Paleo Diet is involved in a merger, acquisition, or asset sale, we will continue to ensure the confidentiality of any Personal Data. These processing activities are within our legitimate interests, including without limitation:
  1. Direct marketing
    1. Personalization and customization of the Site and Application for individual users
    1. Determining the effectiveness of marketing campaigns
    1. Localizing our services
    1. Securing our Site, Application, and network, investigating suspicious activity or violations of our Terms of Service or policies; and protecting the safety of Personal Data, including preventing exploitation or other harms to which users may be particularly vulnerable.
    1. We balance our interests with any potential impact on you when we process your Personal Data for our legitimate interests. You may object to this processing as permitted by applicable law.
  • Events. You may interact with third parties during live events. If you do, those third parties may be able to see or hear your Content. Event sponsors will have access to the event and all Personal Data collected by those events; we will notify you of all event sponsors. We may also record events with notice to you, which recordings may be available to other users.
  • Interactive Forum. You may post information or interact with third parties on the Forum. This information is visible to third parties outside of our control. Third Parties outside our control may have access to the Content. This content may be used by other users, recorded, preserved, and shared.
  • Affiliates. To streamline certain business operations and develop applications and services that better meet your interests and needs, we may share your Personal Data with any of our current or future affiliated entities or subsidiaries.
    • Corporate Events. Your Personal Data may be processed if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
    • Legal Disclosures. In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Service, or to protect the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.
  • Cookies. “Cookies” are small pieces of information that a website stores on your computer while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (most of which have an expiration date, based on the purpose of the cookie, at which point they self-delete). We may place two kinds of cookies: essential and performance/analytics (non-essential).

a) Essential Cookies. These cookies are strictly necessary to provide you with the Website and services available through our Site and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Site, you cannot refuse them without impacting how our Site functions.

b) Non-Essential Cookies. We may use two kinds of non-essential cookies: performance or advertising. You may opt into or out of non-essential cookies using the cookie banner on the Site. Non-essential performance cookies help us analyze how the Site is being accessed and used, enable us to track performance, and secure the Site.  For example, we use those cookies to get insights regarding users and Site performance, such as page speed or to help us customize our Site and services for you in order to enhance your experience.

c) Uses. We generally use cookies and similar technologies as follows:

  • for “essential” or “functional” purposes, such as to enable various features of the Site like remembering passwords or staying logged in during your session;
  • for analytics purposes necessary to carry out electronic communication processes or to provide certain functions you wish to use (e.g. shopping cart), based on GDPR Art. 6 Para. 1(f). As the operator of this Site, we have a legitimate interest in storing cookies for the technically error-free and smooth provision of our services;
  • legitimate interests in how our Site is used or performs, how users engage with and navigate through the Site, what sites users visit before visiting our Site, how often they visit our Site, whether an email was received or opened, and other similar information; and
  • subject to any consent required by law, for the purpose of analyzing your feedback on our products on other platforms.

d) Opting Out. If you would like to remove or disable cookies via your browser, refer to your browser’s settings. If you wish to limit third parties’ collection of information about your use of our Site, you can opt-out of such at the Digital Advertising Alliance or Network Advertising Initiative.  PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE SITE.  IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

e) Changing your marketing preferences.

You may ask us not to process your Contact Data for marketing purposes and can exercise the right at any time by sending us an email at help@thepaleodiet.com or by clicking on ‘unsubscribe’ in any of our marketing emails.

6. Do Not Track

While you may disable the usage of cookies through your browser settings, the Site currently does not respond to all “Do Not Track” signals in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. We will update this Policy when that becomes possible.

7. Data Security

We implement a variety of security measures to maintain the safety of your Personal Data when you place an order.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential.

After a transaction, your payment information will not be stored on our servers. While we use industry-standard precautions to safeguard your Personal Data, we cannot guarantee complete security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us is compromised), please immediately notify us of the problem.

  • International Transfers. We operate in and use Service Companies located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. If you create and use accounts with us, you consent to your data being processed and stored in the United States.
  • Updates to this Policy; Contact Information

If we change or update this Privacy Policy, we will post changes on the Website so that you will always be aware of what information we collect, use and disclose. We will also change the “Last Updated” date above. We encourage you to review this Privacy Policy from time to time. If you have any questions about the Privacy Policy, please contact us at our physical address:

The Paleo Diet, LLC
1405 Arapahoe Ave
Boulder, CO 80302
Email: help@thepaleodiet.com

.

NOTICE OF PRIVACY PRACTICES

Effective Date: September 13, 2022

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

If you have any questions about this Notice, please contact our Privacy Officer at
help@thepaleodiet.com or 720-350-4089.

This Notice of Privacy Practices describes how we protect your health information and what rights you have regarding your health information. “Protected health information” is information about you, including demographic and financial information, that may identify you and that relates to your past, present, or future physical or mental health condition and related health care services.

In certain circumstances, we are required by law to maintain the privacy of your protected health information, to provide you with and to abide by the terms of this Notice. We may change the terms of this Notice at any time. The new Notice will be effective for all protected health information that we maintain at that time.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION WITHOUT YOUR PERMISSION

We may use and disclose your protected health information for certain purposes without your authorization, including the following:

Treatment: We may use and disclose your protected health information to provide, coordinate, or manage your treatment and fitness plans. This includes the coordination or management of your health care with other providers and communication with your coaches or organizations. For example, we may use or disclose your information to your National Governing Body, your personal trainer, your coach, your physical therapist, or your medical provider to perform diagnostic tests, to discuss your plan of care or training plan. We may also disclose your information to another provider who cares for you, such as a chiropractor or physician who is treating you or a physical therapist. Your protected health information may be provided to a provider to whom you have been referred to ensure that the provider has the necessary information to diagnose or treat you. Other providers may be present during your treatment to observe or assist with equipment or materials, unless you object. This disclosure may include the use of photographs or videos taken before, during and after treatment as permitted by law.

Payment: We may use or disclose your protected health information to obtain payment for health care services we provided to you.

Health Care Operations: We may use or disclose your protected health information for certain administrative and managerial activities that are necessary to support the business activities of the Company, such as assessment and improvement activities, employee review activities and licensing. We may also use and disclose your protected health information for purposes of teaching our providers, coaches, trainers, and staff about our clinical and non-clinical practices and techniques. The purpose of such use and disclosure is to improve the knowledge and expertise of those who provide fitness training and coaching services or provide supporting services.

Appointment Reminders / Treatment Alternatives: We may also call, write, or email to remind you of routine scheduled appointments or referral appointments. We may also contact you to notify you of other treatments or services available that might help you.

Business Associates: We may disclose your protected health information to persons or entities that perform certain services or health care operations for us and who agree to comply in writing with certain privacy and security obligations.

Others Involved in Your Health Care or Payment for Your Care: Unless you instruct us not to, we may disclose your protected health information to a member of your family, a close friend, or any other person who is involved in your fitness plan or health plan of care. We may also disclose certain information about you to an entity assisting in a disaster relief effort.

Business Associates: We may disclose your protected health information to persons or entities that perform certain services or health care operations for us and who agree to comply in writing with certain privacy and security obligations.

Electronic Disclosures: We may make an electronic disclosure of your protected health information as permitted by law.

Other Uses and Disclosures: We may also use or disclose your protected health information without your permission in some other limited situations if certain conditions are met, but not all of these situations apply to us and some may never occur at all. Such permitted uses and disclosures are:

  • when state or federal law requires that certain information be reported for a specific purpose;
  • for public health activities and purposes, such as contagious disease reporting, investigation or surveillance and notices to and from the federal Food and Drug Administration;
  • for health oversight activities, such as licensing, audits, investigations and inspections;
  • to governmental authorities about victims of abuse, neglect, or domestic violence;
  • for judicial or administrative proceedings, such as in response to an order of a court or administrative tribunal (to the extent such disclosure is expressly authorized), or in response to a subpoena, discovery request, or other lawful process under certain conditions;
  • to avert a serious threat to your health and safety or the health or safety of another person pursuant to applicable law;
  • for law enforcement purposes, such as to provide information about someone who is or was suspected to be a victim of a crime or to report information about a crime, or to a correctional institution in certain circumstances;
  • to a medical examiner or coroner to identify a dead person or to determine the cause of death, or to funeral directors to aid in burial, or to organizations that handle organ or tissue donations;
  • for health-related research that has been approved by an institutional review board or its equivalent;
  • for specialized government functions, such as for lawful national intelligence purposes, for military purposes, or for evaluation and health of members of the foreign service; and
  • disclosures authorized by an applicable workers’ compensation program.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION WITH YOUR PERMISSION

Before we can use or disclose your protected health information in a manner which is not described above, we will obtain your written authorization. For example, we will obtain your authorization for most uses and disclosures of your health information for marketing purposes and for the sale of your health information. Further, we will not use or disclose psychotherapy notes without your written authorization. You may revoke an authorization in writing at any time. If you revoke your authorization, we will no longer use or disclose your protected health information for the reasons covered by your written authorization, except to the extent we have already relied on it or as otherwise permitted by law. You may obtain a Revocation of Authorization form from the Privacy Officer and submit it to the email address noted above.

STATE LAWS

Every state has its own set of privacy laws. If your state has a privacy law that provides greater limits on how we may use or disclose your protected health information than what is stated in this Notice, we will abide by that state law. If you have any questions regarding any such laws, you may contact the Privacy Officer at the telephone number or email address noted above.

YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION

The following is a list of your rights with respect to your protected health information and a brief description of how you may exercise these rights. You can request to exercise any of these rights by contacting our Privacy Officer at the telephone number or email address shown at the beginning of this Notice.

Access to your records. You have the right to look at or order a copy of the fitness plan and healthcare plan of treatment records that we maintain. Except in a few limited situations, we will provide you with access to or a copy of your health information within 30 days of your written request. If we need more time, we will notify you in writing. If we have information about you in electronic format, we will provide it to you in an electronic format. As permitted by federal and state law, we may charge you a reasonable cost-based fee for a copy of your records.

Restriction of your protected health information. You may request restrictions on how we use and disclose your health information. We will consider such a request, but we are not required to agree to a restriction.

Confidential communications. You may ask us to communicate with you in a confidential way. We will accommodate any reasonable request for you to receive your protected health information by alternative means of communication or at an alternative location. We will not request an explanation from you as to the basis for the request.

Amendment to your protected health information. You may ask us to amend your protected health information if you think it is incomplete or inaccurate. We will respond within 60 days of such request, unless we notify you in writing we need additional time. Please contact our Privacy Officer if you have questions about amending your medical record.

Accounting of certain disclosures of your protected health information. You have the right to request a list of disclosures that we have made of your health information within the past six years (or a shorter period if you want). We will usually respond to your request for a list of disclosures within 30 days if required by law.

Additional copies of this Notice. You may request additional copies of this Notice of Privacy Practices even if you agreed to accept this Notice electronically.

Notice of a Breach. We will notify you if there is a breach involving your protected health information as required by law.

COMPLAINTS

If you believe that your privacy rights have been violated, you may file a complaint with us. For more information on how to file a written complaint with us, call the Privacy Officer at the number listed above. Your privacy is one of our greatest concerns, and you will never be retaliated against if you choose to file a complaint. There may also be a federal or state agency that enforces rules relating to the privacy and security of your health information, and you may have a right to file a complaint with that agency.

CHANGES TO THIS NOTICE

We reserve the right to change our privacy practices and the terms of this Notice at any time, provided such changes are permitted by applicable law. We will make any new Notice available to you. You may request a copy of the Notice currently in effect at any time by contacting the Privacy Officer at the telephone number or email address listed above.

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