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Reload Health SAS. California Privacy Policy As of February, 25th, 2021
This California Privacy Policy (the “CA Policy”) supplements the information contained in our Privacy Policy and applies solely to individual residents of the State of California ( "consumers" or "you"). This CA Policy provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.
Scope When we use the term “personal information” in this CA Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. For the purposes of this CA Policy, personal information does not include:
Publicly available information from government records.
Deidentified, aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Information excluded from the CCPA's scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
Information relating to our employees, contractors and other personnel.
Collection and use of Personal Information In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the ‘Information Collection & Received’ and ‘Information Use ’ sections of our Privacy Policy:
Category of Personal Information Collected Collected Commercial or Business Purpose Categories of Sources
Identifiers including your name, address, email address, date of birth or other similar identifiers. X To run the application
To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
Understanding consumer shopping behavior
To fulfill orders
To communicate with you about your order
Addressing software issues
Updating your payment information
For customer service purposes
For quality assurance purposes
For regulatory compliance purposes
For collecting feedback
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
For marketing purposes
Product and services improvement
For contests and sweepstakes
Directly from you
Your browser or device
Our business partners and affiliates
Third parties you direct to share information with us
Push notification providers
Shipping providers
Customer service platforms
Data providers
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate, contact information and payment information. X To run the application
To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
To fulfill orders
To communicate with you about your order
Updating your payment information
For customer service purposes
For quality assurance purposes
For regulatory compliance purposes
For collecting feedback
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
For marketing purposes
Product and services improvement
For market research purposes
Directly from you
Your browser or device
Our business partners and affiliates
Third parties you direct to share information with us
Shipping providers
Customer service platforms
Protected Classification Characteristics including your age, and gender. X To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
Directly from you
Commercial Information including shopping and purchase history. X To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
To fulfill orders
For customer service purposes
For quality assurance purposes
For regulatory compliance purposes
For collecting feedback
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
Directly from you
Your browser or device
Our business partners and affiliates
Internet/Network Information including device information, logs and analytics data. X To run the application
Understanding consumer shopping behavior
Addressing software issues
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
Product and services improvement
Directly from you
Your browser or device
Data providers
Geolocation Data precise location information from your device or generated based on IP address. X To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
Directly from you
Your browser or device
Professional/Employment Information including your employment history, educational history, and degree relevant to your job application (applicants only). X For job application purposes
Directly from you
For applicants, from third parties you direct to share information with us
Other Personal Information including loyalty program data, information you post on our social media pages or otherwise provide to us. X To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
For market research purposes
Directly from you
Your browser or device
Third parties you direct to share information from us
Inferences including predictions about your interests and preferences. X To generate recommendations for users
Shipment purposes
Monitor the use of products
Monitor habit formation and apply rewards
For financial and engagement analytics
Subscription forecasting purposes
Personalization purposes
For market research purposes
Directly from you
Your browser or device
Information generated or derived from your purchases, online browsing and usage activity
How to Exercise your California Consumer Rights To Exercise Your Right to Know or Right to Request Deletion To exercise your Right to Know or your Right to Request Deletion, please send an email request to ‘privacy@reload.co’ with the subject line “Privacy Request” + either the word “Download” (We will provide a complete report of your personal data across our systems) or “Delete” (To Delete your personal data found in our systems) We will need to verify your identity before processing your request. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems.
To Exercise Your Right to Opt Out of Personal Information Sales To initiate your request to opt-out, please email us at privacy@reload.co with the subject line “California Opt-Out” . We need your name and email address in order to process your request and safeguard your data. To the extent that our third-party advertising and analytics providers’ collection of information from users of our websites and other online services constitutes a “sale” under the CCPA, please refer to the ‘Third-Party Analytics & Advertising’ disclosures in the ‘Information Use’ section of our Privacy Policy for more information about the choices and opt-out options you have in relation to those practices. By visiting www.privacyrights.info, you can also opt out from “sales” of this type of personal information by businesses that participate in the DAA’s CCPA Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.
Do Not Sell My Personal Information Minors Under Age 16 We do not sell the personal information of consumers we know to be less than 16 years of age.
California’s “Shine the Light” Law California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In order to facilitate these rights, we do not disclose personal information of California residents to third parties for their direct marketing purposes, as defined under California’s “Shine the Light” law, where the resident opts out of such sharing. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, please send an email request to privacy@reload.co with the subject line “Right to Opt-Out” filling in the email your first name, last name, and email address, which we need in order to process your request and safeguard your data. PLEASE NOTE: To opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.
Additional Information Updates to This CA Policy We will update this CA Policy from time to time. When we make changes to this CA Policy, we will change the last updated date at the beginning of this CA Policy. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to privacy@reload.co with “California Privacy Notice” in the subject line. Alternatively, inquiries may be addressed to our US Subsidiary: Reload Health LLC Delaware