SUPPLE LLC PRIVACY PRINCIPLES
Supple LLC takes your privacy seriously. The following principles guide our treatment of your personal information:
1. We value the trust you place in us when sharing your personal information with us.
2. We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.
3. We endeavor to work with you to address your concerns about how we use your personal information.
4. We strive to take steps designed to secure your personal information and reduce the risk it will be misused.
Last Updated Date: April 22, 2023
When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
TYPES OF PERSONAL INFORMATION WE COLLECT
• Contact Information. We may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
• Payment Information. We may collect your credit card number, related security codes, and billing address.
• Shopping History. We may collect personal information about the items you viewed, added to your cart, purchased, product concerns or returned.
• Information You Post. We may collect personal information you post in a public space on our Platform, such as a ratings and reviews feature.
• Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.
• Information You Submit. We may collect personal information when you send us a message through the “Contact Us” page, raise a customer service issue, interact with an event page or similar features we make available on our Platform. We may also collect personal information when you enter a promotion, survey, review or quiz. This may include photos, videos and other user-generated content that you submit. When applicable, we may have additional disclosures about these services or features that we make available to you before you interact with these tools and ask for permission to collect the information that will be collected in that service or feature.
• Demographic Information. We may collect your birthdate, age, gender, ethnicity and zip code. We may also collect personal information relating to your hobbies, eating habits, interests, pet information, family statistics, and shopping behavior.
• Device, Identifier & Network Information. We may collect the type of device you use to access our Platform. For example, we may also collect your device identifier or other online identifiers associated with you, such as your Universal ID, social media ID or may add in an identifier when you visit our Platform, geolocation, hardware model, network related information, IP address or operating system.
• Location Information. We may collect precise location information from your device. This may include information about your exact location when you use our Platform or may include information that allows us to approximate your location. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the “Choices Regarding Your Information” section below.
• Log, Behavior and Analytics Data. If you use our website, we may collect information about the browser you are using. We may look at what site you came from, or what site you visit when you leave us. If you use our app, we may look at how often you use the app and where you downloaded it. We may collect information on what buttons or parts of the website you interact with using heat mapping, keystrokes or other similar technology.
• Health-Related Information. If you choose to have a medical consultation or take our tests or surveys, or use certain features of the Platform, we may receive from you directly certain health related information to better serve you, such as general health history, pregnancy wellness information and other related information, other prescriptions or supplements that you may use, dietary habits, sleep habits, and health and wellness habits.
• Preferences. You may provide us with information about your personal and household preferences in response to website interactions.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information in the following ways:
Directly From You. For example, when you:
• Register for an account or a subscription.
• Purchase products or services through our Platform.
• Sign up to receive promotional communications either online or offline, such as a trade show.
• Request a sample.
• Join a loyalty, rewards or similar program or club.
• When you consult with one of our specialists, and / or choose to send us laboratory samples.
• Participate in one of our promotional sweepstakes, quizzes, offers, contests, surveys, or focus groups.
• Use of our Platform services and features such as completing a quiz or interacting with a virtual store.
• Use the ratings and reviews or related services and features.
• Submit a request to our Consumer Service team or otherwise communicate with us.
• Interact with our social media pages or other promotional advertising sites.
Automatically. For example, when you:
• Install and use any mobile apps, as may be applicable.
• Visit and navigate our Platform on any device.
• Enable location-based features on our Platform.
• Click on sponsored links or ads, third party connections or third-party advertisements, including social media sites.
We may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, beacons, pixels, flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.
Our Affiliates. We may receive personal information from our Supple affiliated companies and brands when permitted by law.
From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:
• Our business partners, including marketing partners, medical professionals, third-party diagnostic/laboratory providers, analytics vendors, and companies that co-sponsor our promotions.
• Online advertising networks and publishers. We may also receive profile information from online publishers, which includes items such as household status, income, educational information, etc. The information that we receive is dependent upon the online publisher.
• Social media sites, including without limitation, Facebook, Twitter, YouTube, Pinterest, Snapchat, Tik Tok and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.
• Third party sites, including those that allow you to integrate your third-party account with your Supple account.
• Family, friends and others who provide your personal information to us because they think you may be interested in our products and services or they want to share a product or service with you.
• Companies that provide personal information to supplement what we already know about you, including data analytics firms and data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information. • Publicly available sources, including social media sites and public databases.
By Combining Personal Information. For example, we may:
• Combine personal information that we collect offline with personal information we collect through our Platform.
• Combine personal information we collect about you from the different devices you use to access our Platform.
• Combine personal information we get from third parties with personal information we already have about you.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your personal information in the following ways:
• To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions. This could mean responding to a customer service issue.
• To Improve Our Products and Services. We may use your personal information to make our Platform, products and services better and for research and development purposes. We may also use your personal information to customize your experience with us.
• To Understand Your Interests. We may use your personal information to better understand your preferences and to make recommendations to you so that we can provide products that interest you and create your own personal profile of these preferences, trends and interests.
• To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
• To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
• To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our products, services and promotions. For example, this may include verifying your age, date of birth and state of residence. If you apply for a job through our Platform, we may use the personal information you provide to evaluate your application.
• For Marketing Purposes. We may provide you with information about new products and special offers. We use your personal information to serve you ads about products and offers on the Platform, other third-party websites and on social media websites. We might tell you about new features or updates. These might be third-party offers or products or our family of brands products that we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message. We may use your personal information to personalize your experience or provide you more tailored features or ads. We may also use your information for joint promotional offers. We may use this information to create segments and profiles of consumers to better understand your interests, behavior, and preferences for advertising purposes.
• For Interest-Based Advertising. We and our third-party partners engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Platform or on other sites, services and mobile applications or on other devices you may use. For more information about your choices related to these communications, see the “Online Advertising and Third Party Tracking” section below.
• For Security, Legal and Infrastructure Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform or enforcing our terms, complying with law and establishing business continuity systems and backups.
• To Send Push Notifications. If you use our mobile apps, we may send you push notifications about new products or special offers.
• For Internal Business Purposes. For example, to provide and improve our Platform, for quality control, and investigations. We may use aggregate and deidentified information to understand how to provide better products to you, improve our products and solutions, improve our advertising and marketing and to other related business purposes:
• As Otherwise Permitted By Law or As We May Notify You.
HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information in the following ways:
• Internally. We may share your personal information within the Supple Companies and Brands.
• On Our Platform. For example, we may display personal information you post on our Ratings & Reviews feature. We may also display personal information you submit in connection with a promotion.
• With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. For example, this may include merchandise providers, payment processors, fraud and security solution providers, subscription services, shipping services, logistics services, customer service providers, cause marketing partners, technology providers, loyalty providers, advertising agencies, marketing and email vendors.
• With Our Business Partners. This may include a third party that co-sponsors a contest or promotion. We may also share personal information with data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers, data analytics providers and business partners who help us offer our products and services.
• With Third Parties for Marketing Purposes. This may include our affiliate companies or brands or third parties whose products or services we believe may be of interest to you or social media platforms where you interact or where our ads are displayed. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising. We may also share aggregated and deidentified data with social media sites, online advertising companies and marketing and advertising providers for our marketing and advertising programs.
• For Business Transactions or Reorganizations. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. As we continue to develop our business we may buy other businesses or services. As we bring these new brands and affiliates into our family of companies we may share data with them. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
• To Comply With the Law or To Protect Ourselves or Third Parties. This could include responding to a court order or subpoena. It could also include sharing personal information as required with government agencies or investigatory body requests. We might share personal information when we are investigating potential fraud.
• For Other Reasons We May Describe to You.
CHILDREN UNDER 13
Our Platform is intended for adults. We do not knowingly collect or solicit any information from anyone under the age of 13 through our Platform. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have collected personal information from a child under 13, please contact us at email@example.com.
CHOICES REGARDING YOUR PERSONAL INFORMATION
At any time, you can opt out of receiving our marketing communications, including promotional emails and text messages. Note that you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries. To opt out of receiving our marketing communications, you can contact us as follows:
• You can opt-out of our promotional emails or text messages by following the instructions included within each of those communications. You can also opt-out of these promotional messages by contacting us: Send us an email at firstname.lastname@example.org.
• Call us at 1-866-219-6371 (Monday through Friday, 9:00 AM – 5:00 PM CST).
Mobile Application and Location Based Services:
• You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.
• You may completely opt out of all location-based information collection by us if you uninstall all of our mobile apps from your devices.
ONLINE ADVERTISING AND THIRD-PARTY TRACKING
Cookies & Other Tracking Technologies:
• We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Platform and your user experience.
• You adjust Advertising and Analytics tracking tools through the “AdChoices – Do Not Sell or Share” link at the bottom of our Platform. In addition, your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here.Why? Because flash cookies cannot be controlled through your browser settings.
• If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.
We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. We permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our websites, including shopping behavior and purchase behavior, and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media or other sites you may use. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
• To learn more about interest-based advertising and how you may be able to opt out of the use of your personal information for interest-based advertising purposes, you may visit the bottom of a Supple brand homepage that links to this Policy and clicking on “AdChoices – Do Not Sell or Share” at the bottom of the page, you will be taken to a tool which will allow you to opt out of certain online advertising and tracking activities.
• Please note, however, that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, the options you select relating to interest-based advertising are browser and device specific. If you use a different device, change browsers, or visit a different Supple brand website or delete the opt-out cookies, you may need to perform the opt-out task again.
• You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt out of interest-based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Google Analytics and Advertising:
We use Google Analytics to better understand how our users interact with our Platform and such data is shared with Google. For information on how Google Analytics collects, uses and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Marketing 360, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service.
You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
Our Do Not Track Policy:
• Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. While we continue to evaluate this evolving technology, we do not currently respond to those signals. However, you can opt-out of such tracking directly on the Platform by following the steps noted in the Interest-Based Advertising section above. If you have questions, please contact us via one of the methods listed in the “How to Contact Us” section at the end of this Policy.
• If you block or reject cookies, not all of the tracking described here will stop and some features of our Platform may not be available.
• Options you select are browser and device specific.
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:
• California. If you are a California resident, please click here for additional California-specific privacy disclosures.
• Virginia. If you are a Virginia resident, please click here for additional Virginia-specific privacy disclosures.
• Nevada. Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at email@example.com. with the subject line “Nevada opt-out”.
The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us via the Platform. We have, however, taken reasonable security measures designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. We encourage you to use caution when using the Internet. A user id and a password are needed to access certain areas of the Platform. It is your responsibility to protect your username and password.
STORAGE OF INFORMATION
Our Platform is directed only to U.S. consumers for products and services of Supple Group of Companies and Brands in the United States. Our Platform is not directed to consumers outside of the U.S. Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. Our Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.
LINKS TO THIRD-PARTY SERVICES
Our Platform may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Policy. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.
HOW TO CONTACT US
• If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at firstname.lastname@example.org or by telephone at 1-866-219-6371 (Monday through Friday, 9:00 AM – 5:00 PM CST).
CHANGES IN POLICY
From time to time, we may change this Policy. We will notify you of any material changes to this Policy as required by law. We will also post an updated copy of this Policy on our Platform. Please check our Platform periodically for updates.