Effective Date of Current Policy: July 29, 2019
All individuals whose responsibilities include the processing of Personal Information (as defined in Section 2 below) on behalf of ELXR Life are expected to protect that data by adherence to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
2. Information We Collect or Receive
In the course of operating the Platform, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.
2.1 Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, email address, physical address, and phone number. We do not collect any Personal Information from you when you use the Platform unless you provide us with the Personal Information voluntarily. We may also collect Personal Information from you when you choose to register for a newsletter or loyalty program that we may offer or participate in online surveys, in-person interviews, or focus groups.
2.4 Promotion and Giveaways. Occasionally we will partner with third parties on social and online channels to sponsor giveaways and promotions. Terms and conditions will accompany each giveaway and promotion, and it is the responsibility of all entrants to read the terms and conditions and privacy policies carefully. If you choose to share your information in order to participate in a giveaway or promotion, your entry information may be shared with such third parties.
2.5 Other Information. In addition to the Personal Information and Payment Information, we may automatically collect or receive additional information regarding you and your use of the Platform; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Platform (collectively, the “Other Information”). Such Other Information may include: From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences. From Your Activity. We may collect or receive information regarding: IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device; browser type and language; referring and exit pages and URLs; date and time; and details regarding your activity on the Platform, such as search queries and other performance and usage data. About Your Mobile Device. If you use a mobile device to visit or access the Platform (whether by using a ELXR Life mobile application or otherwise), we may collect or receive information regarding the type of mobile device you use to access the Platform, along with information about that mobile device’s operating system and version (e.g., iOS, Android or Windows), carrier; and network type (e.g., WiFi, 3G, 4G, LTE). Other Information Collected by Automated Means. Additional information collected by automated means as described in Section 3 below.
3. Information Collected By Automated Means
We may associate this information with your Account with ELXR Life if you have one, the mobile device or browser you use to access to the Platform, or email or social media accounts that you use to engage with ELXR Life. If you do not want us to deploy cookies in the Platform, you can opt out by setting your mobile device or browser to reject cookies. You can still use the Platform if you choose to disable cookies, although your ability to use some of the features may be affected.
4. Advertising Services Provided By Others
5. How Information is Used and Shared
You authorize us to use the Personal Information, Payment Information, and the Other Information (collectively, the “Information”) to: provide and improve the Platform or any services offered or made available through the Platform; provide and improve our Products; provide any services offered or made available through the Platform; administer our promotional programs; solicit your feedback; and inform you about our Products, the Platform, and any services offered or made available through the Platform. Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, referral offers, newsletters, mailings, or phone calls from us with information on ELXR Life’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
In order to provide our services and administer our promotional programs, we may share the Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
In an ongoing effort to better understand our users, the Platform, any services offered or made available through our Platform, and our Products, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the Platform and/or such Products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Platform and these Products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
The content you post to the Platform may be displayed. Other users of the Platform may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of other users who will view and use the posted information.
We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
To the extent permitted by law, we may also disclose the Information (a) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (b) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.
6. Accessing and Modifying Information and Communication Preferences
If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth in Section 14. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing emails. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. Note that you will continue to receive transaction-related emails regarding products or services you have requested (e.g., requests for support).
We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.
We will provide opt-out notices to third parties who may contact you on our behalf in accordance with this Policy. While we will endeavor to ensure that you are removed from any such contact lists, we cannot guarantee that this will occur (for example, if your Information is provided to the third party through another advertiser whose communications you have elected to receive and not opted out).
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
7. Your Sharing of Information Through the Platform
We do not control your use of the Platform to share Information about you (whether Personal Information or otherwise) with others. If you chose to share any Information about yourself publicly on or through the Platform, you understand and acknowledge that we cannot control the actions of third parties who could collect this Information.
8. Do Not Track
We do not monitor, recognize, or respond to any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
9. How We Protect Your Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email.
The security of your use of your Account relies on your protection of your username and password. You may not share your username and password with anyone. If you believe that unauthorized access to your Account has occurred please report it immediately at firstname.lastname@example.org. You must promptly notify us if you become aware that any information provided by or submitted to your account has been lost, stolen, or used without permission. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on an ELXR Life website.
Any email or other communication purporting to be from ELXR Life or our Platform or made by a third party on ELXR Life’s behalf that requests your password or asks you to provide sensitive account information via email should be treated as unauthorized and suspicious and should be reported to us immediately by emailing email@example.com. If you believe someone else has obtained access to your password, please change it immediately by logging in to your Account and selecting the provided option to change your password and report it immediately by emailing firstname.lastname@example.org.
10. Important Notice to Non-U.S. Residents
The Platform and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Platform, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.
11. App-stores; External Websites
In the event you are accessing the Platform by means of a mobile application owned or operated by ELXR Life, your app store (e.g., iTunes or Google Play) may collect certain information in connection with your use of the Platform, such as Personal Information, Payment Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.
Neither the Platform nor the Products are directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the Platform. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.
14. How to Contact Us