Privacy Policy

TRUSALUS, Inc. Privacy Policy

Effective: March 23, 2022

IMPORTANT NOTICE

At TRUSALUS, our mission is to end overuse injury, bringing true health, vitality and prosperity to all people.  We educate athletes of all ages on the perils of overuse.  We inspire the development of healthy relationships with the body, allowing for real change to occur.  We lead individuals through the process of safely recovering from overuse injury, re-conditioning the body, and overcoming performance plateaus to master their athletic potential.  That mission covers our offline and in-office activities, and extends to our online community as well through our websites, applications, and connected products and services (which we collectively refer to in this Privacy Policy as the “Services”). Our Privacy Policy describes how we collect and process your Personal Data through our websites (e.g., including, but not limited to, trusalus.com and trunutrition.fit (“Websites”)).  We encourage you to read this Privacy Policy as well as our Terms and Conditions of Use (referred to throughout as our “Terms”).

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.

Please read this Privacy Policy carefully, as your access to and use of the Services signifies that you have read, understand and agree to all terms within this Privacy Policy. If you do not agree with any part of this Privacy Policy or our Terms, please do not access or continue to use any of the Services or otherwise submit your Personal Data.

Who We Are

We are TRUSALUS, Inc. (collectively referred to herein as “TRUSALUS” “we,” “us,” or “our”). We provide education and services designed to highlight the prevalence of overuse injury and recommendations for movement, nutrition, hydration, and sleep to promote overuse injury recovery and prevention.

Information About Your Personal Data

This Privacy Policy relates to data about you and your interaction with our Services.

"Personal Data" is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your full name, email address, phone number, and "Fitness and Wellness Data."

TRUSALUS collects, uses, discloses and processes Personal Data as outlined in this Privacy Policy, including to operate and improve the Services and our business; for advertising and marketing; and to provide you with innovative fitness and wellness services, as further described in this Privacy Policy.

We may create de-identified or anonymous data from Personal Data by excluding data components (such as your name, email address) that makes the data personally identifiable to you, through obfuscation, or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

 

How We Collect and Use Personal Data

We collect your Personal Data in a number of ways and for various purposes, including:

  1. When you register for an account or interact with our Services.

We collect Personal Data when you use or interact with our Services, including when you register with us, browse our products online, obtain coaching and training services, make purchases from us (including processing of payment), and when you ask us to customize products, or Services. This Personal Data may include name, address, phone number, username and password, email address, date of birth, and payment information.

2. When you input Fitness and Wellness Data within our Services or use our Services that collect or infer such data from “Team Injury Screenings”, “Telehealth”, or “Online Membership.”

"Fitness and Wellness Data" includes data you provide related to your lifestyle (e.g., sleeping habits), life events, dietary restrictions, fitness goals, height, weight, measurements, fitness level, heart rate, sleep data, BMI, biometric data, and similar types of data relating to physiological condition, and activity. We collect this data in order to provide the Services and to tailor features, products, advertising, and services to your interests and goals, including providing meal suggestions, workout plans, training- and coaching-related services, and product recommendations (e.g., custom products).

  1. When you communicate with us or sign up for promotional materials.

We collect Personal Data when you communicate with us or sign up to receive promotional materials or information via email, push notifications, or text messages - including email address, mobile number, etc.

If you consent to such messages, we may use your Personal Data and other information to communicate with you about the TRUSALUS products or Services you have purchased or used; provide you with promotional messages and personalized advertising; to notify you of other products; to notify you of contests, challenges, sweepstakes, and other promotions ("Promotions"); to notify you of Services we think may be of interest to you; and, for other marketing purposes. You can manage your communication preferences by registering for and logging into your account.

Please note that regardless of your email settings, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms or this Privacy Policy or other formal communications relating to products or Services you have purchased or use.

We may use your Personal Data to respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests. We may also use your Personal Data to address your requests, inquiries, and complaints.

  1. When you participate in special activities, offers, or programs.

We may request or otherwise collect Personal Data, including Fitness and Wellness Data when you participate in Promotions, when you participate in surveys, or when you participate in research activities or initiatives, including for academic, commercial, wellness-related, and research study purposes ("Research"). This includes Personal Data, such as name, address, email address, telephone number and age and other information that may be appropriate in order to participate.

We may also launch surveys that ask you to answer questions about a range of topics from Personal Data to brand and product preferences. Promotions or surveys may be run by a TRUSALUS service provider or co-branded with one of our business partners. In such instances, Personal Data may be collected directly by and/or shared with TRUSALUS, the service provider, and/or business partner, including for marketing purposes. Each Promotion or survey that treats your Personal Data in a way that differs from this Privacy Policy will state the privacy policy governing that collection of information in connection with that Promotion or survey.

  1. When you engage with our online communities or advertising.

We may collect your Personal Data when you engage with our online communities. This includes when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with TRUSALUS. Please note that our community forums are public, so we recommend that you exercise care in deciding what information and content you wish to disclose.

  1. When you access third party products and services.

We may allow you to register and pay for third-party products and services or otherwise interact with another website, mobile application, or Internet location (collectively "Third Party Sites") through our Services, and we may collect Personal Data that you share with Third Party Sites through our Services. When we do so, we will inform you of the further details of how we use your Personal Data.

  1. When you connect with us through social media.

You may choose to enable, log into, or sign on to the Services through various social media or social networking services, such as Facebook or Twitter ("Social Networking Service" or "SNS"). When you connect using your SNS accounts, we may collect Personal Data that you have provided to that SNS. For example, when you log in with your Facebook credentials, with your consent, we may collect Personal Data from your Facebook profile that is permitted under Facebook's Terms of Use - such as your email address, profile picture, and friend list. We use this data to provide, enhance, and personalize the Services (e.g., to help connect you with or suggest friends within our Services). If you do not want to provide us with this data, you need to adjust the privacy settings on your SNS account.

  1. When we collect data from third parties or publicly-available sources.

We may obtain certain data about you from third party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services, such as providing you with a single point of sign on for our Services and/or building an account dashboard letting you understand how to access and control all the Services you use from a single page.

  1. When we leverage and/or collect cookies, device IDs, Location, data from the environment, and other tracking technologies.

We may collect certain Personal Data using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. Our Cookie and Device ID Use section contains more information and options to control or opt-out of certain data collection or uses.

  1. When we aggregate or centralize data.

We aggregate and centralize Personal Data and Fitness and Wellness Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.

  1. When we link you to friends across platforms.

Some of our services consist of social sharing and communication with others. We use your Personal Data to enable sharing as described in the service, including to enable you to find and link to friends on other TRUSALUS platforms.

  1. When you take fitness tests or assessments; share content or achievements; or invite friends.

We use video data you provide to us and phone sensor data in order to estimate joint flexibility measurement, angles of motion, real-time fitness potential, and to assess your physical movement. We use this data to provide instructional videos, instructional feedback, coaching, and training services. With your permission, we access your contacts and calendar to enable you to share content or achievements, including videos, with friends or other members, and to invite friends to use the Services.

We use photos, videos, or other data you provide to us to customize apparel, products, or Services.

  1. When we comply with Legal Requirements or Obligations, Law Enforcement, and for Public Safety Purposes (Location-Specific Disclosures may apply).

We may use Personal Data in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

How We Disclose Personal Data

We may disclose your Personal Data for the purposes as described in the prior section of this Privacy Policy, in the Location-Specific Disclosures section, and in the following ways:

  1. To Affiliates and Partners

With companies or ventures that are owned or controlled by TRUSALUS, and internally within TRUSALUS, in order to provide and improve Services, for marketing purposes, and for advertising.

  1. To Service Providers and Vendors.

With business partners, marketing partners, and vendors to provide, improve, and personalize the Services.

With social network providers when we use social network widgets, buttons, or plug-ins in our Services.

  1. To other Users/TRUSALUS Registered Users.

With other users in the context of specific Services that are social in nature. In these cases, we disclose social data and certain Fitness and Wellness Data by default because the service being provided is one of social interaction. Additionally, any information you post or disclose in our community forums (for example, Facebook, YouTube, Twitter, Instagram) is public.

  1. For Advertising and Marketing.

With advertising and marketing partners for advertising and marketing purposes on TRUSALUS’s behalf and on behalf of third parties.

  1. For Certain Analytics and Improvement

With certain companies for purposes of analytics and improvement of the Services.

  1. For Interest-Based Advertising.

With companies involved in interest-based advertising, including web, mobile app and other advertising. This advertising consists of TRUSALUS and third party ads that are personalized and displayed on our sites and apps and through other channels. Advertising also includes personalized ads from TRUSALUS displayed on Third Party Sites and apps and through other channels.

  1. For Legal Compliance, Law Enforcement, and Public Safety Purposes.

With law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.

  1. In the event of an actual or contemplated sale.

With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.

Legal Basis for Processing

For the purposes of applicable data protection laws, TRUSALUS is the controller of the Personal Data you provide to us (“Data Controller”). As a Data Controller, we process the Personal Data we maintain about you in accordance with this Privacy Policy. If you have any questions or concerns regarding the processing of your Personal Data, or if you have questions regarding this Privacy Policy, please see “How to Contact Us” below for appropriate contact information.

We collect and process your Personal Data for a variety of purposes outlined in this Privacy Policy. In certain cases, separate consent is not required, including:

  1. For the performance of a contract

To perform our contractual obligations to you, including account registration, fulfilling orders or purchases you have made (including processing of payment), contacting you in relation to any issues with your order, in relation to the provision of the Services, including when you use or interact with a wearable or other connected device and in relation to location-based Services (including to provide you geographically relevant Services), to connect you with friends across platforms, when you take fitness tests or assessments, share content or achievements, or invite friends, when you ask us to customize products, or Services, where we need to provide your Personal Data to companies or ventures that are owned or controlled by TRUSALUS and to our service providers, where we need to collect Personal Data from third party sources and when you access third party products and services, where we collect data from third parties or publicly-available sources, or to aggregate and centralize data for the performance of the Services

  1. To meet legal obligations

To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.

  1. For Legitimate Interests

To operate our business and provide the Services, other than in performing our contractual obligations to you for TRUSALUS's "legitimate interests" for the purposes of applicable law - except where overridden by the interests or fundamental rights and freedoms that require protection of Personal Data.

For example, the following areas include processing covered by Legitimate Interests, subject to applicable law:

    • Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to our TERMS and also to address your requests, inquiries, and complaints. We may send strictly necessary communications, including emails, even if you have opted out of receiving other TRUSALUS emails or communications. These types of communications do not require consent. We also process your Personal Data for our legitimate interests when you communicate with us, including when you sign up for promotional materials and we have not asked you for your consent in that regard.

    • Respond to Your Requests. To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.

    • Promotional Messages. We process your non-sensitive Personal Data to provide you with promotional messages and personalized marketing, including: when you communicate with us or sign up for promotional materials; when you participate in special activities, offers, or programs; when you engage with our online communities or advertising; to provide you geographically relevant Services, offers, or advertising; when we aggregate and centralize data; and when we share Personal Data with companies or ventures that are owned or controlled by TRUSALUS and with our service providers and vendors.

    • Surveys. To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given us your consent to receive marketing from us.

    • Compliance with Law and Public Safety. To assist in the investigation of suspected illegal or wrongful activity, including in-store tracking and sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend our rights and property, or the rights or safety of third parties.

    • Improvement and Development. To develop, provide, enhance, and improve our Services and your experience, including to enable you to use the full range of our Services (e.g., processing of non-sensitive Personal Data related to use of team injury screens, telehealth, or online membership services, when you access third party products and services; when we collect, use, or otherwise leverage cookies, device IDs, data from the environment, and other tracking technologies; when you connect with us through social media; when we collect data from third parties or publicly-available sources; when we aggregate and centralize data; and when we share Personal Data with companies or ventures that are owned or controlled by TRUSALUS and with our service providers and vendors). For internal purposes related to certain research, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.

    • Enforcing Terms and Notice. To enforce our Terms or this Privacy Policy, or agreements with third parties.

    • Merger or Acquisition. (Location-Specific Disclosures may apply). To support a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.


Consent as a Basis for Processing

In some cases, we will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, ticking a box (or equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services or a form (including enrolling in Promotions); or (ii) registering or creating an account with us. Due to different countries' laws governing consent for the collection and use of Personal Data, the requirements for consent will differ across regions. We may request your consent for a number of activities including:

  1. TRUSALUS Marketing and Communication.

We may ask for your consent to contact you by telephone, SMS/text message, and/or email about other offers, products, Promotions, events, or services that we think may be of interest to you and for other marketing purposes.

  1. Sharing with Third Party Services.

We may also ask for your consent to share your Personal Data with certain Third Party business partners in order to offer certain goods, services, or programs.

  1. Third Party Marketing.

We may ask for your consent to provide Personal Data to allow third parties to contact you regarding their products, services, Promotions, or offers. Typically this is in conjunction with a sweepstakes or challenge (your consent for third party marketing is generally not a pre-requisite to participation. To withdraw consent, please contact info@trusalus.com

  1. Processing Sensitive Personal Data.

We may request your consent to process sensitive Personal Data. Certain Websites or Mobile Apps may require this data to provide the Services, including when you use or interact with a wearable or other connected device, and when you take fitness tests or assessments. If you choose not to provide sensitive Personal Data (for example, specific kinds of Fitness and Wellness Data), certain features or Services may be unavailable or not function properly.

  1. Research.

We may request your consent to use your Personal Data for Research purposes. We may also request your consent to contact you to determine your interest to participate in certain Research initiatives and to share identifying results. For market research, we may ask questions on behalf of business partners and share your response with business partners.

  1. Advertising.

We use cookies, pixels (including email pixels), mobile device and advertising IDs, Fitness and Wellness Data, app or service usage data and data from sensors for purposes of interest-based and cross-app, cross-device advertising.

  1. Transfer of Data.

We transfer data to the United States and to other countries/regions for processing. We may request your consent for this transfer or the transfer, in other cases, may be justified by a legal basis other than consent.

  1. Automated Processing.

We may use some automated processing to provide our Services and to make recommendations in the context of specific services. This processing is strictly necessary for providing certain Services (and, in some cases, is the service itself) and is not covered by consent. Other automated processing is not significant either due to the nature of the data or the decisions being made or recommended, and so consent is not required. However, for automated processing that is significant and related to sensitive Personal Data, prior to sharing or using such data, we will first seek your consent.

  1. To Enable Social Sharing and Connect with Us on Social Media.

Some of our services consist of social sharing and communication with others. If you sign up for these services, we may ask for your consent to use your information to enable sharing as described in the service.

We may also ask for your consent when you connect with us through Social Media.

  1. Promotions.

We may ask you for permission to use your Personal Data and Fitness and Wellness Data for special offers, events, sweepstakes, and other Promotions. We may use the Personal Data we collect during Promotions, to administer the Promotion, verify identity and age, and to communicate with you about the Promotion.

Interest-Based Advertising

Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. Our advertising practices also include the creation and use of "audience segments." You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads. Depending on where you access our website from, you may also be asked to consent to our use of cookies, including advertising cookies. Additional information on Audience Segments and our choices for interest- based advertising is found below.

  • Audience Segments

We disclose various types of information for purposes of interest-based advertising, including for third party, interest-based advertising. This processing includes the use of Personal Data to create de-identified audience segments. These audience segments are then made available for interest-based advertising, including for third party advertising, on TRUSALUS online properties. The audience segments are based on website visits, app usage data, Fitness and Wellness Data, online and offline purchasing behaviors, interaction with our ads or marketing emails, similar types of information, and in some cases, data from third parties. The segments, prior to being used, are de-identified so that they will not identify you personally.

United States Note: The audience segments are made available for interest-based advertising for third party advertising on TRUSALUS online properties and on and within third party websites and apps. We use one or more safe haven entities and partners to de-identify segments before sharing these segments for third party advertising displayed on online properties operated by entities other than TRUSALUS. We use a third party to match de-identified segments to targeting IDs that are then used on third party sites.

  • Interest-Based Advertising Opt Outs, Choices, and Control

For all of the interest-based advertising described above, including segments, you have the choice to not have your data used to target and serve you interest-based advertising-including third party advertising-regardless of where such ads might be served. These opt-outs require that strictly necessary cookies are not blocked by the settings in your web browser.

Managing Preferences and Withdrawing Consent

You may at any time withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding website and online data collection, interest-based advertising, your communication settings, and app preferences. Depending on the Service, collection and use of Personal Data may be required for the Services to work.

We provide you several ways to manage your preferences:

  • Cookie Use and Controls

Cookies serve a wide variety of purposes. Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to remember your shopping cart and personalize your web experience and for security, analytics, marketing, and interest-based advertising. Our cookies are placed and read by our web servers, while other cookies are placed and read by other companies' web servers.

One way to think about cookies is based on their function. The following settings will control our use of browser cookies, the use of IP address for tracking, and the collection and use of data for cookie-based, interest-based advertising.

    • [ IN ] Required Cookies. These strictly necessary cookies are used for core functionality, and recognize when you are signed in, remember things such as shopping carts and text entered, are necessary for security, and enforce your privacy preferences. Without these cookies, some functionality on our websites will fail. You can block these cookies in your browser preferences.

    • [ IN / OUT ] Functional Cookies. These cookies help to improve the sites by allowing us to understand how the site is used and how the site performs. These cookies include analytics and measurement.

    • [ IN / OUT ] Advertising Cookies. These cookies help us and other parties personalize ads that are shown to you on our sites and Services, as well as on other sites. If enabled, these cookies will allow third parties engaged in interest-based advertising on our site to recognize your browser software on other sites too.

  • IP Address Use

An IP address refers to an identifier assigned by a network to a computer, mobile device, Internet of Things (IoT) device, or routing device. IP addresses, for purposes of this Privacy Policy, include "public" IP addresses, such as the IP address for a home router that is visible to the Internet, as well as "local" IP addresses, which are IP addresses assigned to computers and mobile devices "behind" a router (such as a home router). Our advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency.

You can choose not to have IP address used for purposes of advertising or analytics by using the cookie controls for "Advertising Cookies," and "Performance/Analytics," above.

  • Web Pixels or Beacons Use

Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party's cookies are currently stored in your browser, those cookies will be transmitted with the request. Beacons can be used on web pages for advertising or to confirm the opening of a marketing email. When used in conjunction with cookies for interest-based-advertising, the cookie controls above can be used to control the purpose for which they are used.

  • HTML5 Local Storage

HTML5 Local Storage in the browser is different from cookies, but can be used for the same purpose (to pair a tracking ID to a particular web server with your web browser so that the web server can identify your web browser over time). You can control the purpose for which HTML5 Local Storage is used by using the cookie controls outlined above.

  • Flash Cookie Use

Flash cookies are "local shared objects" used by Flash player to store data, similar to cookies. Although Flash content is declining in use, we may still use Flash on our sites. If you have Flash installed, and wish to delete, block, or manage Flash cookies, please use the Flash settings panel made available by Adobe.

  • Social Network Interaction and Widgets

Social network widgets, buttons, and plug-ins on our websites passively transmit data regarding a social network's members to that social network, even when a button is not clicked. These technologies may allow a social network (such as Facebook, Twitter or YouTube) to personally identify its members and to know the web pages its members have visited. This is true wherever social network buttons are embedded, regardless of whether a button is "clicked" or "pressed." If you belong to a social network or use these categories of web services, you should review the privacy policies of those services to understand the nature of the data that they collect and what, if any, options the service offers to control how data is collected and used. If you disable advertising cookies, the passive tracking associated with these buttons will be blocked on our sites.


Consent for Email Communication: After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any commercial email we send. If you use more than one Service, then unsubscribing from the emails relating to that Service will not stop you from receiving emails from other Services. Please note that if you unsubscribe from "all emails" this means "all emails other than strictly necessary emails." You will still receive email communications from us if they are strictly necessary to provide the TRUSALUS service or to confirm or validate a transaction, recover accounts, etc.

Opt-In Mobile Text Messages: You can opt-in to receive promotional, marketing, and special offer text messages from TRUSALUS. Text messages are auto-dialed and consent to text messages is not required for any purchase or service. You can opt-out of marketing by sending STOP to the number following the directions sent back to you when you sign up.

Transfers of Your Personal Data to Other Countries

The Personal Data TRUSALUS processes, and all associated Services and systems, including registration, is housed on servers in the United States. If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States (the data protection and privacy laws in the United States may offer a lower level of protections than in your country/region).

By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the United States. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy.

Data Retention

We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete your Personal Data from our systems.

Where permissible, we will also delete your Personal Data upon your request.

If you have questions about our data retention practices, please contact us through our Support Team.

Security

We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

Links to Other Websites. Please note that this Privacy Policy does not apply to the practices of companies that we do not own or control or to people that we do not employ or manage. Our Services may provide a link or otherwise provide access to Third Party Sites. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for Third Party Sites, their content, or any goods or services available through the Third Party Sites. Our Privacy Policy does not apply to Third Party Sites, and any data you provide to Third Party Sites, you provide at your own risk. We encourage you to review the privacy policies of any Third Party Sites with that you interact with.

Children

We do not knowingly collect Personal Data online from children under the age of 12, without parental consent (note that the minimum age may vary based on location, and on local law). If you become aware that a child has provided us with Personal Data without parental consent, please contact us through our Support Team. If we become aware that a child under 12 has provided us with Personal Data without parental consent, we will take steps to remove the data and cancel the child's account.

How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through our Support Team or write to us at:

TRUSALUS, Inc.
Attention: Privacy Office, Legal Department
1981 N. Broadway, Suite 150

Walnut Creek, CA 94596

*Residents of the United States have the right to ask us to delete your Personal Data, as permitted by law.

Residents of California

If you are a resident of California, you have certain rights to the Personal Data that we have collected about you. Under California law, the exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., maintaining confidentially when legally required). We will comply with your request as soon as reasonably practicable. Requests to exercise your rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. To prevent unauthorized access to your Personal Data, we take steps to verify an individual's right to the data - including requiring users to reach out to us directly from a verified email address, pass a challenge response, and/or confirm information associated with the account. Following verification of your identity, we will notify you if we are unable to fullfill your request and outline the reasons we are unable to honor your request at this time.

  1. Your California Privacy Rights
    You have the following rights:

    • Right of access to your Personal Data: You have the right to ask us for confirmation on whether we are processing your personal data, and access to the Personal data, as permitted by law. This may include what Personal Data we collect, use, or disclose about you.

    • Right to deletion: You have the right to ask us to delete your Personal Data, as permitted by law.

    • Right to Opt-out of "Sale" and Certain Sharing Practices: You have the right to opt-out of certain data sharing practices with third parties who may use your Personal Data solely for their own purposes. Your right to opt-out is limited to information we "sell" to these third parties. "Sell" in this case does not mean providing data in exchange for money-we don't do that. "Sell" instead means the disclosure of data, including technical device data that does not identify you directly, when a third party might use that data for its own purposes, such as for personalized advertising.

Note to California users between 13 and 16: If you are between the ages of 13 and 16, we do not "sell" your information to these third parties without authorization from you.

    • Right to Non-Discrimination: We will not discriminate against you, in terms of price or services that we offer, if you submit one of the rights requests listed above.

  1. How to exercise your rights

    • Exercise your rights (other than opt-out of "sale"): To exercise your rights to your Personal Data, please contact us through our Support Team or at the address listed below.


TRUSALUS, Inc.
Attention: Privacy Office, Legal Department
1981 N. Broadway, Suite 150

Walnut Creek, CA  94596


For Shoppers in the United States:

    • Exercise your opt-out of "sale" rights: For instructions on how to exercise your rights, please email info@trusalus.com

  1. Additional California Rights:

California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party's direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge.

Under Section 1798.83, we currently do not share any Personal Data with third parties for their direct marketing purposes. If we do decide to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to our Support Team, or in writing to:

 


It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing.

Additionally, if you are a registered user under the age of 18 and a resident of California, you may request removal of content you have posted to the Services. Requests can be made to our Support Team. Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party we do not own or control may copy the posting and repost it elsewhere.