Last Updated: January 19, 2024
Introduction
This Privacy Policy describes how Vytalogy Wellness, L.L.C. and its affiliates (together, “Vytalogy”, “we”, “us”, or “our”) collect, use, disclose, and protect information from or about those individuals visiting our websites (located at www.vytalogy.com, www.jarrow.com, and www.natrol.com), our social media pages, any other website offered by us that links to this Privacy Policy, and any other interactions (e.g., customer service and other communications) that you may have with Vytalogy (collectively, the “Services”).
By using the Services, you acknowledge and represent that you have read, understood, and agree to this Privacy Policy.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLEYOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USETHE SERVICES.
For purposes of laws using such terms, Vytalogy acts as the “data controller” of your information, meaning the entity that determines the nature of means of processing your information.
This Privacy Policy contains the following sections:
1. Information We Collect About You
2. How We Use YourInformation
3. Disclosure of Your Information
4. Online Analytics and Advertising
5. Information for International Users
6. Your Rights and Choices
7. Notice to California Residents
8. Security of Your Information
9. Retention of Your Information
10. Links to Third Party Sites
11. Children’s Privacy
12. Changes to this Privacy Policy
13. Contact Information
14. Accessibility Statement
1. Information We Collect About You
Information You Provide Directly to Us
We collect information about you when you voluntarily submit it directly to us or when you access or use our Services. This can include information you provide to us when you:
· Correspond with us via the Services, phone, email, or otherwise;
· Fill out an online form;
· Place an order;
· Subscribe to our mailing lists, newsletters or other forms of marketing communications;
· Respond to or participate in surveys, sweepstakes, contests, or other offers;
· Attend our events, or otherwise interact with us at other events or conferences; or
· Interact with us or the Services in another way.
The types of information we collect directly from you depend on how you interact with us, and may include your name, business contact information (including email address, postal address, telephone number), company or organization name, job title, billing and payment information for the business on whose behalf you place an order, information about your marketing and advertising preferences, and any other information you choose to provide to us.
If you choose not to provide certain information, we may not be able to provide the Services to you or respond to your other requests. For example, we cannot contact you if you do not provide us with your contact information.
Information We Collect Automatically
When you use our Services, we and our third-party vendors may automatically collect certain information about your browser, device, and use of the Services, including your IP address, browser type, browser language, operating system, the state or country from which you access the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).
To collect this information, we and our vendors (including certain third-party advertising technology partners) may use “cookies” or similar tools that track, measure, and analyze the behaviors and usage patterns of the users of our Services. Cookies are small data files that can be stored on your browser and device to perform a variety of functions, including to recognize you when you return to the Services, deliver certain features of the Services, help us understand and analyze how the Services are used, facilitate online advertising, and improve your experience of the Services. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Services may be restricted. To learn how to manage your cookies, please follow the instructions from your specific browser or device. Please be aware that if you access the Services from a new browser or device, or if you delete all cookies from your browser, you will need to re indicate your cookie preferences. In addition, please note that you cannot opt out of “essential” or “strictly necessary” cookies, which are needed for operation of the Services. We may also use cookies and similar tools in emails to, for example, identify users who click links to our websites in our emails.
For more details about our use cookies and similar tools for analytics and advertising purposes, please refer to the “Online Analytics and Advertising” section below.
Information We Collect from Other Sources
From time to time, we may collect information about you from other sources, including marketing vendors, survey providers, data enhancement services, conferences, and other industry events, as permitted by applicable law. We may also collect information about you via social media, when, for example, you follow our social media pages, like our posts, tag us in a post, or share or comment on our content.
2. How We Use Your Information
We may use your information for various purposes, depending on the types of information we have collected from and about you, including to:
· Provide and maintain the Services;
· Respond to your inquiries, communicate with you about your orders, provide customer service, or communicate with you in similar ways;
· Facilitate transactions and fulfill your orders;
· Market and advertise ourselves, our products, and the Services to you, including via email, mail, phone, SMS/text message, and online advertising, subject to applicable law and any preferences you have communicated to us;
· Administer surveys, sweepstakes, contests, promotions, or other offers;
· Analyze use of the Services and improve the Services;
· Develop new products and services;
· Secure the Services and resolve technical issues;
· Manage our business relationships and for other business purposes such as audits, analyses, and in the context of corporate mergers or other reorganizations;
· Comply with applicable laws, rules, regulations, and legal process (such as subpoenas, warrants, and court orders);
· Establish, exercise, or defend our legal rights, and protect the rights or safety of us, the Services, our employees, and any other parties; and
· For any other purpose, with your consent.
Aggregate/De-Identified Information
We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device(“De-Identified Information”). We may use De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.
Combined Information
We may combine the information that we collect through the Services with information that we collect from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Legal Bases for Processing
The laws in certain jurisdictions (such as those in the European Union and United Kingdom), require us to inform you of the “legal bases” on which we process your information. The legal bases for using your information as set out in this Privacy Policy are as follows:
· Where we need to perform the contract we are about to enter into or have entered into with you for the Services.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
· Where we have your consent to process your information in a certain way.
3. Disclosure of Your Information
We may disclose your information to the following categories of recipients:
· Service Providers, Agents, Consultants, and Related Third Parties: We may disclose your information when we use other companies to perform certain business-related functions on our behalf, including the functions described in this Privacy Policy. Examples of such functions include collecting and analyzing data about visits to our site, managing email campaigns and maintaining databases, tax and accounting services, legal services, payments processing, data storage, billing and shipping, security, fraud prevention, and web hosting.
· Advertising Partners: We may allow third-party advertising technology partners (e.g., ad networks and ad servers) to use cookies and similar technologies on the Services to deliver relevant and targeted content and advertising to you on other websites you visit and applications you use, as explained further in “Online Analytics and Advertising” below. To accomplish this, we may disclose or allow such third parties to collect your information.
· Testimonials and Reviews: If you choose to post a review about our Services, we may share the content of your review and/or name with third party websites where our products are sold. We may use third parties, such as Pixlee TurnTo, to syndicate your product review content. By submitting a review, you agree that you will not include personal or sensitive information and that you agree to the use and disclosure of your review for these purposes.
· Related Companies: We may disclose your information to any subsidiary or entity that is affiliated with us for purposes consistent with this Privacy Policy. In addition, in the event of a merger, corporate sale, financing, reorganization, dissolution or similar event involving some or all of our assets, your information may be disclosed in connection with the transaction, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
· Legal Requirements and Other Circumstances: We may disclose your information if required to do so bylaw or in the good faith belief that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement, (b) enforce our legal terms or to protect the security or integrity of our Services, and/or (c)protect the rights, property, or personal safety of Vytalogy or any third party.
· Otherwise with your consent or at your direction: In addition to the disclosures described in this Privacy Policy, we may disclose your information to third parties with your consent or at your direction.
4. Online Analytics and Advertising
Online Analytics
We may use third-party web analytics services on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
Tailored Online Advertising
In using the Services, we allow certain third-party advertising technology partners to place cookies or other tracking technologies on your browser or device to collect information about you as discussed above. These third parties(e.g., ad networks and ad servers) may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser or device to assist in this activity.
For more information about online advertising activities, and how you can generally control cookies from being put on your browser or device to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that if you use these mechanisms, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.
5. Information for International Users
The information we collect may be transferred to and stored in countries outside of the country where you are located, where we and our third-party vendors have operations, including the United States. The applicable data protection laws in these countries may differ from those in your country of residence. By using the Services, you acknowledge that these transfers will occur and consent to them.
6. Your Rights and Choices
Marketing Communications
In accordance with applicable law, we may send you marketing communications regarding us or our Services, or about third party services that may be of interest to you. You can ask us to stop sending such communications at any time through the opt-out instructions provided in the communication or by contacting us using the information in the “Contact Information” section below.
If you opt in to SMS/text communications, we may, either directly or through a service provider, send SMS/text messages to the phone number you provide to us, including marketing communications. To opt out of SMS/text-based marketing communications, follow the instructions in the text.
Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain administrative or transactional emails from us, such as those confirming your requests, regarding your orders, or providing you with updates regarding our Privacy Policy or other terms.
Rights Regarding Your Information
Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to in this section as “personal information”).Specifically, you may have the right to ask us to:
· Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we disclose personal information.
· Provide you access to and/or a copy of certain personal information we hold about you.
· Correct or update personal information we hold about you.
· Delete certain personal information we have about you.
· Provide you with information about the financial incentives that we offer to you, if any.
· Restrict or object to certain uses of your information.
· Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.
Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.
As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.
To exercise any of these rights, you may email us at CAprivacy@vytalogy.com or write to us at 15233 Ventura Blvd., Ste. 900, Sherman Oaks, CA 91403, Attn: Legal Department with your name and type of request you are making.
You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.
Depending on your jurisdiction, you also have the right to lodge a complaint with a supervisory authority for your jurisdiction.
Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes
Depending on your jurisdiction, you may also have the right to opt out of “sales” of your information and “sharing” or “processing” of your information for “targeted advertising.” As explained in the “Disclosure of Your Information” and “Online Analytics and Advertising” sections above, we may provide information to third-party advertising technology partners for targeted advertising purposes or use analytics partners (such as advertising analytics partners) to assist us in analyzing use of our Services and our user/customer base. Under applicable law, the disclosure of your personal information to these third parties to assist us in providing these Services may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.
If you would like to opt out of the disclosure of your personal information through cookies and similar tools for purposes that could be considered “sales” of your information or “sharing” or processing for purposes of targeted advertising, you may, where relevant, navigate to the Cookie Policy link on the bottom right hand corner of our website, select “Preferences,” and adjust the toggle next to “Performance cookies” and “Targeting cookies” so that they are turned off. Note that you will need to opt out on each device you use to access the Services.
7. Notice to California Residents
If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
Throughout this Privacy Policy, we discuss in detail the specific categories of personal information we collect from and about you (Section 1), the purposes for which we use that personal information (Section 2), and how we disclose that personal information (Section 3). We retain your personal information as described in Section 9 below.
We provide additional information required by the CCPA in the chart below.
Opt Out of Sale/Sharing of Personal Information
The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising purposes.
If you would like to opt out of the disclosure of your personal information through cookies and similar tools for purposes that could be considered “sales” of your information or “sharing” or processing for purposes of targeted advertising, you may, where relevant, navigate to the Cookie Policy link on the bottom right hand corner of our website, select “Preferences,” and adjust the toggle next to “Performance cookies” and “Targeting cookies” so that they are turned off. Note that you will need to opt out on each device you use to access the Services.
Additional California Privacy Rights
California residents may make certain requests about their personal information under the CCPA as set forth in “Your Rights and Choices” section above.
Incentive Programs. The Services may offer opportunities to receive certain services or benefits such as discounts or free products, which may require the provision of personal information. Such opportunities could be considered a financial incentive under the CCPA. When you participate in an incentive program, you agree to the terms of that incentive program (if applicable), and you maybe able to revoke your participation depending on the incentive offered (e.g., you can unsubscribe from marketing emails). To the extent we can determine the value of your personal information, we consider the value of providing you with a more personalized experience as well as the expenses we incur in providing incentive programs that are reasonably related to the costs associated with offering the incentives.
Shine the Light
California law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected overtime and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. You can learn more about Do Not Track here.
8. Security of Your Information
We implement a variety of technical and organizational measures to protect your information from accidental or unlawful loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure. We therefore cannot guarantee the absolute security of your information. You provide us with your information at your own risk.
9. Retention of Your Information
Vytalogy will retain your information only for as long as we determine is necessary for the purposes set out in this Privacy Policy, in accordance with applicable law. In addition, we will retain your information as necessary to comply with our contractual obligations, for our legitimate business interests, and to comply with any legal or reporting requirements.
10. Links to Third Party Sites
Our Services may contain links to other websites or applications that are not owned or controlled by us, including websites where you can purchase our products and services. We make no representations about, or endorsements of, any such third-party websites or applications or the parties that control them. Please be aware that Vytalogy is not responsible for the privacy practices of third parties. We encourage you to read the privacy policies of any third parties you interact with to understand their practices. This Privacy Policy applies only to information collected by Vytalogy and to websites and other web properties owned and operated by Vytalogy.
11. Children’s Privacy
The Services are not intended for minors or children under the age of 13, and we do not knowingly collect “personal information” (as defined in the Children’s Online Privacy Protection Act) from such minors or children on the Services. If we discover that an individual under 13 has provided us with personal information via the Services, we will delete the personal information to the extent required bylaw.
12. Changes to this Privacy Policy
We may revise this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, or advances in technology. If we do so, we will update the “Last Updated” date above. You should revisit this page to stay aware of any changes. If we make any material changes to this Privacy Policy, we will post the updated version here and notify users in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy.
13. Contact Information
If you have questions about this Privacy Policy or our privacy practices, you may email us at CAprivacy@vytalogy.com or write to us at 15233 Ventura Blvd., Ste. 900, Sherman Oaks, CA 91403, Attn: Legal Department.
14. Accessibility Statement
We are committed to making sure that our Services are accessible to everyone. To access this Privacy Policy in an alternative form, please submit a request to info@vytalogy.com or call us at (800) 262-8765. For more information, please see our Accessibility Statement for www.vytalogy.com by clicking here, our Accessibility Statement for www.jarrow.com by clicking here, and our Accessibility Statement for www.natrol.com by clicking here.