UCARI

Privacy Policy

Effective Date: January 1, 2021

We at Ucari ("Ucari," "we," "us," or "our") provide this privacy policy ("Privacy Policy") to help inform you about how we collect information, how we use the information, and with whom we disclose such information. This Privacy Policy relates to our online services (the "Services"), which are available to you through a variety of platforms, including our website www.personanutrition.com (the "Website"), mobile application, and other interaction by telephone, e-mail, chat or other media (collectively, the "Platform"). Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

1. The Information We Collect

1.1. Information You Provide to Us

We collect information you provide to us. For example, we collect information when you sign up to become a subscriber, use our chat services, email us, call us, order a gift subscription, or enter a contest, promotion, or sweepstakes. Such information may include your name, e-mail address, date of birth, mailing address, and phone number.

Additionally, when you take our assessment, you may also voluntarily provide us with additional information about yourself such as your hobbies, personal interests, household income range, gender, number of children, and other demographic information. You may also voluntarily provide us with information about your health and diet, and product and service preferences.

1.2 Cookies and Other Tracking Technology

We may use cookies, embedded scripts, and other similar tracking technologies (“Tracking Technologies”) to collect additional personal information automatically as you interact with the Site and to personalize your experience with our Site. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services (known as “behavioral tracking”).

1.2.1 Cookies

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes: to make our Site function properly, to improve our Site and Services, to make login to our Site easier (such as by remembering your User ID), to recognize you when you return to our Site, to track your interaction with the Site, to enhance your experience with the Site and Services, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site. The length of time a cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing).

We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from Ucari. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party's website for more information on how they use cookies. The following types of cookies are used on our Site:

· Strictly Necessary Cookies. These cookies are essential because they enable you to use our Site. For example, strictly necessary cookies allow you to access secure areas on our Site. Without these cookies, some elements of our Site cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they cannot be disabled.

· Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Site.

· Performance or Analytic Cookies. These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site and Services. We do not use these cookies to target you with online marketing. You may choose to disable these cookies.

· Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may choose to disable the use of these cookies as set forth below.

1.2.2 Analytics

We may use third-party Service Providers (defined below) to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

1.2.3 Other Tracking Technologies

We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.

Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

1.2.4 Your Choices

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.

· First-Party Cookies.You can use the browser with which you are viewing the Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Site may not work properly. You can find more information about how to change your browser cookie settings athttp://www.allaboutcookies.org.

· Third-Party Cookies.To opt-out of third-party advertising networks and similar entities that use advertising cookies go tohttp://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please seehttp://www.aboutads.info/consumers.

· Flash Cookies.Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage. Flash cookies are not managed by the same browser settings as are used for browser cookies, but may be managed here:http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

· Targeted Advertising.If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by adjusting your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending an email stating your request to Care@UCARI.com. You can also opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

· Google Chrome

· Internet Explorer

· Mozilla Firefox

· Safari (Desktop)

· Safari (Mobile)

· Android Browser

· Opera (Desktop)

· Opera (Mobile)

1.2.5 Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

1.3. Information from Other Sources

We may receive information from third parties that provide us with information about you from online and offline sources. These third parties may use cookies or other similar technologies. For example, we may use third party web analytics tools to help us provide you with a better experience, determine your interest in our products, and improve the quality of our offerings. Additionally, such third parties may collect and combine your email address with other information they have access to solely so that we may serve relevant marketing offers to you via direct email.

Ucari does not share any personal health information with third parties.

1.3.1. Digital Advertising

We may partner with third party companies that collect data from our Services, as well as from other non-affiliated websites and mobile apps over time in order to infer what interests you to deliver more relevant advertising to your browser or device, as well as browsers and devices associated with it. These partners, however, do not collect or receive information about your responses to assessment questions answered on the Platform for advertising or marketing purposes. This type of advertising is known as interest-based advertising. To learn more about this type of advertising for your browser, and your choices about it for companies that participate in the Digital Advertising Alliance's ("DAA") WebChoices tool, you can visit www.aboutads.info/choices. To learn about your choices about this activity on your mobile device for companies that participate in the DAA's AppChoices you can download the appropriate version of the app from www.youradchoices.com/appchoices.

We adhere to the DAA's Self-Regulatory Principles. When you exercise choice through these tools, data will no longer be collected from that browser or device for interest-based advertising, and data collected from associated browsers or devices will not be used on the browser or device for interest-based advertising on the browser or device where choice was exercised. Note that you will still see advertising, but that advertising may be less relevant to your interests. If you use multiple browsers or devices, clear your cookies, or reset your device identifier, you may need to exercise choice again.

1.4. Payment Information

When you sign up to become a subscriber or order a gift subscription, you provide certain payment information. Such information may include a debit card number, credit card number, and similar information (collectively, the "Billing Information") in order to complete your transaction. Billing Information is collected and processed through third-party vendors pursuant to the terms and conditions of their privacy policies and terms of use.

2. How We Use the Information

We use the information we collect to process transactions; provide you with the Services; solicit your feedback; provide information about our products, Services, or otherwise market to you; inform you about upcoming events, recipes, and special promotions; administer and process contests, promotions, and sweepstakes; analyze use of the Services; improve our Services; or as disclosed at the time of collection.

3. How We Share the Information

We may share your information in the following situations:

· With service providers to provide services such as food services, delivery services, marketing assistance, information technology support, and customer service. These service providers will have access to the information only as necessary to perform their functions and to the extent permitted by law. We do not allow these service providers to share your information with others without our authorization or to use it for their own purposes;

· With our affiliates and subsidiaries;

· Third Party Marketing Vendor for Commercial Purposes

· In the event of a business transaction or sale of all or part of our assets, including at bankruptcy;

· In response to a court order, subpoena, warrant, or as otherwise required to by law;

· To other parties with your consent or as disclosed at the time of collection; and

· To protect our rights and the rights of third parties.

We may also aggregate information together in order to operate, maintain, manage, and improve the Services. We may share this aggregated data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and Services to current and prospective business partners and to other third parties for other lawful purposes.

You may submit a request to opt out of the sale(s) of your personal information through the "Do Not Sell My Info" form

4. Accessing and Modifying Personal Information and Communication Preferences

If you have registered for the Services, you may access, review, and make changes to your Personal Information and Billing Information by following the instructions found on the Platform. 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 Ucari marketing email.

5. Data Security

We take reasonable and appropriate measures to help protect information we collect and maintain from loss and unauthorized access. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

6. Retention of Data

In broad terms, we retain your personal data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of the data and the reason that we have the data.

We have procedures in place regarding our retention periods which we keep under review taking into account our reasons for processing your personal data and the legal basis for doing so.

7. Your GDPR Rights

This section applies to those who live in the European Economic Area, Switzerland, and the United Kingdom that use the Services and Platform.

Ucari, in Tampa, Florida, United States, is the controller of any personal data it may collect, process and hold about you. We process personal information with your consent (e.g. when we process personal information to provide vitamin supplement recommendations), to fulfill a contract, provide you with customer service, or as required by law.

The Platform and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Services and/or providing us with any information, you consent to this transfer.

You have the right to the following:

· To request access to your personal information

· To data portability

· To rectify your personal information

· To object to the processing of your personal information

· To request the erasure of your personal information

· To restrict the processing of your personal information

· To withdraw consent to the processing of your personal information

You can exercise your rights by sending an email to Care@UCARI.com You also have the right to lodge a complaint with your national Data Protection Authority.

8. Children

Our Services and Platform are not directed to, or intended for, individuals under the age of 18 and we do not knowingly collect personal information from individuals under the age of 18. If you are under 18, please do not give us any information. If you believe that we have any such information, please notify us immediately using the contact information provided in Section 14 and we will delete the information as quickly as possible.

9. External Websites

The Platform may contain links to third-party websites. Ucari has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

10. Notice to California Residents - Your California Privacy Rights

This Privacy Notice for California Residents ("CA Privacy Notice") applies solely to visitors, purchasers, users, and others who reside in the State of California ("California Consumers" or "you" or "users"), and who use our Platform, as referenced in the Privacy Policy.

10.1 Personal Information We Collect, Disclose for a Business Purpose, and Sell

In the past twelve months we may have collected, disclosed for a business purpose, and sold, the following categories of personal information about California consumer.

Category and Sources of Information

How We Collect this Information

How We Use the Information

How We Share This Information

Sold to Following Categories of Third Parties

Identifiers such as a real name, alias, date of birth, postal address, unique personal identifier, online identifier, Internet Protocol address, phone number, email address, account name or other similar identifiers

We collect this information from users who voluntarily provide such information when using our Platform, such as when signing up as a subscriber, using our chat services, entering a contest, promotion, or sweepstakes, or otherwise interacting with us. We may collect such information automatically or passively.

We use this information to provide our Services to you, improve user experience, and for data analysis and market research.

We share this information with our service providers.

Our Affiliates and Partners, Our Service Providers, Our Vendors and Our Social Media Partners

Personal information categories listed in the Cal. Civ. Code § 1798.80(e)

We collect this information from users who voluntarily provide such information when using our Platform, such as when signing up for an account, or otherwise interacting with us.

We use this information to provide our Services to you, improve user experience, and for data analysis and market research.

We share this information with our service providers.

Our Service Providers

Protected classifications under California or federal law

We collect this information from users who voluntarily provide such information when using our Platform.

We use this information to provide our Services to you, improve user experience, and for data analysis and market research.

We share this information with our service providers.

Our Social Media Partners

Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

We collect this information from users who voluntarily provide such information when using our Platform.

We use this information to provide our Services to you, improve user experience, and for data analysis and market research.

We share this information with our service providers.

Our Vendors, Our Affiliates and Partners

Biometric information

We collect certain physiological, biological, and behavioral information from users who voluntarily provide information about their health, diet, and lifestyle.

We use this information to provide our Services to you, improve user experience, and for data analysis and market research.

We do not share this information.

N/A

Internet or electronic network activity information (such as website activities and browsing history)

We collect this information from users' browsers using cookies, tags, pixels, heat maps, screen grabs, and other similar technologies.

We use this information to improve user experience, and for data analysis and market research.

We share this information with our service providers.

Our Social Media Partners

Geolocation data

We collect this information from users' IP addresses.

We use this information for data analysis and market research.

We share this information with our services providers.

Our Service Providers

Professional or employment-related information

We collect certain information that users voluntarily provide about their household income range and other demographic information.

We use this information to provide our Services to you, improve user experience, and for data analysis and market research.

We do not share this information.

N/A

Inferences drawn from any of the information above

We only collect this information because users send it to us or are using our Platform.

We use this information to provide Services to you.

We share this information with our service providers.

Our Vendors, Our Affiliates and Partners

10.2 Your Rights as a California Consumer

As a California resident, you have certain rights regarding your personal information, which are described in detail below.

10.2.1 Opting Out of "Sales"

You have the right to opt out of our sale(s) of your personal information.

10.2.2 Your Access Rights

You have the right to request from us the following information: (1) the categories of personal information we have collected about you; (2) the categories of sources from which your personal information is collected; (3) the business or commercial purpose for collecting or selling your personal information; (4) the categories of third parties with whom we share personal information; and (5) the specific pieces of personal information we have collected about you.

To the extent that we used any of your personal information for a business purpose, you have the right to request that we disclose to you: (1) the categories of personal information that we collected about you; (2) the categories of personal information that we sold about you and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold; and (3) the categories of personal information that we disclosed about you for a business purpose.

10.2.3 Your Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete), or will instruct you on how to delete, your personal information from our records, unless an exception applies.

10.2.4 How to Exercise Your Rights

To exercise any of the rights listed above, please submit a verifiable consumer request, which must include your full name, email address, and phone number, by either emailing us at Care@UCARI.com or calling us at 813-472-7747. You are not required to have an account with us in order to submit a request and we will only use personal information provided in a consumer request to verify the requestor's identity or authority to make such a request. Please note you may only make a verifiable consumer request for access twice within a 12-month period. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. If we are unable to comply with a request, we will inform you of the reason why.

10.2.5 Non-Discrimination Policy

California residents that choose to exercise such rights will not be denied any goods or services, charged different prices or rates, or be provided a different level or quality of goods or services unless those differences are related to your personal information.

10.2.6 Shine the Light Disclosure

You may request and obtain from us once year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.

10.2.7 Minors' Right to Opt In

We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

11. Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Platform as soon as they go into effect. By accessing the Platform or using the Services after we make any such changes to this Privacy Policy, you are deemed to have acknowledged such changes. Please refer back to this Privacy Policy on a regular basis.

12. Contact Us

If you have questions or concerns about this Privacy Policy, you can send an e-mail to Care@UCARI.com.

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