I. WHO MAY USE THE WEBSITES
II. INFORMATION COLLECTION
Savvy Wellness is the sole owner of the Website, including Replicated Websites. We collect information from Independent Distributors (“Distributors”), Customers and visitors to the websites at different points on the websites.
A. Traffic Data. Like most website operators, Savvy Wellness automatically gathers information of the sort that browsers automatically make available, including: (i) IP addresses; (ii) domain servers; (iii) types of devices accessing the Website; and (iv) types of Web browsers accessing the Website (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you.
We also use the following tools:
❖ Google Analytics – This is a web analytics tool by Google Inc., 1600 Amphitheatre Parkway Mountain View, California 94043, United States, hereinafter referred to as “Google”, to record your online activities on our site and to determine how many users are visiting us, what contents of our page are viewed, and how many times. The evaluation is done anonymously. Google Analytics cookies, including the Google Analytics tool “anonymous IP address” and usage data, are usually transmitted to a Google server in the United States and stored there. For further information, please refer to https://support.google.com/analytics/answer/6004245?hl=de. At https://tools.google.com/dlpage/gaoptout?hl=de. Google Analytics offers the option to opt out of data collection.
❖ Piwik Open Analytics Platform – This allows us to record your online activities on our site and determine how many users visit us on the Internet, which content of our site is viewed, and how often. The evaluation is done anonymously. The cookies are stored on your computer. For additional information, please refer to https://piwik.org/faq/.
❖ Google AdWords– This is used to record website visits for advertising purposes (remarketing) in Google and in the Display Network. When you visit a website, your browser saves cookies that allow you to be recognized as a visitor when you visit websites that belong to Google’s advertising network. On these pages, ads that relate to content that you previously viewed on other websites that use Google’s remarketing function can be presented to you as a visitor. You can opt out of data collection by Google AdWords on the website http://www.google.com/settings/ads
❖ Salesforce Marketing Cloud– We use this to record your behavior on our website to optimize our product offering. It helps us determine how many users visit us in the Internet, which content of our site is viewed, and how often. The evaluation is done anonymously and is used automatically by predictive intelligence to improve the presentation of our product offering. For registered members, the user-related behavior on the website is recorded to improve the user experience and is used to display the relevant content. Salesforce cookies are usually delivered to a Salesforce server in the United States and stored there.
❖ Hotjar – We collect non-personal information, including standard internet log information and details of your behavioral patterns when you visit our website. This is done to enable to provide you with a better user experience, to identify preferences, to diagnose technical problems, to analyze trends and to improve our website. The following information may be collected related to your device and browser: device’s IP address (captured and stored in an anonymized form), device screen resolution, device type (unique device identifiers), operating system, and browser type, geographic location (country only), preferred language used to display our website. The following information is collected related to your user interaction: mouse events (movements, location and clicks), keypresses. For a sampling of visitors, Hotjar also records information which is collected from our website: referring URL and domain, pages visited, geographic location (country only), preferred language used to display our website, date and time when the website pages were accessed. By visiting the opt-out page https://www.hotjar.com/opt-out and clicking on “Disable Hotjar” you can at any time refuse to collect your data from Hotjar when you visit our website. You may opt-out from having Hotjar collect your information when visiting our website at any time by visiting the Opt-out page https://www.hotjar.com/opt-out and clicking “Disable Hotjar”.
❖ Facebook Pixel — With your consent, we use the “Facebook Pixel” by Facebook Inc., 1601 South California Avenue, Palo Alto, California 94304, United States (“Facebook”) on our website. This is a cookie (i.e., a small text file that is stored on your computer and can be accessed again later). With its help, actions of users can be tracked after they have seen or clicked on a Facebook ad. This allows us to track the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, in other words, it does not provide any information on the identity of the users. However, the data is stored and processed by Facebook, so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes, according to the Facebook Data Policy (https://www.facebook.com/about/privacy/). You can allow Facebook and its partners to display ads on and off Facebook. A cookie may also be stored on your computer for these purposes. By using the website, you agree to the use of the visitor action pixel.
C. Personal Information. Through your use of or visits to our websites, you may be required or requested to provide personally identifiable information (hereafter “Personal Information”) to us. Personal Information is any piece of information which can potentially be used to uniquely identify, contact, or locate a single person. Such information includes, without limitation: (1) “Contact Data” (such as your name, membership number, title, gender, date of birth, mailing address, address coordinates (longitude and latitude), phone number(s), fax number, and e-mail address); (2) “Demographic Data” (such as your age, gender, profession, education level, relationship status, religious affiliation, country, state, city and likes and dislikes,); (3) “Financial Data” (such as your credit/debit card number and expiration date); and (4) “Shopping Preferences” (such as items purchased, purchase date, place of purchase, time of purchase, purchase amount, currency and shopping cart). For certain transactions, we may be required to collect information to comply with legal requirements. In each case, you will be asked to provide Personal Information; the Website will not gather it surreptitiously. Savvy Wellness may supplement the Personal Information you provide with additional personal information gathered from public sources or from third-parties (e.g., consumer reporting agencies) who may lawfully provide such information to Savvy Wellness. You are under no obligation to provide Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the features and services available on the Website or from purchasing any of our products.
E. Distributor and Customer Registration. In order to become a Distributor, an applicant must provide Personal Information to us. We also may require an applicant’s Social Security Number or Federal Tax ID Number so that we may prepare and file necessary non-employee compensation forms for the IRS. Certain customers may be required to register in order to purchase products directly from us. Customers will be required to provide Personal Information. We use this information to maintain contact with Distributors and Customers, and to process Distributor and Customer orders.
F. Product or Service Purchases. When a Customer or Distributor purchases products or services from us through any of our websites, the purchaser must provide us with Personal Information. This information is used for billing and payment purposes and to fill orders.
G. Information that you make Public. The Website may contains features (e.g. public profiles, forums, and message boards) that permit you to upload, post, transmit, display, perform or distribute content, information or other material, including some of your Personal Information. Any information that you choose to disclose by means of such features becomes public information over which Savvy Wellness is unable to exercise control. You should exercise caution when deciding to disclose your Personal Information by means of such features, and you agree to assume all responsibility for doing so.
III. INFORMATION USE AND DISCLOSURE PRACTICES
❖ allowing you to enter your password less frequently;
❖ remembering your preferences;
❖ presenting information that is targeted to your interests;
❖ measuring the effectiveness of our sites, services, content, and advertising; and
Savvy Wellness analyzes Traffic Data and information gathered using Cookies to help Savvy Wellness better understand who is using the Website and how they are using it. By identifying patterns and trends in usage, Savvy Wellness is able to better design the Website to improve your experience, and to serve you more relevant and interesting content. From time to time, Savvy Wellness may release Traffic Data and information gathered using Cookies in the aggregate, such as by publishing a report on trends in the usage of the Website. Savvy Wellness does not attempt to link information gathered using Cookies to Personal Information.
B. Web Beacons. We may also use web beacons. A “web beacon” is an electronic image placed in the code of a web page. Beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our website and other sites were effective. We use web beacons to monitor the traffic patterns of users from one page to another and to improve site performance.
- Disclosure in Connection with Services. Some of our operations, such as our electronic commerce, may be managed by Service Providers who are unaffiliated companies. These companies may share Personal Information with their affiliates and service providers whom they engage to perform services related to our Websites or the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, Website hosting and evaluation, data storage, analysis, or security and, where applicable, data cleansing. These companies may have access to your Personal Information on a confidential basis only to the extent necessary to perform their functions. In no event will we authorize these companies to use your Personal Information for any reason other than to provide you with those specific services. If your purchases are being shipped to you, your shipping information will be shared with our delivery service providers (U.S. Postal Service, UPS, FedEx, or other delivery companies we or you select). Our delivery service providers are asked not to use your Personal Information for any purpose other than making the delivery.
- The website contains “Share” buttons for the social networks Twitter Inc., 795 Folsom St., Suite 600, San Francisco, California 94107, United States, XING, which is operated by XING AG, Dammtorstrasse 30, 20354 Hamburg, Germany, LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, United States, Facebook, 1601 South California Avenue, Palo Alto, California 94304, United States, and GooglePlus of the social network Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, United States. In addition, there is also a “Share” button for e-mail. The “Share” buttons can be recognized by their respective logos. All “Share” buttons are set up in compliance with data protection requirements. A direct connection between your browser and the server of the operator of the respective social network is established only when you click on the respective “Share” button on this website (and only then). According to the operators of the social networks mentioned, no personal data is collected by the social networks without a click on the respective “Share” button. Only data of logged-in Distributors and Customers, , including the IP address, is collected and processed. If you do not wish to associate your visit to our website with your user account of the respective social network, please log out of the user account of that social network. We do not receive any information regarding the content of the data transmitted and its use by the social networks. For more information about the use of data by the social media networks, please refer to the privacy policies of the social networks mentioned.
- By Law or to Protect Rights. Savvy Wellness discloses Personal Information when required to do so by law, or in response to a subpoena or court order, or when Savvy Wellness believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of Savvy Wellness, third parties, or the public at large.
- Legally Required Law Enforcement, Judicial and Administrative Agency Disclosures. Savvy Wellness will provide confidential and personally identifiable information as necessary to comply with judicial and administrative orders, subpoenas, Civil or Criminal Investigative Demands, Administrative and Regulatory Demands and other legal obligations. In order for Savvy Wellness to conduct business in certain jurisdictions, Savvy Wellness must disclose certain personally identifiable and confidential information to regulatory authorities in such jurisdictions. Such information may include, but is not limited to, income information and personally identifiable information.
- Unpaid Accounts. If you fail to pay any balance owed in consideration of Services, Savvy Wellness may, as permitted by law, report your Personal Information, including without limitation your unpaid balance, to consumer credit reporting services, collection agencies and others.
- Invite a Friend. When you invite family or friends to join the Savvy Wellness network or to attend a Savvy Wellness home party, Savvy Wellness will send an email on your behalf to the indicated recipient. Your name and email address will appear in the “From” line of such email.
- To help Distributors in Savvy Wellness’s network marketing program manage their independent businesses, we provide your Savvy Wellness sponsor and other upline Savvy Wellness Distributors with your name, rank, address, telephone number, and email address as well as data relating to your sales and recruitment activity through the Back-Office to the Website. We also provide downline Distributors with the names, rank, address, telephone number, and email address of their sponsor and certain specified upline Distributors.
VI. COMMUNICATIONS FROM US
A. Special Offers and Updates. By enrolling as a Distributor, registering as Customer, or making a purchase or other inquiry through the Website, you consent to receive periodic email and other communications from us and from Savvy Wellness Distributors. For example, Savvy Wellness sends all new Distributors and Customers a welcoming email to verify password, username, and acceptance of the Distributor Agreement. All Distributors and Customers will occasionally receive information on products, services, special deals, and a newsletter.
B. Service Announcements. On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send Distributors and/or Customers an email. Generally, Distributors may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.
C. Distributor and Customer Service. Savvy Wellness communicates with Distributors and Customers via email, regular mail and telephone on a regular basis to provide requested services and in regards to issues relating to their Savvy Wellness business. Savvy Wellness communicates with other Customers with respect to products or services purchased by such Customers from Savvy Wellness. Such communications may be by email, regular mail, or telephone.
D. Privacy Preferences/Opt-Out. We now offer an on-line preference page located within the My Account section on www.savvywellness.com where you can register and change your preferences to receive or not receive marketing materials. You may also update what product/lifestyle preferences you prefer, which may determine what offers and promotional materials you may receive. You may update these preferences at any time, but you must first register by creating an account before you can update any of your preferences. Please allow sufficient time for your preferences to be processed. You may also change your marketing preferences or remove yourself from our mailing list by clicking on an “unsubscribe” hyperlink contained in promotional emails we send you or by contacting us at: Savvy Wellness, Attn: Privacy Manager, 7334 Topanga Canyon Boulevard, Suite 115, Canoga Park, California91303, or by e-mailing us at email@example.com.
A. Links. Savvy Wellness’s websites may contain links to other sites. Please be aware that Savvy Wellness is not responsible for the privacy practices of such other sites. We encourage users to be aware when they leave our site and to read the privacy statements of each and every website that collects Personal Information. This privacy statement applies solely to information collected by Savvy Wellness websites.
B. Text Messaging. If you so elect, you may provide your mobile phone number to Savvy Wellness. By submitting your mobile phone number, you consent to receive text message alerts from Savvy Wellness containing product and event information, product tips or promotions that may be sent using automated dialing systems (“Text Messages”). Your consent to receive Text Messages is not otherwise required to purchase any goods or services from us. You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number. You agree to enter into, sign and receive your consent to receive Text Messages electronically.
You may receive approximately (six) recurring texts per month. We do not charge a fee for you to receive Text Messages from us, however, your mobile service provider may charge you for sending and/or receiving text messages and air-time, as well as any other standard applicable rates charged by your mobile service provider. Participating Carriers are:
|ACS Wireless||Cox Wireless||Pocket Wireless|
|Alltel||Cricket Communications||Revol Wireless|
|All West Communications||Element Mobile||Silver Star PCS|
|Appalachian Wireless||Farmers Mutual Telephone Co.||Simmetry Wireless|
|AT&T||GCI Wireless||Snake River PCS|
|Bluegrass Wireless||Golden State Cellular||South Central Communications|
|Boost||Illinois Valley Cellular||Sprint|
|Boost Unlimited||Immix||Sprocket Wireless|
|Breakaway Wireless||Inland Cellular||Strata Networks|
|Carolina West Wireless||iWireless||Syringa Wireless|
|Cambridge Telephone Company (CTC)||Metro PCS||Thumb Cellular|
|Cellular South||Nex-Tech Wireless||United Wireless|
|Cellular One of East Central Illinois||Nextel||Union Wireless|
|Cellular One of Montana||Northwest Missouri Cellular||U.S. Cellular|
|Cellular One of NEPA||nTelos||Verizon Wireless|
|Centennial Wireless||Nucla-Naturita Telephone Co.||Viaero Wireless|
|Chat Mobility||Panhandle Telecommunications||Virgin Mobile US|
|Cellular 29||Pioneer Cellular||West Central Wireless|
|Cincinnati Bell||Plateau Wireless|
Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery or guarantee availability or performance of this service, including liability for transmission delays or message failures. To receive help with Text Messages, you can either text the word “Help” to SAVVY or call 818-975-084 or email firstname.lastname@example.org.
You may unsubscribe from receiving Savvy Wellness Text Messages any time by texting the word “STOP” to SAVVY from your device. You may also choose not to receive Text Messages by emailing email@example.com and specifying that this is your preference.
From time to time you may be asked to provide your mobile phone number to Savvy Wellness in connection with specific text messaging programs, which is in addition to the general Savvy Wellness marketing text messaging program. That text messaging program may have additional or different terms and conditions from those set forth above, which will be presented you at the time that you opt-in to receive those text messages. In general, in order to stop receiving text messages from a specific Savvy Wellness text messaging program, you can text STOP to the five digit short code for the text messaging program from which you no longer wish to receive message (i.e., the five digit number from which its text messages are being sent). You will then receive confirmation of your opt-out of that text messaging program. This will only opt you out of the specific text messaging program associated with that five digit short code. You will remain opted in to any other Savvy Wellness text messaging programs that you have signed up for.
C. Security of Personal Information. We maintain administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control. We also are committed to employing reasonable technology in order to protect the security of our Websites. However, even with the best technology, no website is 100% secure. We will take reasonable measures which we believe are appropriate to protect your Personal Information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer such information to take comparable steps to protect that security.
D. Secure Shopping. When you place orders on our Websites, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our Websites from capturing and viewing your Personal Information. Since any order information you provide to us on our Websites will be transmitted using a secure connection, if your Web browser cannot support this level of security, you will not be able to order products through our Websites. The most recent versions of Google Chrome, Netscape Navigator, Apple Safari, and Microsoft Internet Explorer can support a secure connection and can be downloaded for free from the Google, Netscape, Apple, or Microsoft website respectively.
E. Password. To provide you with an increased level of security, online access to your Personal Information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. Savvy Wellness will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or e-mail messages).
F. Lost or Stolen Information. You must promptly notify us if your credit, banking, other financial information, user name or password is lost, stolen or used without permission. In such an event, we will remove that credit card number, bank account information, other financial institution information, user name or password from your account.
I. Making Changes to Your Personal Information. Distributors and Customers may update their personal information as necessary by logging into their Savvy Wellness online Back Offices or Customer Accounts, which allows them to access and edit their registration account information. In addition, Distributors and Customers may contact us at firstname.lastname@example.org to update their profiles.
J. Information Sharing Disclosure Requests. If you are a California resident, you have the right to request one Notice of Information-Sharing Disclosure per year which will identify the third parties with whom Savvy Wellness or any of our affiliates has shared the Personal Information we have collected from you. You may request the Notice of Information-Sharing Disclosure by writing to us at. Savvy Wellness, Attn: Privacy Manager, 7334 Topanga Canyon Boulevard, Suite 115, Canoga Park, California91303, or by e-mailing us at email@example.com. We will respond to your request for a Notice of Information-Sharing Disclosure within 30 days.