Prior Privacy Notice
US Health & Wellbeing, LLC PRIVACY PRINCIPLES
US Health & Wellbeing, LLC takes your privacy seriously. The following principles guide our treatment of your personal information:
- 1. We value the trust you place in Unilever when sharing your personal information with us.
- 2. We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.
- 3. We endeavor to work with you to address your concerns about how we use your personal information.
- 4. We strive to take steps designed to secure your personal information and reduce the risk it will be misused.
Last Updated Date: November 23, 2022
When we use the term “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, deidentified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
TYPES OF PERSONAL INFORMATION WE COLLECT
Contact Information. We may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
Payment Information. We may collect your credit card number, related security codes, billing address and credit card status.
Identifiers: Depending on how your interact with us, you may provide us with online identifiers associated with you, such as your Universal ID, social media ID or we may add in an identifier when you visit our Platform or one of our brands.
User Behavior. We may collect information on what buttons or parts of the site you interact with using heat mapping, keystrokes or other similar technology.
Shopping History. We may collect personal information about the items you viewed, added to your cart, purchased, product concerns or returned.
Information You Post. We may collect personal information you post in a public space on our Platform, such as a ratings & reviews feature.
Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.
Information You Submit. We may collect personal information when you send us a message through the “Contact Us” page, raise a customer service issue, event page or similar features on our Platform. We may also collect personal information when you enter a promotion, survey, review or quiz. This may include photos, videos and other user-generated content that you submit.
Demographic Information. We may collect your birthdate, age, gender, ethnicity and zip code. We may also collect personal information relating to your hobbies, eating habits, interests, pet information, family statistics, and shopping behavior.
Device & Network Information. We may collect the type of device you use to access our Platform. For example, we may also collect your device identifier, geolocation, hardware model, network related information, IP address or operating system.
Location Information. We may collect precise location information from your device. This may include information about your exact location when you use our Platform or may include information that allows us to approximate your location. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the “Choices Regarding Your Information” section below.
Log and Analytics Data. If you use our website, we may collect information about the browser you are using. We may look at what site you came from, or what site you visit when you leave us. If you use our app, we may look at how often you use the app and where you downloaded it.
Medical Related Information. If you choose to have a medical consultation or take our tests or surveys, we may receive from you directly certain health related information to better serve you, such as health history, pregnancy wellness information and other related information, other prescriptions or supplements that you may use, dietary habits, sleep habits, and health and wellness habits.
Preferences. You may provide us with information about your personal and household preferences in response to website interactions.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information in the following ways:
Directly From You. For example, when you:
- Register for an account or a subscription.
- Purchase products or services through our Platform.
- Sign up to receive promotional communications either online or offline, such as a trade show.
- Request a sample.
- Join a loyalty, rewards or similar program or club.
- When you consult with one of our specialists, and or choose to send us laboratory samples.
- Participate in one of our promotional sweepstakes, quizzes, offers, contests, surveys, or focus groups.
- Use the ratings & reviews or related services and features.
- Submit a request to our Consumer Service team.
- Interact with our social media pages or other promotional advertising sites.
- Apply for a job through our Platform.
Automatically. For example, when you:
- Install and use any mobile apps, as may be applicable.
- Visit and navigate our Platform on any device.
- Enable location-based features on our Platform.
- Click on sponsored links or ads, third party connections or third-party advertisements, including social media sites.
We may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, beacons, pixels, flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.
From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:
- Our affiliates, business partners, including marketing partners, business partners, medical professionals, third party diagnostic/laboratory providers, analytics vendors, and companies that co-sponsor our promotions.
- Online advertising networks and publishers. We may also receive profile information that online publishers, such as Bing, which includes items such as household status, income, educational information, etc. The information that we receive is dependent upon the online publisher.
- Social media sites, including without limitation, Facebook, Twitter, YouTube, Pinterest, Snapchat, Tik Tok and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.
- Third party sites, including those that allow you to integrate your third-party account with your Unilever account.
- Family, friends and others who provide your personal information to us because they think you may be interested in our products and services or they want to share a product or service with you.
- Companies that provide personal information to supplement what we already know about you, including data analytics firms and data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information.
- Publicly Available Sources, including social media sites and pubic databases.
By Combining Personal Information. For example, we may:
- Combine personal information that we collect offline with personal information we collect through our Platform.
- Combine personal information we collect about you from the different devices you use to access our Platform.
- Combine personal information we get from third parties with personal information we already have about you.
Some of this information may be considered “sensitive” under the laws of certain jurisdictions (“Sensitive Information”). Whether information is Sensitive Information will depend on the laws of your jurisdiction, please refer to our state specific notices.
HOW WE USE YOUR PERSONAL INFORMATION
We may use your personal information in the following ways:
To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions. This could mean responding to a customer service issue.
To Improve Our Products and Services. We may use your personal information to make our Platform, products and services better and for research and development purposes. We may also use your personal information to customize your experience with us.·
To Understand Your Interests. We may use your personal information to better understand your preferences and to make recommendations to you so that we can provide products that interest you and create your own personal profile of these preferences, trends and interests.
To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.
To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our products, services and promotions. For example, this may include verifying your age, date of birth and state of residence. If you apply for a job through our Platform, we may use the personal information you provide to evaluate your application.
For Marketing Purposes. We may provide you with information about new products and special offers. We often use your personal information to serve you ads about products and offers on our website, other third party websites and on social media websites. We might tell you about new features or updates. These might be third-party offers or products or our family of brands products that we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message. We may use your personal information to personalize your experience or providing you more tailored features or ads. We may also use your information for joint promotional offers. We may use this information to create segments and profiles of consumers to better understand your interests, behavior, and preferences for advertising purposes.
For Interest-Based Advertising. We and our third party partners engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Platform or on other sites, services and mobile applications or on other devices you may use. For more information about your choices related to these communications, see the “Online Advertising and Third Party Tracking” section below.
For Security and Infrastructure Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform and establishing business continuity systems and backups.
To Send Push Notifications. If you use our mobile apps, we may send you push notifications about new products or special offers.
As Otherwise Permitted By Law or As We May Notify You.
We may use aggregate and deidentified information to understand how to provide better products to you, improve our products and solutions, improve our advertising and marketing and to other related business purposes:
HOW WE SELL OR SHARE YOUR PERSONAL INFORMATION
We may share your personal information in the following ways:
Internally. We may share your personal information within the Health & Wellbeing Companies and Brands and the Unilever Group of companies and brands.
On our Platform. For example, we may display personal information you post on our Ratings & Reviews feature. We may also display personal information you submit in connection with a promotion.
With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. This may include merchandise, payment processors, fraud and security solution providers, subscription services, shipping, logistics, customer service, cause marketing, technology, loyalty, advertising agencies, marketing and email vendors.
With Our Business Partners. This may include a third party that co-sponsors a contest or promotion. We may also sell or share personal information with data aggregators or brokers, advertisers, media buying agencies, advertising networks and advertising service providers, data analytics providers and business partners who help us offer our products and services.
With Third Parties for Marketing Purposes. This may include our affiliate companies or brands or third parties whose products or services we believe may be of interest to you or social media platforms where you interact or where our ads are displayed. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
For Business Transactions or Reorganizations. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. As we continue to develop our business we may buy other businesses or services. As we bring these new brands and affiliates into our family of companies we may share data with them. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
To Comply With the Law or To Protect Ourselves or Third Parties. This could include responding to a court order or subpoena. It could also include sharing personal information if a government agency or investigatory body requests. We might share personal information when we are investigating potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
We may also share aggregated and deidentified data with social media sites, online advertising companies and marketing and advertising providers for our marketing and advertising programs.
For Other Reasons We May Describe to You.
CHILDREN UNDER 16
Our Platform is intended for adults. We do not knowingly collect or solicit any information from anyone under the age of 16 though our Platform. In the event that we learn that we have inadvertently collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have collected personal information from a child under 16, please contact us at email@example.com.
CHOICES REGARDING YOUR PERSONAL INFORMATION
You can opt out of receiving our marketing communications. Note that you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries. To opt out of receiving our marketing communications, you can contact us as follows:
- Send us an email at firstname.lastname@example.org.
- Call us at 1 (833) BE-WELLY (Monday through Friday, 8:30 AM – 9:00 PM Eastern)
- Send us a letter at:
Welly Health PBC
1600 Utica Ave., Suite 900
St. Louis Park, MN 55416
- For promotional emails or text messages, follow the unsubscribe or STOP instructions included with the marketing communication.
Mobile Application and Location Based Services:
- You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.
- You may completely opt out of all location-based information collection by us if you uninstall all of our mobile apps from your devices.
ONLINE ADVERTISING AND THIRD-PARTY TRACKING
Cookies & Other Tracking Technologies:
We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Platform and your user experience.
You can turn off Advertising and Analytics tracking tools through the AdChoices link on the bottom on our Platform. In addition, your browser may give you the ability to control cookies or other tracking technologies, or to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.
Some browsers allow you to opt out on online tracking which may be considered a sale or sharing of your personal information. You have the right to submit a request to opt out of the selling and sharing of personal information through an global opt out preference signal. If you use an opt out preference signal we will apply that opt out to that device and browser. At this time we do not respond Do Not Track and other browser based signals.
If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.
We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. We permit third party online advertising networks, social media companies, and other third party services to collect information about your use of our websites, including shopping behavior and purchase behavior, and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices or serve you ads on social media or other sites you may use. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
To learn more about interest-based advertising and how you may be able to opt out of the use of your personal information for interest-based advertising purposes, you may visit the bottom of a Unilever brand homepage that links to this Notice and clicking on “AdChoices” at the bottom of the page, you will be taken to a tool which will allow you to opt out of certain online advertising and tracking activities.
Please note, however, that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, the options you select relating to interest-based advertising are browser and device specific. If you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.
You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt out of interest-based ads" (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Google Analytics and Advertising:
We use Google Analytics to better understand how our users interact with our Platform and such data is shared with Google. For information on how Google Analytics collects, uses and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Marketing 360 Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:
- California. If you are a California resident, please click here for additional specific privacy disclosures.
- Nevada. Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at email@example.com with the subject line “Nevada opt-out”.
SECURITY AND RETENTION OF DATA
The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us via the Platform. We have, however, taken reasonable security measures to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. We encourage you to use caution when using the Internet. A user id and a password are needed to access certain areas of the Platform. It is your responsibility to protect your username and password.
We retain your Personal Information for as long as it is reasonably necessary to fulfill the business purposes for which the Personal Information was collected and received. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.
STORAGE OF INFORMATION
Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.
LINKS TO THIRD-PARTY SERVICES
Our Platform may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Policy. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.
HOW TO CONTACT US
If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at firstname.lastname@example.org or by telephone at 1 (833) 239-3559 (Monday through Friday, 8:30 AM – 9:00 PM Eastern). You may also write to us at the following address:
Welly Health PBC
1600 Utica Ave., Suite 900
St. Louis Park, MN 55416
CHANGES IN POLICY
From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy of this Policy on our Platform. Please check our Platform periodically for updates.