Privacy Policy

Topsiders Marketing, Inc.: “We”, “us” or “our”
WellBeingNNow101.com: the “Website”

Our Privacy Policy was last updated on 11 October 2022.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you access or use the Website. By accessing or using the Website (including but not limited to purchase any products or services marketed through the Website), you agree to the collection and use of such information in accordance with this Privacy Policy. Should you have any questions about our Privacy Policy, you may email us at support@wellbeingnnow101.com.

Definitions

For purposes of this Privacy Policy, the following words will have the following definitions regardless of whether they appear in singular or in plural:

1. “You” means the individual accessing or using the Website.
2. “Account” means a unique account created by you to use our Website.
3. “Consumer” means a natural person who is in the USA for other than a temporary or transitory purpose, or who is domiciled in, but outside of, the USA for a temporary or transitory purpose.
4. “Cookies” refers to small electronic files that are placed on your Device containing the details of your browsing history on that website among its many uses.
5. “Device” means any device that can access the Website as a computer, a cell phone or a digital tablet.
6. “Personal Data” refers to any information that identifies, relates to, describes or is capable of being associated with, or reasonably could be linked with you, directly or indirectly.
7. “Sale” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
8. “Service Provider” means any natural or legal person who processes the data on our behalf, or whom we employ to facilitate the Website, perform services related to the Website, assist us in analyzing how the Website is used, provide the Website on our behalf, or process payments for the purchase of products and services via the Website.
9. “Usage Data” refers to data collected automatically, either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
10. “Web Beacons” refer to small electronic files that permit the Company, 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 a certain section and verifying system and server integrity).

Personal Data Collection and Use

We may ask you to provide us with certain personally identifiable information to contact or identify you as a condition to your use of the Website. Personally identifiable information may include, but is not limited to you email address, first and last name, telephone number, and physical address (including city, state and zip code) information.

We automatically collect certain Usage Data when you use the Website. Examples may include information such as your Device’s IP address, operating system, browser type, browser version, unique device identifiers, the time and date of your visit, what pages you visit, and how long you spend visiting those pages, and other information that your browser sends when you access the Website.

Cookies and Tracking

We use Cookies and similar tracking technologies (e.g. beacons, tags, and scripts) to track activity on our Website and store certain information, which we may use to improve the quality of our Website and our services, and for analytical purposes.

We may administer two types of Cookies: “Session Cookies,” which are deleted as soon as you close your browser; and “Persistent Cookies,” which remain on your Device when you go offline.

Session Cookies are necessary to our ability to provide you with the services available through the Website. We administer these Cookies for the purpose of authenticating users and protecting their accounts.

We administer certain Persistent Cookies to confirm that a user has accepted the use of Cookies on the Website, and to remember your login details, language preferences and other choices you make when you use the Website. Our third party Service Providers may also administer Persistent Cookies to track information about use of and traffic to the Website.

Personal Data Use, Retention, Transfer, Disclosure, Processing, and Security

We may use your Personal Data to: operate our Website, manage your Account, fulfill your order(s) for our products and services, manage your requests, contact you, and/or provide you with news and special offers. We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Website, products, services, marketing and your experience. We may share your personal information with our Service Providers, affiliates, and business partners for routine business purposes, including analytics, payment processing, and marketing. With your consent, we may also disclose your personal information for other purposes.

We may retain and use your Personal Data and Usage Data for as long as necessary to accomplish the purposes described herein. For Personal Data, such purposes include legal compliance, dispute resolution, and enforcement of our legal agreements and policies; and for Usage Data, such purposes include internal analysis, legal compliance, and enhancing the functionality and security of our Website.

We may process your information, including your Personal Data, at our offices and/or in any other place where our third party processing partners are located. As a result, we may transfer and maintain your information on computers located in different jurisdictions where the data protection laws may differ from the state and/or country in which you reside. We will act in a commercially reasonable manner to ensure that your data is treated securely and in accordance with this Privacy Policy, and prevent the transfer of your Personal Data to another organization or country unless there are adequate controls in place to protect the security of your data and other personal information. By agreeing to this Privacy Policy, you consent to the transfer of such information.

Upon prior written notice, we may disclose your Personal Data to accomplish a corporate merger, acquisition or asset sale. We may also disclose your Personal Data in response to valid requests by public authorities (i.e. government agency or court order) or if otherwise required by law. Finally, we may disclose your Personal Data if we believe in good faith that such action is necessary to protect and defend our rights and/or prevent or investigate possible wrongdoing related to the Website.

We may use third-party Service Providers to monitor and analyze the use of our Website. Toward that end, they may have access to your Personal Data to collect, store, use, process and transfer information about your activity on our Website in accordance with their own Privacy Policies. We may also use third-party Service Providers to process payments flowing from your purchase of our products or services via the Website. In the event of a purchase, your payment information will be provided directly to our payment processing partners, who are bound by PCI-DSS standards to ensure the secure handling of your payment information. We will never store or collect your payment card details. Finally, we may use your Personal Data to send you special offers, newsletters and marketing materials. You may opt-out of receiving any, or all, of these communications from us at anytime by emailing us or using the unsubscribe link contained in any such email.

We will always employ commercially reasonable means to protect your Personal Data. However, we cannot guarantee its absolute security against cyber attacks and hackers.

California Consumer Privacy Act (“CCPA”) Privacy Policy

This section supplements the information contained in Our Privacy Policy for all California residents who visit, access or use our Website.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device.

We may collect, or within the past 12 months may have collected, the following categories of information from California residents. The categories and examples listed below track the CCPA. This does not mean that we have in fact collected all examples of personal information provided in each category, but reflects our good faith belief that we may have collected, or may in the future collect, at least some of these examples from some of these categories.

1. Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.Collected: Yes.
2. Customer records information: Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information.Collected: Yes.
3. Characteristics of protected classifications under California or federal law: Race, religion, sexual orientation, gender identity, gender expression, age.Collected: No.
4. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Collected: Yes.
5. Biometric information: Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data.Collected: No.
6. Internet or other electronic network activity information: Browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.Collected: Yes.
7. Geo-location data.Collected: Yes.
8. Audio, electronic, visual, thermal, olfactory, or similar information.Collected: No.
9. Professional or employment-related information.Collected: No.
10. Education information: Information that is not “publicly available personally identifiable information” as defined in the California Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).Collected: No.

The CCPA excludes the following categories from its definition of personal information: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) information excluded from the CCPA’s scope, such as (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or (ii) personal Information covered by certain sector-specific privacy laws, including the Fair Credit reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Personal Information Sources

We may collect the aforementioned categories of personal information from: (a) forms you complete, preferences you express, or purchases you make on our Website; (b) observing your activity on our Website; (c) Cookies set on your Device by us or our Service Providers as you navigate our Website; and/or (d) our third party Service Providers (e.g. providers of analytics or payment processing).

Use and Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose your personal information for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include: (a) operating, monitoring and improving our Website; (b) responding to your inquiries and providing you support; (c) fulfilling the purpose for which you provided the information; (d) responding to law enforcement requests and complying with applicable laws, court orders, or governmental regulations; (e) performing internal administrative tasks and audits; (f) detecting and preventing security incidents; and (f) any other purpose described by us to you when collecting your personal information, or as otherwise set forth in the CCPA. We will update this Privacy Policy if we decide to collect additional categories of personal information, or use it for materially different, unrelated, or incompatible purposes.

We may use or disclose, or may in the last twelve months have used or disclosed, the following categories of personal information for business or commercial purposes, as defined in the CCPA: (a) Identifiers; (b) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (c) Commercial information; or (d) Internet or other similar network activity. Reference to these categories reflects our good faith belief that we may have disclosed, or may in the future disclose, at least some portions of personal information from these categories for a business or commercial purpose. But, if we do, we will only do so pursuant to a written contract that requires the recipient to keep that personal information confidential, and to refrain from using it for any purpose other than to perform the express purpose described in the contract.

Sale and Sharing of Personal Information

The CCPA defines the terms “sell” and “sale” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for “valuable consideration” (i.e. money or some other type of benefit).

We may sell, or may in the last twelve months have sold, the following categories of personal information for business or commercial purposes, as defined in the CCPA: (a) Identifiers; (b) Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)); (c) Commercial information; or (d) Internet or other similar network activity. Reference to these categories reflects our good faith belief that we may have sold, or may in the future sell, at least some portions of personal information from these categories for valuable consideration.

We may share this personal information with our: (a) Service Providers; (b) affiliates; (c) business partners; and/or (d) third party vendors as authorized by you in connection with products or services you purchase via the Website.

Minors Under 16 Years of Age

You must be at least 18 years old to visit, access or use our Website. We do not knowingly allow minors to use the Website, collect their personal information, or sell their personal information. We have no control over third party websites even if their links appear on our Website. Such third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission. If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

1. The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
2. The right to request. You have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes, and sharing of personal information. Once we receive and confirm your request, we will disclose to you: (a) the categories of your personal information we collected; (b) the categories of sources from which we collected your personal information; (c) our business or commercial purpose for collecting or selling your personal information; (d) the categories of third parties with whom we shared your personal information; (e) the specific pieces of personal information we collected about you; and (f) if we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you the categories of your personal information that we sold or disclosed.
3. The right to Opt-Out from the sale of your Personal Data. You have the right to direct us to not sell your personal information. Please contact us to submit an Opt-Out request.
4. The right to delete your Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to: (a) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (e) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (f) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (g) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (h) comply with a legal obligation; and/or (i) make other lawful, internal use of that information compatible with the context in which you provided it.
5. The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your rights as a consumer. That means we cannot discriminate against your by (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting that you will receive a different price or rate for, or a different level or quality of, goods or services.

Exercising Your CCPA Data Protection Rights

If you are a California resident, you may exercise your CCPA data protection rights by sending us an email at support@wellbeingnnow101.com, or contacting us via the Website at WellBeingNNow101.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. Your request must (1) provide us with sufficient information to reasonably verify you are either the person about whom we collected personal information, or his/her authorized representative; and (2) include sufficient detail to enable us to understand, evaluate, and meaningfully respond. Our ability to respond to your request is contingent upon its compliance with both requirements. We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended one time by an additional 45 days upon prior notice if reasonably necessary to our ability to respond. Any disclosure by us will cover only the 12-month period preceding your verifiable request. We will select a readily usable format for our response that should allow you to easily transmit the information from one entity to another for data portability purposes.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of your personal information. To exercise this right, send us an email at support@wellbeingnnow101.com, or contact us via the Website at WellBeingNNow101.com. We will immediately refrain from any sale of your personal information upon receipt of a verifiable consumer request from you. Our Service Providers may use technology on the Website that “sells” personal information within the meaning of the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising and other potential “sales” activity within the meaning of the CCPA, you may do so by following the instructions below. Please note that any opt out is specific to your browser so you may need to opt out separately for each browser you use.

First, you may opt out of receiving personalized ads by following the opt-out procedures prescribed by the following links:

• The NAI’s opt-out platform: http://www.networkadvertising.org/choices/
• The EDAA’s opt-out platform http://www.youronlinechoices.com/
• The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

The opt-out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again.

You may also opt out of from allowing the sharing of usage information about the apps you use on your mobile device in order to serve you ads that are targeted to your interests: “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices, or “Limit Ad Tracking” on iOS devices. You may also change the preferences on your mobile device to block the collection of location information.

Children’s Privacy

People under the age of 18 are prohibited from using our Website. Accordingly, we will never knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will remove that information from our servers. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information.

Links to Other Websites

Our Website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to a third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We may also email you and/or place a prominent notice on our Website to notify you of such changes before they become effective. We recommend that you review this Privacy Policy periodically for changes, all of which become effective when they are posted on this page.

Contact Us

Please contact us via email at support@wellbeingnnow101.com, or via the Website at WellBeingNNow101.com, if you have any questions about our Privacy Policy.