Security & Privacy Policy

Welcome to the proshp Website, joliewell.com (the “Website” or “Services”). The Services are operated by joliewell.com. (“we,” “us,” or “our”). We believe that the privacy and security of your information and data (“Information”) is very important. This Privacy Policy (“Policy”) explains the type of Information we collect from users of the Services, how that Information is used, how the Information may be shared with other parties, and what controls our users have regarding their Information. We encourage you to read this Policy carefully.

Any updates or modifications to this Policy will be posted to our website on this page. By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy.

Our Services are operated in China but can be accessed worldwide. If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom, please consult the sections of this Policy relating to the “Rights of EEA Data Subjects” and “International Data Transfers” for provisions that may apply to them.

California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.

INFORMATION WE COLLECT AND HOW WE USE IT

Types of Information

We may collect the following types of Information through our Services:

(1) “Personal Data” such as your name, e-mail address and phone number, account or mailing address, and other information that can be used to directly identify and contact you (which, in some cases, may include certain Device Information or information from the signature block of your e-mail);

(2) “Device Information” which is information relating to the computer or device you are using when you access our Services, such as your computer’s IP address, your mobile device identifiers (including Apple IDFA or an Android Advertising ID), the type of browser and operating system you are using, the identity of your internet service provider, and your device and browser settings.

(3) “Usage Data” which is data related to your use of the Services such as the pages you visit, the sites you use before or after visiting ours, your actions within the Services, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.

As described in more detail below, we collect Personal Data only when you provide it to us but may collect other types of Information whenever you use our Services through automated means such as software developer kits, cookies and web beacons (which are discussed in more detail below).

Personal Data

You may enter the Website and browse its content without submitting any Personal Data. However, we will need to collect relevant Personal Data to provide you with certain services offered by the Services, including if you choose to create an account on our website, contact us or otherwise communicate with us in any way, subscribe or opt in to our newsletter, alerts, or other communications, subscribe or opt in to SMS messages, sign up for product waitlists, participate in a contest or promotion, order our products, submit product reviews, questions, feedback or user comments, complete an optional survey, contact customer service or otherwise interact with the Services.

We use the Personal Data that we collect to respond to your requests, communicate with you regarding the Services and our content, send you promotional or marketing communications, guard against potential fraud, provide product information, service your requests and orders, and provide you with the applicable services, features or functionality associated with your submission. When you submit Personal Data through the Services, whether by directly providing it to us upon request or voluntarily disclosing it through comments, you are giving your consent to the collection, use and disclosure of your Personal Data as set forth in this Privacy Policy.

Device Information & Usage Data

Whether or not you submit Personal Data, any time you visit our Services, we or our service providers may collect, store or accumulate certain Device Information and Usage Data. This Information may be used in furtherance of the purposes described above with respect to Personal Data and in aggregate form for internal business purposes, such as optimizing the Services, evaluating the popularity of content, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.

Information to and from Social Networks

We may provide functionality that will allow you to connect to our Services through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”). If you connect through a Social Network, we may collect Personal Data from your profile, such as your name, username, and e-mail address, and we will use that Personal Data for the purposes set forth herein. In addition, our Services may offer social sharing features which will allow you to “Share” or “Like” on a Social Network. If you decide to use such features, it may allow the sharing and collection of Information both to and from such Social Network, so you should check the privacy policy of each Social Network before using such features.

SHARING OF INFORMATION

In no event will we disclose, rent, sell or share any of your Personal Data to third parties for direct marketing purposes. We only share your Information with third parties for the purposes described below.

We contract with companies or individuals to provide certain services related to the functionality and features of the Services, including content streaming, email and hosting services, software development, data management, orders, payment processing, management of forms, quizzes and polls, customer service, returns, live chat, marketing, fraud prevention, product review and questions, and administration of contests and other promotions. We call them our “Service Providers”. We may share your Information with Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Information only for such purposes.

The server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

In certain instances, as with Paypal, which process payments, you may also be directed to a third-party website which is governed by its own privacy policy:

https://www.paypal.com/us/webapps/mpp/ua/privacy-full

We may also share or transfer Device Information and Usage Data in aggregated, anonymized form with or to our affiliates, licensees, partners and Service Providers for administrative, analytical, research, optimization, and security purposes, but no such Information will be linked with your Personal Data or be used to identify or contact you.

Finally, we may share your Information: (i) In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us; (ii) When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms of Use and other agreements; or (iii) In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

As described above, we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

– Google: https://www.google.com/settings/ads/anonymous

– [[INCLUDE OPT-OUT LINKS FROM WHICHEVER SERVICES BEING USED]]

AUTOMATED DATA COLLECTION / COOKIES

We may use certain automatic analytics and tracking technologies to assist us in performing a variety of functions, including storing your Information, collecting Device Information and Usage Data, understanding your use of the Services and customizing the content offered to you on the Services. We may use platforms like Google Analytics to provide aggregated or anonymized information relating to demographics, geography, interests or affinities. Other technologies we may use include:

(1) Cookies. Cookies are text files placed in your computer’s browser to store your preferences. We use cookies or other tracking technologies to understand site and Internet usage and to improve or customize the Services and the content, offerings, or advertisements you see on the Services. For example, we may use cookies to personalize your experience on the Services or remember any settings you have chosen. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, not accepting cookies may make certain features of the Services unavailable to you.

(2) Web Beacons. We may also use “web beacons” or clear GIFs, or similar technologies, which are small pieces of code placed on a web page or in an email, to monitor the behavior and collect data about the visitors viewing a web page or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

(3) Mobile Device Identifiers and SDKs. We also sometimes use, or partner with publishers or app developer platforms that use, mobile Software Development Kits (“SDKs”) that are incorporated into the Services to collect Information, such as mobile identifiers (e.g., IDFAs and Android Advertising IDs), geolocation information, and other information about your device or use of the Services. A mobile SDK may act as the mobile version of a web beacon (see “Web Beacons” above).

By visiting the Services, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Services through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you. Please note that no such tracking technologies will collect any Personal Data from you unless you choose to submit it to us and that data relating to you individually is not shared with any third parties.

PERSONAL DATA RETENTION

We retain the Personal Data we receive as described in this Privacy Policy for as long as you use the Services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

PRIVACY AND SECURITY

We take reasonable precautions to protect our customers’ Personal Data against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Data, we cannot ensure or warrant the security of any Information that you transmit to us or from us, and you do so at your own risk. You hereby acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.

If you believe your Personal Data is being improperly used by us or any third party, please immediately notify us via email at support@joliewell.com.

USE OF AUTOMATED DECISION MAKING AND PROFILING

Except to the extent personal data is used by third-party ad networks for online behavioral advertising, neither we, nor service providers on our behalf, engage in profiling or automated decisionmaking activities that produce legal and/or similarly significant effects upon you.

CHILDREN UNDER 16

Children under 16 years of age are not permitted to use the Services. We do not knowingly collect or solicit Personal Data directly from anyone under the age of 16. If you are under 13, please do not send any Personal Data about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Data, please contact us at support@joliewell.com.

LINKS TO THIRD PARTY PLATFORMS

Our Services or communications may contain links to third party websites, over which we exercise no control, including the form of embedded content, sponsored content or co-branded content. Except as set forth in this Policy, we do not share your Personal Data with those third parties and are not responsible for the privacy policies of any third party or their management of your Personal Data. Because they may treat your Information differently than we do, we suggest you read the privacy policies on those third-party websites prior to submitting any Personal Data to such sites.

In addition, you may be redirected to a third-party platform for certain functions, including returns, forms, and customer service. See above section regarding “Sharing of Information”.

YOUR RIGHTS

Opting Out of Communications

As described above, we may use the Personal Data we collect from you to send you newsletters or other communications from us, including those promotional or marketing in nature. If you do not want to receive such communications, you can unsubscribe them.

Disallowing Cookies and Location Data Collection

You can opt out of the collection and use of certain information, which we collect about you by automated means, by changing the settings in the device you use to access the Services. In addition, your browser may tell you how to be notified and opt out of receiving certain types of cookies. Please note, however, that without cookies you may not be able to use some or all of the features of the Services.

Your Right to Access, Review, and Delete Personal Data

Under certain laws, including the General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), you may have the right to: obtain confirmation that we hold Personal Data about you, request access to and receive information about the Personal Data we maintain about you, restrict the use of the data, receive the data in a portable format, receive copies of the Personal Data we maintain about you, update and correct inaccuracies in your Personal Data, object to the continued processing or use of your Personal Data, complain to a supervisory authority, and have the Personal Data blocked, anonymized or deleted, as appropriate. The right to access Personal Data may be limited in some circumstances by local law. If you qualify, in order to exercise these rights, please contact us at support@joliewell.com.

We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

Please understand, however, that we reserve the right to retain an archive of such Personal Data for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such Information.

Do Not Track

We use analytics systems and providers and participate in ad networks that process Personal Information about your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. We process or comply with any web browser’s “do not track” signal or similar mechanisms.
Note, however, that you may find information about how to opt out of online behavioral advertising and/or block or reject certain tracking technologies in the section caption “Disallowing Cookies and Location Data Collection” above.

YOUR CALIFORNIA PRIVACY RIGHTS

Last Updated: July 23rd, 2022

This California Privacy Notice (“California Notice”) supplements the Privacy Policy and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). (“proshp”, “we”, “us”, “our”) adopted this California Notice to comply with California privacy laws, including the California Consumer Privacy Act (“CCPA”). Any terms defined in the CCPA and not defined here have the same meaning when used in this California Notice.

NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this notice.

Categories of Personal Information

We collect the following categories of Personal Information:

Identifiers such as a real name, account name, email address, online identifier, internet protocol address, mobile device identifier (including Apple IDFA or an Android Advertising ID), or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e)), such as your name, account or mailing address, phone number, credit card number, and debit card number.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information, such as the pages you visit; the sites you use before or after visiting ours; your actions within the Services; the type of content or advertisements you have accessed, seen, forwarded and/or clicked on; Wi-Fi connections; date and time stamps; log files; and diagnostic, crash, website, and performance logs and reports.
Geolocation data.
Inferences drawn from any of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, and shopping behavior.

We will not collect additional categories of Personal Information other than those categories listed above. If we intend to collect additional categories of Personal Information, we will provide you with a new notice at or before the time of collection.

Use of Personal Information

We collect and process your Personal Information for the following business and commercial purposes:

Responding to your requests, communicating with you regarding the Services and our content, providing product information, servicing your requests and orders, and providing you with the applicable services, features or functionality associated with your submission(s).
Marketing our products and services to you, including sending you promotional or marketing communications, which may include contests, promotions, and special offers for products and services.
For internal business purposes, such as optimizing the Services, evaluating the popularity of content or effectiveness of our marketing campaigns, generating statistics and developing marketing plans, and otherwise for general administrative, analytical, research, optimization, and security purposes.
Understanding your use of the Services and improving or customizing the Services and the content, offerings, or advertisements you see on the Services.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Debugging to identify and repair errors that impair existing intended functionality.
Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law.
As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.

We will not use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.

Sources of Personal Information

We collect Personal Information from the following categories of sources:

From You. For example, if you choose to create an account on our website; contact us or otherwise communicate with us in any way; subscribe or opt in to our newsletter, alerts, or other communications; subscribe or opt in to SMS messages; sign up for product waitlists; participate in a contest or promotion, order our products; submit product reviews, questions, feedback or user comments; complete an optional survey; contact customer service; or otherwise interact with the Services.
From our Service Providers. For example, we contract with companies or individuals to provide certain services related to the functionality and features of the Services, including content streaming; email and hosting services; software development; data management; orders, payment processing; management of forms, quizzes and polls; customer service; returns; live chat; marketing; fraud prevention; product review and questions; and administration of contests and other promotions. See our Security & Privacy Policyfor more information about our services providers.
Operating Systems and Platforms. For example, we automatically collect information relating to the computer or device you are using when you access our Services, such as your computer’s IP address, your mobile device identifiers, the type of browser and operating system you are using, and your device and browser settings.
Data Analytics Providers.For example, we and our technology providers automatically collect data related to your use of the Services through the use of logging and analytics tools (such as Google Analytics), cookies, pixel tags, and other tracking technologies and as a result of your use of and access to the Services, such as the pages you visit, the sites you use before or after visiting ours, your actions within the Services, the type of content or advertisements you have accessed, seen, forwarded and/or clicked on, Wi-Fi connections, date and time stamps, log files, and diagnostic, crash, website, and performance logs and reports.
Advertising Networks. For example, ad networks, such as Google, to serve advertisements across the Internet. These advertisers use cookies, pixel tags, and other tracking technologies to collect information about your online activity and provide online behavioral advertising.
Social Networks. For example, if you connect to our Services through a third-party social network such as Facebook, Twitter or Instagram (each, a “Social Network”), we may collect Personal Information from your profile, such as your name, username, and e-mail address.

Sharing of Personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above.

For example, we use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here:

https://policies.google.com/privacy

You can also opt-out of Google Analytics here:

https://tools.google.com/dlpage/gaoptout

Finally, we may share your Personal Information: (i) in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law; (ii) when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms & Conditions and other agreements; or (iii) in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

YOUR CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to support@joliewell.com, and are free of charge. However, we do not disclose personal information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.

The CCPA provides California residents with the following rights:

Right to Know:You have the right to request that we disclose certain information to you about the Personal Information we collected, used, disclosed, and sold about you in the past 12 months. This includes a request to know any or all of the following:
The categories of Personal Information collected about you;
The categories of sources from which we collected your Personal Information;
The categories of Personal Information that we have sold or disclosed about you for a business purpose;
The categories of third parties to whom your Personal Information was sold or disclosed for a business purpose;
Our business or commercial purpose for collecting or selling your Personal Information; and
The specific pieces of Personal Information we have collected about you.
Data Portability:You have the right to request a copy of Personal Information we have collected and maintained about you in the past 12 months.
Right to Deletion:You have the right to request that we delete the Personal Information we collected from you and maintained, subject to certain exceptions. Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:
Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
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 deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
Comply with a legal obligation.
Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt-In to Financial Incentives:You have the right to opt-in to financial incentives. You also have the right to opt-out at any time. Please see the “Notice of Financial Incentive(s)” section below for more information about the financial incentive(s) and/or price or service difference(s) that we may offer.
Right to Opt-Out/In:You have the right to opt-out of the sale of your Personal Information. You also have the right to opt-in to the sale of Personal Information.
Right to Non-Discrimination:You have the right not to receive discriminatory treatment by us for the exercise of your CCPA privacy rights. Unless permitted by the CCPA, we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Some of our products and services, however, may require your Personal Information. If you choose not to provide your Personal Information that is necessary to provide any aspect of our products or services, you may not be able to use those products or services. In addition, as described in the section captioned “Your Rights” in the Security & Privacy Policy, it is possible to change your browser settings to block the automatic collection of certain information.

III. SUBMITTING A VERIFIED CONSUMER REQUEST

To exercise your Right to Know, Data Portability, and Right to Delete, you must provide us with sufficient information to allow us to verify your identity, and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Once we receive the information you provide to us, we will review it and determine if more information is necessary to verify your identity as required by law, and we may request additional information in order to do so.

To exercise your California privacy rights described above, please submit a verifiable request to us by emailing us at support@joliewell.com.

Only you, or a person authorized by you to act on your behalf, may make a verifiable consumer request related to your Personal Information.

You may only make a verifiable consumer request for Right to Know or Data Portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We will need to verify your identity with at least 2 pieces of information, such as name and email address.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may deny your request if we are unable to verify your identity or have reason to believe that the request is fraudulent.

Consumer Request by an Authorized Agent

If any authorized agent submits a consumer request on your behalf, in order to confirm that person or entity’s authority to act on your behalf and verify the authorized agent’s identity, we require the below items:

To verify your authorization to request on behalf of a California resident, provide one or more of the following: (1) California Secretary of State authorization, (2) written permission from the California resident, or (3) power of attorney.
Sufficient information to verify the authorized agent’s identity, depending on the nature of the request.
To verify the identity of the California resident for whom the request is being made, provide the information set forth above for verification of the consumer request.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the request’s identity or authority to make the request.

We will acknowledge receipt of the request within 10 business days of its receipt. We will respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For Data Portability requests, we will provide the responsive information in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

SALE OF PERSONAL INFORMATION

We do not sell your Personal Information to third parties for money. We do not and will not knowingly sell the Personal Information of minors under the age of 16 without affirmative authorization. We only share your Personal Information for the following business or commercial purposes:

Marketing our products and services to you, including sending you promotional or marketing communications, which may include contests, promotions, and special offers for products and services.
Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions.

However, the CCPA defines “sale” broadly, and that definition could include information that we have shared with certain technology providers that provide certain services to us, including delivering advertisements that we believe may be of interest to you.

Do Not Track

Note, however, that you may find information about how to opt out of online behavioral advertising and/or block or reject certain tracking technologies in our Security & Privacy Policy.

NOTICE OF FINANCIAL INCENTIVE(S)

From time to time, we may offer a financial incentive and/or price or service difference to our customers related to the collection of Personal Information. This Notice of Financial Incentive(s) explains the financial incentives or price or service differences that we may offer, so that you can make an informed decision on whether you would like to participate.

Customers who sign up for our emails may receive a coupon code on their next purchase. You can opt-in to receive this code by providing your email address and/or phone number. You have the right to withdraw your consent to participate at any time and can do so by clicking on the “Unsubscribe” link at the bottom of our marketing communications.

Generally, we do not assign monetary or other value to Personal Information. However, in the event we are required by law to assign such value in the context of financial incentives or price or service differences that we offer, we have valued the Personal Information collected and used as being equal to the value of the discount code or financial incentive offered, and the calculation of the value is based upon a reasonable and good-faith estimate often involving the consideration of (i) the categories of Personal Information collected (e.g., email addresses and phone numbers), (ii) the value of the discount offered, and (iii) the value of the total purchase (excluding taxes and fees). The disclosure of the value described herein is not intended to waive, nor should be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

MODIFICATIONS AND UPDATES TO THIS CALIFORNIA NOTICE

This California Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this California Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised California Notice. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this California Notice, such as by posting a notice on the Services or sending you an email. Your continued use of the Services following our posting of any revised California Notice will constitute your acknowledgement of the amended California Notice.

VII. ADDITIONAL INFORMATION AND ASSISTANCE

If you have any questions or concerns about this California Notice and/or how we process Personal Information, please contact us at support@joliewell.com.

INTERNATIONAL DATA TRANSFERS

If you are located outside the United States, including in the EEA, we transfer Personal Data for processing in the United States, including Personal Information sent via e-mails or when you make an order. Under the GDPR, we are considered a “controller” of the Personal Data of EEA Data Subjects. By using the Services outside the United States, you acknowledge that we will transfer your data to, and store your Personal Data in, the United States, which may have different data protection rules than in your country, and Personal Data may become accessible as permitted by law in the United States, including law enforcement and/or national security authorities in the United States. For transfers of data into and out of the EEA, pursuant to Article 46 of the GDPR, we use standard contractual clauses adopted by the European Commission.

Rights of EEA Residents

This section of the Privacy Policy is applicable to individuals located in the EEA, Switzerland, and the United (“EEA Data Subjects”).

Our purpose for collecting and processing Personal Data from EEA Data Subjects is to provide them with the features and functionalities of our Services and information regarding our Services. The legal basis for processing Personal Data is because it is necessary for performance of a contract between us to provide you with the Services and its related features and functionality and in other circumstances may be necessary for our legitimate interests in making the Services available and secure, or to exercise our rights or comply with legal obligations. We also rely on your consent to receive information about our Services. You may withdraw consent from receiving marketing and promotional communications by clicking the “Unsubscribe” link on the communication or sending an e-mail to support@joliewell.com. If EEA Data Subjects do not provide Personal Data to us or withdraw consent for processing such Personal Data, we may not be able to provide such individuals with certain features or functionalities of the Services or information regarding the Services, including processing orders. Note that we do not collect any sensitive personal information about you.

EEA Data Subjects may obtain information about the Personal Data that we hold about them by contacting us at support@joliewell.com.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Policy at any time. In the event we make changes to this Policy, such policy will be re-posted in the “Privacy” section of our Services with the date such modifications were made indicated on the top of the page. Therefore, please review this Policy from time to time so that you are aware when any changes are made to this Policy. If you have any questions about the changes that were implemented, please contact us at support@joliewell.com and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the Services after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the Services or opt out by sending us an appropriate notice.

GENERAL LEGAL

All other terms governing this Privacy Policy shall be those set forth in our Terms & Conditions which are incorporated herein by this reference.