PRIVACY POLICY

Effective Date: 05/01/19
Last Updated: 4/16/19

Vernon Health LLC (the “Company”) is a New York, USA, limited liability company with offices in New York City. We have adopted this Privacy Policy to make it easy for you to understand what sorts of information the Company collects and how we use that information. Please read this Privacy Policy carefully prior to using this website, our mobile applications, and/or submitting information through this website, our social-media channels, and our mobile applications (collectively, the “Services”). If you do not consent to the practices detailed in this Privacy Policy, you should not use the Services.

Scope

The Company provides subscription-based herbal supplement delivery services via web and mobile applications. This Privacy Policy discloses information that we collect and use when you use the Services. By providing information through this Services, you acknowledge that such information is governed by this Privacy Policy.

Please note that this Privacy Policy can only disclose what we do with the data we collect and use. We can’t guarantee that this Privacy Policy discloses every possible way that data is used by service providers who have custody of your information, though we use commercially reasonable efforts to ensure that our service providers use your information in accordance with this Privacy Policy.

For purposes of this Privacy Policy, we will refer to the following types of data:

  • Personal Data,” which refers to information that can be used to identify you, directly or indirectly; and

  • Anonymous Data,” which refers to information that cannot be used to identify you.

Information We Collect & How We Collect It

We collect the following information through our Services:

  • Personal identification information like your name, email address, mailing address, date of birth, and phone number;

  • Billing information such as a credit card number and billing address;

  • Unique identifiers such as a user name, universal ID number, and password;

  • Preferences information such as product “wish lists,” order history, marketing preferences, and notification preferences;

  • Survey responses, including information we receive through chat bots and text messages;

  • Personal information that you might send to us via email or other correspondence with our personnel;

  • Log and analytics information such as IP address, time of visit, browser type, device type, and the entry/exit points onto our websites.

We collect Personal Data and Anonymous Data in the following ways:

  • When you voluntarily give us information. For example, you may provide us information by filling in forms on our Services, or by corresponding with us or automated services by telephone, email or otherwise. This includes information you provide when you register for a newsletter, take part in a survey or promotion, or report a problem with our websites or mobile applications.

  • Through our clients and service providers. We have contracts with clients and service providers who automatically collect and supply us Personal Data and Anonymous Data when you use our Services. Our service providers who provide information to us include products like Google Analytics, Shopify, ShipStation, Zapier, and Facebook Pixel, which provide information about how users interact with our Services and help us automate the ordering process.

  • Through cookies and similar technologies. We and our service providers use various technologies that place small pieces of data on your device to identify your browser or device and distinguish you from other users of our Services. Please see below regarding our use of cookies, web beacons, and similar technologies.

Cookies

What are Cookies

Cookies are small data files stored on your hardware that help us remember you and your settings and to collect general, anonymous information about how users use our Services. Cookies can be “persistent” or “session” cookies. We use persistent cookies and session cookies.

Persistent Cookies

A persistent cookie is stored on a user’s device in between browser sessions which allows the preferences or actions of a user across the Services (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future visits to our Services and to remember your settings for following visits to our Services.

Session Cookies

A session cookie allows the Services to link your actions during a browser session. We use session cookies to enable certain features of our Services, to better understand how you interact with our Services and to monitor aggregate usage by users and web traffic routing on our Services. Unlike persistent cookies, session cookies are deleted from your device when you log off from our Services and then close your browser.

Web Beacons

Web Beacons (sometimes called “pixel tags”) are small images placed on our Services to compile usage and analytics data. Web beacons allow us to collect Anonymous Data regarding how a specific page is used, including how many users are on a page or what links they click on the page.

Options and More Information

You can set up your browser options to stop your device accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use certain functionalities of our Services.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org, www.allaboutcookies.org, and http://optout.aboutads.info/.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. To modify your settings for Facebook ad tracking you can visit https://www.facebook.com/ads/preferences/.

How We Use Your Information

Personal Data

We use Personal Data:

  • For any purpose that you consent to, including:

    • Recommending products to you.

    • Sending you product and service information.

    • Sending you newsletters you request.

    • Displaying content based on your interests.

    • Providing you with the information, products and services that you request from us.

    • Verifying your eligibility and deliver prizes in connection with contests and sweepstakes.

    • Responding to your inquiries.

  • To fulfill our contractual obligations to you, including:

    • Fulfilling your orders and send you order confirmations.

    • Processing payment for purchases you make.

    • Sending important notices, such as communications about changes to our terms, conditions, and policies.

  • To comply with our legal obligations, for instance to respond to a lawful government request.

  • Pursuant to our legitimate interests to provide our customers a fair and professional experience, including:

    • Providing technical administration and customer support.

    • Making it easier for you to log back into our Services.

    • Notifying customers about changes to our Services.

    • Sending you information that you request from us.

    • Ensuring that content from our Services is presented in the most effective manner for you and for your device.

Anonymous Data

We collect, analyze and use Anonymous Data in an aggregated form to help us provide you with a better user experience on our Services and to improve our Services. For example, we keep track of the domains from which users visit the Services, the types of devices that access the Services, and visitor activity on the Services. We aggregate this Anonymous Data to better understand how our Services are used and how they can be improved.

Disclosure of Your Information

We are not in the business of sharing or selling your Personal Data. We consider this information to be a vital part of our relationship with you. However, in addition to specific requests by you, there are certain circumstances in which we may share your Personal Data with third parties without further notice to you, as set forth below:

  • Business Transfers. As we develop our business, we may buy, sell or reorganize businesses or assets. In the event of such sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

  • Affiliated Companies. We may also share your Personal Data with our subsidiaries, affiliates and other related companies for purposes consistent with this Privacy Policy and providing you with our Services and services.

  • Agents, Consultants and Service Providers. We, like many other businesses, sometimes hire other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function, and we only allow them to process that information for the purposes the information was collected.

  • Credit Card Processing. We use third-party service providers to manage billing and credit card processing. Except for shipping information, we generally do not have direct access to this type of data, but we may in a limited capacity serve as an intermediary that passes such data from you to the payment processor.

  • Service Optimization. We use analytics and search engine providers to assist us in the improvement and optimization of our Service and provide information to providers such as Google for these purposes.

  • Legal Requirements. We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation; (ii) enforce, protect or defend our rights or property, or the rights or property of others; (iii) act in urgent circumstances to protect the personal safety of users of our Services or the public; (iv) protect against legal liability; (v) prevent fraud; or (vi) reduce credit risk.

Special Notification for California Residents – Your Privacy Rights

Individuals who are residents of California and have provided their Personal Data to us may request information regarding our disclosures, if any, of their Personal Data to third parties for direct marketing purposes. Such requests must be submitted to our Privacy Officer in writing at hello@goplato.com or:

Vernon Health LLC
1732 1st Ave, #20745
New York, NY 10128


Such requests must include the reference “Request for California Privacy Information” in the subject line and in the body of the message and must include the e-mail address or mailing address, as applicable, for us to send our response. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted to us if not submitted pursuant to the terms set forth above.

Storage of Personal Data

Our Services are global and your information (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer your information to countries outside of your country of residence, which may have data protection rules that are different from those of your country of residence.

If you live in the European Economic Area (the “EEA”), the Personal Data that we collect from you may therefore be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers or partners. By submitting your Personal Data, you agree to this transfer, storing or processing outside of the EEA.

Protection of Your Information

All information you provide to us is stored on our secure servers located in the United States. Any credit card information or payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavor to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Services. Please be advised that no communication over the Internet is 100% secure, and any data transmission over the Internet is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Links to Other Websites

Our Services may, from time to time, contain links to and from the websites of our partner networks, clients, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

HIPAA

The Company is not covered by HIPAA as we are not a health provider or business associate of a health provider. This means that the information that you provide to us is not protected by the HIPAA privacy rules and regulations.

Your Data Protection Rights

You have the following rights with respect to your Personal Data:

Right to Access - you have the right to request from our Company any copies of Personal Data. We may charge you the reasonable costs of providing such copies, if there are any.

Right to Rectification - you have the right to request that our Company correct any information you believe is inaccurate or incomplete. Most of this information can be corrected via your account page when you log into our Services.

Right of Erasure - You have the right to request that our Company areas your Personal Data by sending an email to hello@goplato.com. When we receive a request to delete your Personal Data, we will use commercially reasonable efforts to honor your request within a reasonable time (but in no event more than 30 days).

Right to Restrict Processing - You have the right to request that our Company restrict the processing of your Personal Data under certain conditions.

Right to Object to Processing - You have the right to object to our Company’s processing of your Personal Data under certain conditions.

Right to Data Portability - You have the right to request that our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

Additionally, you may choose to stop receiving communications from us by following the unsubscribe instructions included in emails or other marketing materials.

Data Retention

We retain Personal Data for as long as necessary for the relevant activity for which it was provided or collected. This will be for as long as we provide access to the Services to you. However, we may keep some data after your account is closed or you cease using our Services for the purposes set out below.

After you have closed your account or ceased using our Services we usually delete Personal Data; however, we may retain Personal Data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our contracts, or fulfil your request to “unsubscribe” from further messages from us.

We may retain Anonymous Data indefinitely.

Customer Support

If you have questions, comments or concerns about our Privacy Policy, please contact us at:

Vernon Health LLC
1732 1st Ave, #20745
New York, NY 10128

hello@goplato.com