Healthy Response LLC

Last Updated: March 14, 2024

Healthy Response LLC (“Healthy Response,” “we,” or “us”) recognizes the importance of data privacy and information security. This Privacy Policy sets forth the terms and conditions with respect to how we process personal information. This Privacy Policy describes, among other things, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

This Privacy Policy applies to the personal information you provide us when you (i) visit any website that we own, license, maintain or otherwise operate and that links to this Privacy Policy (each, a “Website”), (ii) purchase or receive products through the Website, or (iii) visit our facilities or otherwise contact or engage with us. For purposes of this Privacy Policy, the Website and all products furnished by Healthy Response through a Website shall be referred to collectively as the “Products.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE PRODUCTS OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY, OUR TERMS & CONDITIONS, OUR COOKIE POLICY, AND ANY APPLICABLE POLICY ON A WEBSITE.

You must be at least eighteen (18) years of age to access the Products. Healthy Response is headquartered in the United States, and the personal information you provide to Healthy Response may be processed and stored in the United States and other jurisdictions. For more information on our data transfer practices, please see Section 9 (Data Retention and Localization).

Scope

This Privacy Policy applies to personal information that Healthy Response receives during its business operations as a “data controller” - which means those activities in which we determine the purpose and means of processing personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or can be associated with a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. Healthy Response may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and Healthy Response may use such data for any purpose.

The Types and Categories of Personal Information We Collect

Healthy Response collects personal information in order to provide our Products, comply with our legal obligations, promote our business interests, manage employment relationships and benefit programs, and for the other reasons set forth in this Privacy Policy. When you choose not to provide personal information to Healthy Response, we may not be able to provide you the Products or to complete a transaction you requested. Generally, we may from time to time collect the following types and categories of personal information during our business operations:

Personal Information
Category	Description/Examples
Personal Identifiers	Identifiers, such as your name, alias, residential address, email address, account name, telephone number, customer identification number.
Registration Information	Information provided when you register for an account to use the Website, including usernames and passwords.
Online Identifiers (For more information, see “Technical Data” below)	Persistent identifiers that can be used to recognize you or your device over time and across different Products, including a device identifier, an Internet Protocol (IP) address, cookies, beacons, pixel tags, mobile ad identifiers, and similar technology.
Transaction Data	Records of the Products you selected, purchased, obtained, or considered, or your other purchasing or consuming histories or tendencies with respect to our Products.
Business Contact Data	Information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, company, partnership, sole proprietorship, nonprofit, or government agency) with whom we conduct, or possibly conduct, business activities.
Health and Disability Data	You may furnish us with health-related information in the event you, or a third party, has an adverse reaction to the use of our products or goods. You may also furnish us with health-related information in the event we undertake health screening or accommodate a disability when you engage with us.
Marketing and Communications Data	Information with respect to your marketing preferences and your subscriptions to our publications and alerts. You may opt out from email marketing at any time by using the “unsubscribe” feature within an email marketing communication or by contacting us in accordance with the “Contact Us” section below.
Communications	Communications with us (such as recordings of calls with customer service representatives for quality assurance and training purposes), and other communications that occur through the Website. Please be aware, we, and our service providers and business partners, may record calls and retain the content of chat transcripts, emails, text messages, and other written or electronic communications between you and us.
Internet and Electronic Network Data	Data pertaining to your access or use of the Website, including browsing history, search history, and information regarding your interaction with the Website or advertisements embedded on the Website or other third-party websites, and information derived from any device that connects to our WiFi Products.
Your Feedback	Information you provide about our Products, which may include data gathered from any Healthy Response surveys or reviews submitted by you.
Visitor Information	Information an individual provides when visiting any physical location or premises of Healthy Response (e.g., visitor logs and registries, vehicle and parking information).
Video and Images	In some circumstances, you may provide us images (e.g., your use of a product) or we may record you via a video camera (e.g., on-premises security systems) or through video teleconferencing.
Geolocation Data	Information about the general city, state, or region in which a user of the Website is located.
Professional or Employment Data (For more information, see “Employment Applications and Talent Management” below)	If you apply for or accept a job with Healthy Response , we collect information set forth in a resumé, curriculum vitae, cover letter, and similar documentation, including contact details, employment history, skills, or qualifications, education-level, job compensation and benefit preferences, criminal record, credit history and similar data, and information provided about or by your references.
Inferences	Inferences drawn from some of the personal information categories identified herein and used to create a consumer profile reflecting your purchasing and marketing preferences, characteristics, and behavior.

Technical Data

When you access the Website, we collect certain data automatically using technical means and tools. This data relates to your device, as well as your experience on the Website and other websites, including the following:

Usage and Device Data. When you access and use the Website, we automatically collect details of your access to and use of the Website, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Website (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Website may collect “diagnostic” data related to your use of the Website, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Website. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Website may become inaccessible or not function properly. In addition, the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Website (e.g., recording the popularity of certain content and verifying system and server integrity). The Website may collect data about the advertisements you have seen or engaged. For more information, see our Cookie Policy.

Non-Cookie Technologies. We may deploy on our Sites certain types of “Non-Cookie Technologies” provided by our service providers to support our digital advertising programs. These technologies often include browser cache, locally stored objects, or the creation of a statistical identifier wherein an identifier, much like a cookie identifier, is calculated based on the characteristics of a browser or device that distinguishes it from other browsers or devices. These identifiers are calculated either from the data your browser or device shares automatically or with additional data specifically requested from your browser or device. For more information, see https://thenai.org/wp-content/uploads/2021/07/NAI_BeyondCookies_NL.pdf.

Website Monitoring. Please be aware that we, and our third-party service providers and partners, use cookies and other tracking technologies within the Website to, as applicable, monitor and record any and all activities and communications to, from, and on, the Website in order to safeguard, improve, and analyze usage of, the Website, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording by us and our third-party service providers and partners.

Audio and Visual Materials. Our Website may, from time to time, display live or prerecorded videos or similar audio-visual materials (“Videos”). We may collect personal information with respect to you requesting access to, or accessing, such Videos, and we may disclose such personal information to third parties, including to our third-party service providers through the use of cookies. By requesting access to, or accessing, such Videos, you hereby agree to our Video Information Disclosure Consent Form. The provision of Videos on our Website is not an admission by Healthy Response and it shall not otherwise be interpreted, in any form or manner, to mean that Healthy Response is a “video tape service provider” for purposes of the Video Privacy Protection Act (codified as amended at 18 U.S. Code § 2710) (the “VPPA”) or that Healthy Response is otherwise subject to the VPPA.

Sources of Information

We collect the personal information identified herein directly from you when you use our Products, through automated means when you are using the Website, and from third parties. More specifically, we collect personal information from the following sources:


First Party / Direct Collection. We collect personal information directly from you when you use our Products, or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Website (see “Technical Data” above and “Cookie and Tracking Technologies” below).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, and third-party references.

How We Use your Information / Purpose of Collection

We may use the personal information we collect about you in order to provide our Products, comply with our legal obligations, and promote our business interests.

How Your Personal Information Is Used

• Provide, operate, maintain, improve, and promote our Website.
• Enable you to access and use our Website.
• Process and complete transactions, and send you transaction related information, including purchase confirmations and invoices.
• Send you messages and communications related to our Products (e.g., responses to your comments, questions, and requests, customer Products), including by email and text messages.
• Furnish technical notices, updates, security alerts, and support and administrative messages to you about our Website.
• Provide you promotional and marketing communications (e.g., information about our Products, features, surveys, newsletters, offers, promotions, contests, and events).
• Monitor and analyze trends, usage, and activities in connection with our Website to promote our business interests.
• Investigate and prevent fraudulent transactions, unauthorized access to or use of our Website, and other illegal activities.
• Personalize our Website, including providing features or advertisements that match your interests and preferences.
• Healthy Response may collect and use your personal information for any other purpose for which we obtain your consent.

Mobile Messaging Program. In the event you opt-in to receive SMS/text messages from us (“Mobile Messaging Program”), we will collect and use your mobile telephone number to maintain and administer our Mobile Messaging Program. With your permission, we may send text messages about our store, new products, and other updates, including “Checkout Reminders,” and we use webhooks to trigger the Checkout Reminders messaging system.

Sharing Information / Third-Party Disclosures

We share your personal data as described below and in this Privacy Policy, and as permitted by applicable law.

Category of Recipient	Purpose of Disclosure
Intra-Group	We may share your personal data with our parent company, and our affiliates, and subsidiaries.
Service Providers	We share personal data with third parties in connection with the delivery of our Products (e.g., credit card processing, customer service, business analytics, fraud prevention, legal compliance Products, and advertising and marketing).
Business Partners	We may share your personal data with third parties that distribute our goods, products, and marketing materials.
Business Restructuring	Circumstances may arise where, for strategic or other business reasons, we decide to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal data to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of our assets.
Legal; Compliance; Legitimate Interests	We may disclose personal data (i) if required by law or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition, we may disclose your personal data with any third party when we believe such disclosure is necessary to defend or protect our legal, regulatory, or business interests.
Consent	In addition to the reasons for disclosure set forth herein, we may also disclose your personal data upon your consent.

 

In the event that you facilitate a transaction with Healthy Response or request information from or otherwise engage with us, and such activities require Healthy Response to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct Healthy Response to intentionally disclose your personal information to the service provider or third party.

Social Media/Platform Data Rights

We may engage with you on various social media platforms (e.g., Facebook, Twitter, LinkedIn, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms also may automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Sites include social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button, and the like) or interactive mini-programs that run on the Sites. These features may collect your IP address and which Website page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Sites. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

Links to Other Websites; Your Direct Third-Party Disclosures

As a resource to you, the Website may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Website. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

Data Retention and Localization

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information for as long as needed to provide you with our Website, to facilitate transactions you have requested, to comply with our legal obligations (e.g., tax filings, export control laws), to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

Healthy Response is based in the United States, and the personal information that we collect and process is retained and stored in the United States. Healthy Response uses service providers that store personal information on our behalf in the United States and in other third countries. Please be aware that the United States, and these other third countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial or administrative orders, decrees, and demands, or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in such other third countries.

Security

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE, AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE WEBSITE OR THE PRODUCTS OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Website, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately (and in any event within twenty-four (24) hours) if you have reason to believe that your username or password to our Website has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

No Data Collected from Children

The Website is not directed at, nor intended for use by, children. As a result, if you are under the age of eighteen (18), you are prohibited from accessing or using the Website ( or with providing us with your personal information.

Publicly Posted Information; Product Reviews

You may, from time to time, have the ability to submit via the Website a comment on, provide an opinion about, rate, or otherwise discuss our Products (a “Review”). In other circumstances, we may provide you with the opportunity to create, submit, post, display, transmit, perform, publish, distribute, or broadcast content and materials to us or on the Website, including but not limited to text, writings, video, audio, photographs, graphics, comments, suggestions, or personal information or other material (collectively, “User Contributions”) on or through the Website. Any information or content you post in a Product Review or in your User Contribution may be available to other users of the Website (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and User Contribution to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and User Contribution that you wish to remain confidential. Any third party with access to your information via the Website will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Website is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available. As between you and Healthy Response , any and all Product Reviews and User Contributions shall be considered our confidential and proprietary information. In order for Healthy Response to utilize such Product Reviews and User Contributions, you grant to Healthy Response a non-exclusive, perpetual, irrevocable, worldwide, royalty-free license, with the right to sublicense, under all relevant intellectual property rights, to use, publish, and disclose such Product Reviews and User Contributions in any manner we choose and to display, perform, copy, make, have made, use, sell, and otherwise dispose of Healthy Response ’s and our sub-licensees’ products or Products embodying such Product Reviews and User Contributions in any manner and via any media we choose, without reference to the source. Healthy Response shall be entitled to use Product Reviews and User Contributions for any purpose without restriction or remuneration of any kind with respect to you and/or your representatives.

Your Responsibilities

You are permitted, and hereby agree, to only provide personal information to Healthy Response if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO HEALTHY RESPONSE, YOU EXPRESSLY REPRESENT AND WARRANT TO HEALTHY RESPONSE THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE HEALTHY RESPONSE WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT HEALTHY RESPONSE ’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY HEALTHY RESPONSE FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO HEALTHY RESPONSE.

Updating Your Information

It is important that the personal information that you provide to us is accurate and reliable. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email), and you must do so when such changes are warranted. You may review, update, or modify your personal data, including profile and contact information, at any time by logging into your account or contacting us in accordance with the “Contact Us” section below.

Do-Not-Track Signals

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

Persons with Disabilities

Healthy Response strives to ensure that every person has access to information related to our Products, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format, and we will seek to meet your needs.

Rewards Programs and Financial Incentives

We may, from time to time, collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We use the personal information you provide in these programs to verify your identity, offer unique rewards, track your program status, and facilitate the exchange of program points for products, promotional materials, training workshops, and other items. If you consent to participate in any of our Rewards Programs, you may withdraw that consent at any time by contacting us in accordance with the “Contact Us” section listed below or in accordance with the instructions set forth in the applicable Rewards Program’s terms and conditions. The Healthy Response may use personal information gathered from, or related to, participants in our Rewards Programs for any other purpose or in any other manner set forth in this Privacy Policy.

Employment Applications and Talent Management

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, resumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

Changes to the Policy

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Products and continued use of the Products after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

Contact Us

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at hello@myhealthyresponse.com.