Privacy Policy

This Privacy Notice describes how IMspire, Inc. d/b/a Greatly Health, together with its subsidiaries and affiliates (collectively, “Company” “us,” “we,” or “our”) processes personal data we collect about you, including through our websites, social media accounts, mobile applications, and other online and offline interactions and communications (collectively, our “Services”).

1. Types of Personal Data We Collect

Depending on how you interact with our Services, we may collect the following types of personal data about you:

• Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
• Records about you, such as signatures, physical characteristics or a description of you, the content, timing and method of communications you have with us, such as online chats, calls, and emails, and reviews, comments and similar information you share with or upload to our Services.
• Demographic information, such as age (including birthdates) and gender.
• Internet or other electronic network activity information, such as your preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Services. For more information about cookies and other device data, please see Section 5 (Cookies and Other Tracking Technologies).
• Non-precise geolocation data, such as your location as derived from your IP address.
• Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
• Professional or employment-related information, such as job title, organization, professional licenses, credentials, or affiliations, and other professional information.
• Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.

Some of the information we collect may be considered sensitive personal data, such as racial or ethnic origin, information about your health, and health insurance information.

2. Sources of Personal Data

We collect personal data about you from the following sources:

• Directly from you. We may collect personal data you provide to us directly, such as when you contact us through our Services, interact with us in person, sign up for offers or newsletters, post reviews and comments, place or customize orders, or sign up for an account or other services.
• Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Services. This may include information about how you use and interact with our Services, information about your device, and internet usage information.
• From third parties. We may collect personal data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, and social media companies.

·        From publicly available sources. We may collect personal data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

3. How We Use Personal Data

We may use personal data for the following purposes:

• To provide our Services, such as processing and fulfill purchases, communicating about orders, soliciting your feedback, providing customer service, creating and maintaining user accounts, and engaging in similar activities that facilitate your relationship with us.
• To operate our business, such as maintaining internal business records, enforcing our policies and rules, auditing, and maintaining security of our systems.
• For our internal research and product improvement purposes, such as improving and designing new products or services, developing and improving algorithms, artificial intelligence or machine learning tools and models, evaluating the effectiveness of our advertising or marketing efforts, and debugging and repairing errors with our systems, networks, and equipment.
• For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements, for the establishment, investigating, responding, or defense of legal claims, protecting safety, property, or rights, detecting, preventing, and responding to security incidents and health and safety issues, and protecting against malicious, deceptive, fraudulent, or illegal activity.
• For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. This may include sending newsletters and promotions, delivering personalized advertising, and communicating about events. You can unsubscribe from our email marketing via the link in the email, by responding “STOP” to the text message, or by contacting us using the information in Section 9 (Contact Information) below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Data

We may disclose personal data to third parties, including the categories of recipients described below:

• Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
• Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms Of Services and other agreements or policies, and to protect our, our customers’, or third parties’ safety, property, or rights.
• Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
• Business partners that may use personal data for their own purposes, such as:

·        Advertisers, ad platforms and networks, and social media platforms;

·        Third parties whose cookies and tracking tools we use as described in our Section 5 (Cookies and Other Tracking Technologies) below.

·        Commercial data partners to whom we make information available for their own marketing purposes; and

·        Partners who work with us on promotional opportunities, including co-branded products and services.

Where required by law, we will obtain your consent prior to disclosing your personal data to our business partners.

• The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any personal data in comments, reviews, or other content that you share in public areas of our Services may be read, collected, or used by other users or the public.
• Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

Our Services and authorized third parties use cookies, pixels, session replay tools, and other tracking technologies to collect information about you, your device, and how you interact with our Services. This information may include your IP address, location, cookie ID, device ID, operating system, browser used, browser history, search history, and information about how you interact with our Services (such as pages on our Services that you have viewed).

We use these technologies the following purposes:

·        Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Services;

·        Improving performance, such as maintaining and improving the performance of our Services;

·        Analytics, such as analyzing how our websites are used.

·        Advertising, such as conducting advertising and content personalization on our Services and those of third parties, tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”), and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our emails; and

·        Security, such as preventing fraud and malicious behavior.

Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Services’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

Some browsers have incorporated Do Not Track (“DNT”) preferences. At this time, we do not honor Do Not Track signals.

6. Data Security and Data Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.

Your personal data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. Once you have terminated your relationship with us, we may retain your personal data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes.

7. Children’s Privacy

Our Services are intended for individuals 18 years of age and older. As a general rule, we do not knowingly collect any information, including personal data, from children under 18 years of age.

8. External Links

Our Services may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

9. Contact Information

If you have questions regarding this Privacy Notice, please contact us at: support@greatlyhealth.com

10. Supplemental U.S. State Privacy Disclosures

California Shine the Light: If you are a California resident, you may opt out of sharing your personal data subject to California Civil Code §1798.83 (the “Shine the Light law”) with third parties for those third parties’ direct marketing purposes by emailing us at support@greatlyhealth.com.

Data Subject Rights

Depending on our relationship with you and in which state you reside within the United States, you may have certain rights regarding personal data:

·        Right to Know. You may have the right to request information about the categories of personal data we have collected about you, the categories of sources from which we collected the personal data, the purposes for collecting, selling, or sharing the personal data, and to whom we have disclosed your personal data and why. You may also request the specific pieces of personal data we have collected about you.

·        Right to Delete. You may have the right to request that we delete personal data that we have collected from you.

·        Right to Correct. You may have the right to request that we correct inaccurate personal data that we maintain about you.

·        Right to Opt Out of Sales and Sharing for Targeted Advertising. You may have the right to opt out of (i) the sale or sharing of your personal data and (ii) targeted advertising.

·        Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit the use and disclosure of Sensitive Personal Information.

You may exercise any of the rights available to you by emailing us at support@greatlyhealth.com.

To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

We will not discriminate against you for exercising your privacy rights.

Nevada residents: Individuals may contact us at support@greatlyhealth.com to inquire about your right to opt out of the sale of your personal data.

Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are, and will inform you if we need such information.

Authorized Agents: In certain states, authorized agents may exercise certain rights on your behalf by submitting a request by email at support@greatlyhealth.com and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of you by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.

Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us by email at support@greatlyhealth.com. We will inform you in writing our response to your appeal.

11. Updates

We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If required by law, we will obtain your consent or contact you directly prior to the changes becoming effective.