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This Consumer Health Data Privacy Policy (“Health Privacy Policy”) applies to Sensoriy’s collection of “Consumer Health Data” of consumers that reside in certain states such as Connecticut, Washington, or Nevada, in accordance with applicable Consumer Health Data Privacy Laws. This Health Privacy Policy supplements Sensoriy’s Privacy Policy and any capitalized but undefined terms have the meanings given in the Privacy Policy or the relevant law.
Definition of Consumer Health Data
“Consumer Health Data” generally includes personal information that is linked or reasonably linkable to you and that identifies, or that we may use to identify, your past, present, or future physical or mental health status. Consumer Health Data does not include information that is publicly available, de-identified, or aggregated.
Categories We Collect
Information about a health or wellness condition that you provide to us, for example in a questionnaire or survey.
Purposes for Collection & Use
- We may collect, use, disclose, or otherwise process your Consumer Health Data as reasonably necessary to provide you with products or services relevant to your Consumer Health Data. See our Privacy Policy for “Our Commercial and Business Purposes for Collecting Personal Data” and “Other Permitted Purposes for Processing Personal Data”.
- We do not engage in geofencing around stores that provide in-person health care services in Washington to identify or track you when seeking health care services, collect your Consumer Health Data, or send notifications, messages, or advertisements related to such data.
- We may create aggregated, de-identified, or anonymized data from Consumer Health Data, including by removing information that makes the data personally identifiable to you. We may use such data and disclose it to third parties for lawful business purposes, provided we do not disclose it in a manner that could identify you.
- We do not “sell” your Consumer Health Data as defined under Health Data Privacy Laws.
How We Disclose Consumer Health Data
- Vendors. We may disclose your Consumer Health Data to service providers, contractors, analytics partners, business partners, and vendors to provide and improve our Services to you.
- Other Parties. We may disclose your Consumer Health Data to other parties to whom you explicitly gave us consent to disclose.
We may also disclose your Consumer Health Data to government (including law enforcement) or other parties to meet legal requirements and enforce legal terms; and all of your Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or similar transaction.
Consumer Health Data Rights
- Access and Portability. Request confirmation of or access to the Consumer Health Data that we process about you. WA/NV residents may request a list of all third parties and affiliates with whom we have disclosed or sold your Consumer Health Data and their contact information (if applicable). CT residents may request a copy of your Consumer Health Data in a machine-readable format, to the extent technically feasible.
- Correction. (CT) Request correction of inaccuracies in your Consumer Health Data, as appropriate to the nature of such data and our purposes of processing.
- Deletion. Request deletion of the Consumer Health Data that we have collected about you.
- Withdraw Consent. Withdraw consent for us to collect and disclose your Consumer Health Data. Due to the nature of our Services, this may require deletion of your Personal Data or your account.
- Opt-Out of Sale, Targeted Advertising, and Profiling. (CT) Opt-out where applicable; however, we do not conduct such activities.
- Nondiscrimination. We will not discriminate against you for exercising your rights.
- Appeal. If we refuse to act on your request within a reasonable period, you may appeal our decision. If we deny your appeal, you may contact the Attorney General of your state of residence (NV, WA, CT).
How to Exercise Your Rights
Submit a request that (1) provides sufficient information to allow us to verify that you are the person about whom we collected Personal Data and your relationship with us (such as your Contact Data or Sensoriy Account Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria.
- Email: privacy@sensoriy.com
- Call us: (number to be provided in the Privacy Policy)
Helpful Links
Contact
If you have any questions about this section or whether any rights apply to you, please contact us at privacy@sensoriy.com.
Profile or Contact Data
Examples: first and last name, email, phone number, mailing address
Purposes: Providing, Customizing and Improving the Services; Marketing the Services; Corresponding with You.
Shared with: Service Providers; Advertising Partners; Business Partners; Parties You Authorize, Access or Authenticate.
Payment Data
Examples: payment card type, last 4 of your payment card, billing address, phone number, and email
Purposes: Providing, Customizing and Improving the Services; Corresponding with You.
Shared with: Service Providers (specifically our payment processing partner, currently Stripe.)
Device/IP Data
Examples: IP address, IP-address location, device ID, type of device/ operating system/ browser used to access the Services
Purposes: Providing, Customizing and Improving the Services; Marketing the Services.
Shared with: Service Providers; Advertising Partners.
Social Network Data
Examples: social media handle, posts, or other content when you interact with us on social media
Purposes: Providing, Customizing and Improving the Services; Marketing the Services; Corresponding with You.
Shared with: Service Providers; Business Partners; Parties You Authorize, Access or Authenticate.
Health Data*
Examples: a health concern you identify in a questionnaire or survey we provide
Purposes: Providing, Customizing and Improving the Services; Corresponding with You.
Shared with: Service Providers; Parties You Authorize, Access or Authenticate.
Lemme Account Data
Examples: unique identifiers and other information you add to your Sensoriy Account
Purposes: Providing, Customizing and Improving the Services; Corresponding with You.
Shared with: Service Providers; Parties You Authorize, Access or Authenticate.
Commercial Data
Examples: purchase history of our products
Purposes: Providing, Customizing and Improving the Services; Marketing the Services; Corresponding with You.
Shared with: Service Providers; Advertising Partners; Business Partners; Parties You Authorize, Access or Authenticate.
Web Analytics
Examples: Web page interactions, Referring webpage/source, non-identifiable request IDs, interaction stats
Purposes: Providing, Customizing and Improving the Services; Marketing the Services.
Shared with: Service Providers; Advertising Partners; Business Partners.
Consumer Demographic Data
Examples: birth month and day
Purposes: Providing, Customizing and Improving the Services; Marketing the Services; Corresponding with You.
Shared with: Service Providers; Business Partners; Parties You Authorize, Access or Authenticate.
Other Identifying Information You Provide
Examples: identifying information in emails or letters you send us, and information you may voluntarily provide when corresponding with us regarding our Products (including feedback)
Purposes: Providing, Customizing and Improving the Services; Corresponding with You.
Shared with: Service Providers; Business Partners; Parties You Authorize, Access or Authenticate.
* This data may be considered “sensitive” under certain U.S. State Privacy Laws. If you are a resident of U.S. states like Connecticut, Washington, or Nevada and we collect your Health Data, the Consumer Health Data Privacy Policy applies.
Categories of Sources of Personal Data
You
- When you provide such information directly to us, create an account, or use our interactive tools and Services.
- When you post or upload content (public submissions may not be subject to this Policy).
- When you complete surveys or questionnaires, or contact us via email/other channels.
- Through giveaways and promotions we sponsor with third parties (see their terms/policies).
- Automatically via Cookies and similar technologies, location-enabled browsers, and certain applications/software we provide.
Third Parties
Vendors
We may use analytics providers to analyze engagement with the Services or help provide you customer support.
Advertising Partners
We receive information from vendors who assist with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Processing orders/transactions; billing.
- Providing products, services or information you request.
- Fulfilling the reason you provided information to us and providing support.
- Improving the Services (testing, research, analytics, product development).
- Personalizing content/communications based on your preferences.
- Fraud protection, security, and debugging.
- Other business purposes as permitted under applicable U.S. State Privacy Laws.
Marketing the Services
- Marketing and selling the Services.
- Showing advertisements, including Targeted Advertising.
Corresponding with You
- Responding to correspondence; sending information about Sensoriy or the Services.
- Sending emails and other communications according to your preferences.
Other Permitted Purposes
We may collect, use, and disclose Personal Data to meet legal requirements, protect rights, enforce agreements, respond to claims, resolve disputes, and for other purposes described by law. We will not collect additional categories or use Personal Data for materially different purposes without notice or consent.
How We Disclose Your Personal Data
We disclose Personal Data to the categories of service providers and other parties listed below. Some disclosures may constitute a “sale” under certain state laws.
Service Providers
- Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- Analytics providers unrelated to Targeted Advertising.
- Payment processors (e.g., Stripe, Klarna).
Advertising Partners
- Ad networks, marketing providers, and analytics providers that assist with Targeted Advertising.
Business Partners
- Businesses you have a relationship with.
- Companies offering joint promotions or shipping/fulfillment services with us.
Parties You Authorize, Access or Authenticate
- Third parties you access through the Services; social media services; other users.
Legal Obligations & Business Transfers
We may share any Personal Data with third parties to meet legal requirements. All Personal Data may be transferred if we undergo a merger, acquisition, bankruptcy, or similar transaction.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data and use/share it for lawful purposes, provided it does not identify you.
Data Security
We use appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we process it. You should also protect your data (e.g., strong passwords, limited device access, sign-off after use). No method of transmission or storage is completely secure.
Data Retention
We retain Personal Data as long as necessary to provide Services or perform business purposes for which it was collected, and longer as needed to comply with legal obligations, resolve disputes, or collect fees. We may retain information in anonymous/aggregated form.
- Profile information and credentials – retained while you have an account.
- Payment data – retained while processing your purchase/subscription.
- Device/IP data – retained as needed to ensure systems function appropriately and efficiently.
Personal Data of Children
We do not knowingly collect Personal Data about children under 18. If you believe someone under 18 provided Personal Data to us, contact privacy@sensoriy.com.
U.S. State Privacy Rights
If you reside in certain U.S. states, you may have rights under applicable privacy laws, including Access, Deletion, Correction, Portability, and the right to Opt-Out of Targeted Advertising or the “sale”/“share” of Personal Data. We do not sell Personal Data for monetary consideration and do not sell/share the Personal Data of anyone under 18. Over the past 12 months, we may have “sold” or “shared” IP/Device Data and Web Analytics Data with Advertising Partners.
Sensitive Personal Data
We may collect “Sensitive Personal Data” as needed and as described above. Your rights (opt-in/opt-out) vary by state. For California residents, we only process Sensitive Personal Data for permitted purposes and not to infer characteristics.
Anti-Discrimination
We will not discriminate against you for exercising your rights. Different service tiers may be offered as permitted by law and related to the value of Personal Data.
Other State-Specific Rights
California residents may request we prevent disclosure of Personal Data to third parties for their direct marketing purposes. Nevada residents may opt out of the sale of certain Personal Data (we do not currently sell Personal Data per Nevada law). We may offer “Sensoriy’s Loyalty Program” and other Programs that could be deemed “financial incentives” under some laws; participation is optional and you may withdraw at any time.
Exercising Your Rights Under U.S. State Privacy Laws
You (or an Authorized Agent) can submit a Valid Request via our Privacy Request Form or by contacting us. We may need sufficient information to verify your identity and understand/evaluate your request. We typically respond within legally required periods. Fees may apply for excessive or unfounded requests.
Residents of certain states may appeal a refusal to act on a request by emailing privacy@sensoriy.com with subject including “[STATE OF RESIDENCE] Appeal”.
European Union, United Kingdom, and Swiss Data Subject Rights
If you are in the EU/UK/Switzerland/Lichtenstein/Norway/Iceland, you may have GDPR rights.
Personal Data We Collect & Use
See “Categories of Personal Data We Collect” and “Our Commercial or Business Purposes for Collecting Personal Data”.
Lawful Bases
- Contractual Necessity – Contact Data; Lemme Account Data; Payment Data; Device/IP Data; Health Data; Other Info You Provide.
- Legitimate Interest – various categories including Contact, Account, Commercial, Device/IP, Web Analytics, Social, Demographic, Payment, and de-identified data.
- Consent – where expressly indicated at collection.
- Other Grounds – legal obligation, vital interests, public interest tasks.
Privacy Rights
- Access, Rectification, Erasure, Withdrawal of Consent, Portability, Objection, Restriction, and the Right to File a Complaint with your Supervisory Authority.
Transfers of Personal Data
The Services are hosted in the United States. By using the Services, you authorize transfer, storage, and processing in the U.S. (and possibly other countries). Transfers may occur pursuant to appropriate safeguards such as standard contractual clauses.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time and will alert you by placing a notice on the Sensoriy website, emailing you, and/or by other means. If you continue using the Services after changes are posted, you agree to the changes. Use of information is subject to the Policy in effect at the time of collection.
Contact Information
If you have any questions or comments about this Privacy Policy or your Personal Data, contact us at:
- Phone: 888-457-1505
- Website: www.sensoriy.com
- Email: info@sensoriy.com
- Address: 1111b South Governors Ave STE 37939, Dover, DE, 19904 US