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Privacy Statement

The ulivingwell.com™ website and any other URLs and websites administered by ulivingwell, LLC d/b/a ulivingwell.com™ and its affiliates (the “Site”), are offered by ulivingwell.com™ and its affiliates (collectively, “ ulivingwell.com™ ”, “we”, “our”, or “us”) to you, the user, subject to your acceptance of all the terms and conditions in the Terms and Conditions and as set forth below (“Privacy Statement”). The terms “you”, “your”, “user”, and “Member”, refers to all individuals and entities that access the Site. ulivingwell.com™ has created this Privacy Statement to make sure the User is aware of the information ulivingwell.com™ collects and how ulivingwell.com™ uses it. By using this Site, you expressly consent to the collection, storage, disclosure, processing, and use of your information, as outlined in this Privacy Statement and the Terms and Conditions (“Policies”) and you agree to the terms and conditions of the Policies. Unless otherwise defined in this Privacy Statement, the terms used in this Privacy Statement have the same meanings as in our Terms and Conditions.

If you reside outside the U.S., your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By visiting our Site and providing information to us, you consent to such transfer to, and processing in, the U.S.

ulivingwell.com™ updates it’s Privacy Statement annually to reflect changes in our practices around Products and Services. When changes are made to this Privacy Statement, ulivingwell.com™ will notify you via an email sent to all Users. Regardless of notice, however, by visiting this Site, you are accepting the terms of the then current Privacy Statement. Any external links to other websites are clearly identifiable as such, and ulivingwell.com™ is not responsible for the content or the privacy policies of these other websites.

ulivingwell.com™ encourages you to check back, from time to time, and review this Privacy Statement so that you are up to date on the type of the personally identifiable information ulivingwell.com™ collects, how it is used, and to whom and how it is/if disclosed.

Membership Registration: In order to utilize certain features and functionality of the Site and to participate in certain Services we provide, specifically through our by ulivingwell.com™ and ulivingwell.com™ Tiered Membership programs, you will be required to register for a ulivingwell.com™ Membership Account. If you choose to register for a ulivingwell.com™ Membership Account, upon registration, you will provide ulivingwell.com™ with an email address, phone, your full name, a password, and billing information.

When you participate in the individual or group video sessions over Zoom, post a comment or message on the Site, provide information in connection with features such as video conference, chat, or messaging functions, forums, profiles, reviews, testimonials, and recommendations, your name may be visible to other Users. Additionally if your comment or message contains personal information and is posted by you in a manner that is accessible to the public, other Users of the Site, or other participants in any lessons or sessions, 3rd parties may make note of the information and you may receive unsolicited messages from other parties as a result. Any content or information you upload, that you choose to make publicly available to 3rd parties is not considered personally identifiable information subject to this Privacy Statement. Use care when posting personal information.

If you have any questions about this Privacy Statement or ulivingwell.com's™ use of your personally identifiable information, please contact us at info@ulivingwell.com

Information non-disclosure: ulivingwell.com™ will not sell or disclose your name, email address or other personal information to 3rd parties without your explicit consent, except as may be specified in this Privacy Statement from time to time.

Information provided by you: You may provide us with personally identifiable information when you:

• Register for a ulivingwell.com™ Site
• Join the by ulivingwell.com™ or any of our Tiered Membership programs;
• Fill out an e-form requesting a provider session;
• Respond to a “Quality of Care” survey with provider feedback;
• Respond to a “Member Satisfaction” survey with your member experience feedback;
• Sign a membership contract;
• Request customer support or send ulivingwell.com™ any other communication;
• Engage in Zoom or any other tele- or video conference, online consultation services, or Q&A
• Sign up for newsletters, email alerts, special offers and promotions;
• Refer a friend via “Refer-a-Friend” e-form;
• Submit an inquiry via e-form or an email; and
• Participate in ulivingwell.com™ ’s referral, rewards, or promotional programs.

Such information may include your name, email address, areas of wellness interest/concern (please refer to Terms and Conditions for HIPAA considerations), information concerning your use of Products and Services, or geographic location. You may also provide us with information about other people, such as their email addresses, if you refer a friend to the Site or ulivingwell.com™ promotions.

If you choose to use our paid services, ulivingwell.com™ may also require additional information, such as a business name (if applicable), billing and payment information (including billing address, phone number, credit card information), a phone number, and/or a physical address.

Access to your personal information by other Users: By participating in the ulivingwell.com™ Services, you make personal information available to/viewable by other Users. ulivingwell.com™ does not monitor these posts or communications between Users. While ulivingwell.com™ ’s Policies prohibit use by any User, of such information, ulivingwell.com™ does not have control over a User’s actions. If the content you contribute contains personal information, that information may be shared by such User. Use discretion when sharing personal information via ulivingwell.com™ or any other electronic media or digital platform.

Each User hereby represents and warrants that such User will keep any personal information of any other User, which User may receive, learn, or have access to, confidential and not use such information, except as specifically instructed by the disclosing User.

Information collected by cookies: ulivingwell.com™ uses cookies on the Site to improve the quality of the Site and Services to you. One of the features of cookies is to provide a convenience feature to save you time. A cookie is a small text file on User’s computer, which a website sends to the User’s computer to allow the website to store information, which uniquely identifies ulivingwell.com™ Users. ulivingwell.com™ ’s cookies do not collect or distort personally identifiable information. Rather, the cookie stores a token, which uniquely identifies a particular User at a particular time. That token is then linked to the User information in ulivingwell.com™ ’s secured database. You can always delete the cookies and reset your browser to refuse all cookies or to display message when a cookie is being sent. If you reset your browser, some of the Site features and functionality may not be available to you and you may not be able to take advantage of all the features on the Site.

Do not track: Do not track (“DNT”) is a privacy preference that Users can set in certain web browsers. DNT is a way for Users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. ulivingwell.com™ is committed to providing its Users with meaningful choices about the information collected on the ulivingwell.com™ Site for 3rd party purposes, and that is a precise reason why ulivingwell.com™ offers the opt-out links below. However, ulivingwell.com™ does not support DNT or recognize or respond to browser-initiated DNT signals.

• To opt-out of the double click and other Google advertising cookies, please visit the Google advertising opt-out page.
• To opt-out of analysis via the Google Analytics cookie, please visit the Google Analytics opt-out page.

Your California Privacy Rights: If you live in California and have an established business relationship with ulivingwell.com™ , you can request a list of the personal information we have shared with 3rd parties for their marketing purposes. We will also give you a list of the 3rd parties that have received your information. You can make a request one time each year. To exercise your rights, you can email us at info@ulivingwell.com. Mention in your letter that you are making a “California Shine the Light” inquiry. We will respond within 30 days.

You may also request that we provide you with an accounting of your personal information held by ulivingwell.com™ . You may submit that request to ulivingwell.com™ via email at info@ulivingwell.com. Upon verification of your identity and within 45 days, we will provide you with a paper copy of your personal information via the United States Postal Service.

Information collected by Web Beacons and Log Files: When you visit the Site, ulivingwell.com™ ’s servers automatically record information that your browser sends whenever you visit a website (“Log Data”).

This Log Data may include information such as your:

• IP address;
• Browser type or the domain from which you are visiting;
• Operating system;
• Your browser ID;
• How many times your device (computer or phone) access the Site, including dates and times of such access;
• Your activities on the Site; and
• Survey metrics (such as aggregate survey activity).

For most Users accessing the Internet from an Internet service provider, the IP address will be different every time you log on. ulivingwell.com™ uses Log Data to monitor the use of the Site and the ulivingwell.com™ Services, and for the Site’s technical administration. ulivingwell.com™ does not associate your IP address with any other personally identifiable information to identify you personally, except as what is required to enforce this Privacy Statement and the Terms and Conditions for the Site or as necessary to protect the rights, property, or safety of ulivingwell.com™ , its providers, customers, and other Users.

Information collected through Reviews and Testimonials: You may choose to submit a review or testimonial. If you post a review, ulivingwell.com™ may ask for certain information to validate your review or testimonial such as email address, photo, and your city/state/country of residence, link to your social media accounts. If you submit a review or testimonial, ulivingwell.com™ may publish your geographic location or other information but your email address will be kept private. Additionally, any personally identifiable information that you submit as part of the review or testimonial can be read or used by other Site visitors. ulivingwell.com™ is not responsible for any personally identifiable information that you choose to submit as part of your review or testimonial.

Information collected from other sources: ulivingwell.com™ may receive information about you from a friend or colleague (e.g. through a Refer-a-Friend type feature). If you use one of these features, ensure that you only submit email addresses of individuals with whom you have a close personal, professional, or family relationship, who would be interested in receiving the communication, and who has authorized you to share their contact information, including the email address.

Please note that it is impossible to provide 100% security while transmitting information over the internet. ulivingwell.com™ cannot promise, and you should not expect, that your personal information or private communications will always remain private. ulivingwell.com™ cannot guarantee complete security.

Payment information security: ulivingwell.com™ ’s merchant gateway is powered by Stripe. Stripe is a San Francisco, CA-based e-commerce platform. It is PCI compliant and adheres to standards and protocols for building and maintaining secure networks for financial transactions. For more information on Stripe’s security policies click here.

Use of your information by ulivingwell.com™ : ulivingwell.com™ uses the personally identifiable information you provide to:

• Identify areas for improvement for our by ulivingwell.com™ Members, Account holders, and Users;
• Ensure our providers deliver superior quality of care;
• Address any concerns you might have surrounding our wellness platform, its provider network, our Products and Services, and/or any other processes and/or practices
• Communicate directly with you regarding the status of your orders and other inquiries relating to ulivingwell.com™ Products and Services;
• Send you information about ulivingwell.com™ Products and Services;
• For internal business purposes such as data analysis, audits, and so forth;
• Assist us in creating value-add content that is most relevant to you; and
• Have your direct input on how we can improve our platform.

ulivingwell.com™ uses your email address to communicate with your about your account and to send you certain notification emails. You can unsubscribe from such communications using the unsubscribe link provided here. If you refer a friend or colleague to the Site, ulivingwell.com™ will use your friend’s/colleague’s email to send them the email you requested. Your friend’s/colleague’s email addresses will only be used for this purpose unless permission is otherwise granted by such friend or colleague.

ulivingwell.com™ uses non-personally identifiable information to monitor the use and performance of the Site so the ulivingwell.com™ can learn more about how people use the Site which helps us improve ulivingwell.com™ ’s Products and Services and improve your experience with the uivingwell.com Site.

Disclosure of information collected by ulivingwell.com™ to outside parties? Generally, ulivingwell.com™ does not share personal information about you with other people or non affiliated companies without your consent except that:

ulivingwell.com™ provides info,ration to its agents and affiliated service providers and contractors for limited purposes, without limitation, advertising, hosting and maintenance, database storage and management, offering certain Products and Services, marketing campaigns, communicating with Account holders, Members, and customers, providing customer service, managing information on ulivingwell.com™ ’s behalf, and enhancing the Site’s features and functionalities. ulivingwell.com™ will share your personally identifiable information with these 3rd parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such 3rd parties to maintain the privacy and security of your data.

This Privacy Statement applies only to the Services. The Services may contain advertisements or links to other web sites not operated or controlled by ulivingwell.com™ (the “3rd Party Sites), and the policies and procedures described in this Privacy Statement do not apply to those 3rd Party Sites, even if you access them through ulivingwell.com™ or its Services. The links from the Services or the 3rd Party Site’s displays of ulivingwell.com™ logo(s) or other intellectual property elements do not imply that we endorse, have reviewed, or are in any way affiliated with the 3rd Party Sites. Please review the respective policies of the 3rd Party Sites you access so you know how they will use and share your information.

ulivingwell.com™ may also release information (including, but not limited to, your name, addresses, phone number, and account activity) when ulivingwell.com™ , in out sole discretion believes that such release is necessary or appropriate to:

1. Comply with law;
2. Comply with subpoenas, warrants, court orders, government investigations, or other legal process;
3. Enforce or apply the terms of any of ulivingwell.com™ ’s User, Account Holder or Membership agreements
4. Investigate or respond to allegation of fraud, intellectual property infringement, or other unlawful activity;
5. Protect the rights, property or safety of ulivingwell.com™ , or its Users, Account Holders or Members, or others;
6. Protect ulivingwell.com™ reputation and operations; or
7. Permit ulivingwell.com™ to pursue available remedies or limit the damages that ulivingwell.com™ might sustain.

For more information, please contact us at info@ulivingwell.com.

Data retention: ulivingwell.com™ retains personal information when we have an ongoing legitimate business, legal, or compliance need to do so. Our retention records will vary depending on the type of personal information. The general factors we consider in determining whether to retain personal information include, but are not limited to:

• Whether we have a legal or contractual need to retain the information;
• Whether the information is necessary to provide our services or for functionality of Site features;
• Whether our Users, Account holders, or Members have the ability to access and delete the information from their accounts.

When ulivingwell.com™ has no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or if this is not possible, then ulivingwell.com™ will securely store such personal information until deletion of such information possible.

Connecting your Account to 3rd Party Websites: You will be able to connect your ulivingwell.com™ account to the 3rd party accounts. By doing so, you acknowledge and agree that you are consenting to the continuous release of information about you to such 3rd parties (in accordance with your individual privacy setting on those 3rd-party sites). If you do not want information about you, including personally identifyable information, to be shared in this manner, do not use features utilizing connections with 3rd party sites.

This Privacy Statement applicability while accessing 3rd party websites: You may be able to access 3rd party websites directly from the Site. However, this Privacy Statement does not apply when you access 3rd party sites. ulivingwell.com™ cannot control and cannot be held responsible for the content that appears on those sites and is not an endorsement authorization or representation of ulivingwell.com™ ’s affiliation with that 3rd party. Furthermore, ulivingwell.com™ is not responsible for the privacy policies of any 3rd party site or for how they manage their users’ information. These 3rd party sites may place their own cookies on your computer, collect data, or solicit personal information. You may be consenting to those sites through use of the Site. ulivingwell.com™ encourages use to read the privacy policies or statements and terms and conditions for each of the 3rd party sites you visit.

Business transfers: ulivingwell.com™ may sell, transfer, or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, restructuring, reorganization or sale of the assets or in the event of bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned management of your information differs materially from the one that is set forth in this Privacy Statement.

Policy around Children: ulivingwell.com™ is strictly intended for persons age 18 or older. If a parent or a legal guardian becomes aware that his/her child has provided ulivingwell.com™ with personally identifiable information without their consent, he/she should contact ulivingwell.com™ at info@ulivingwell.com. ulivingwell.com™ will take actions to promptly remove such data. ulivingwell.com™ does not knowingly collect personally identifiable information from children under 18. If ulivingwell.com™ becomes aware that a child under 18 has provided personal identifiable information, ulivingwell.com™ will delete such information.

Managing (changing, updating, deleting) your information: Most of your account information can be changed in the “My Account” or “My Membership” section of your Membership on the Site. If you have any questions about what information is stored or would like to obtain a copy of such information, please contact us at info@ulivingwell.com. After receiving proof of your identity, ulivingwell.com™ will provide the information to you, and you may request that ulivingwell.com™ delete or change any or all of the information.

Unless stated otherwise, ulivingwell.com™ ’s current Privacy Statement applies to all information that ulivingwell.com™ has about you and your account.

The current version of ulivingwell.com™ Privacy Statement was adopted effective December 1, 2022.