Noho Health Inc. California Privacy Notice

Last Updated: April 11, 2020

This California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).

This CA Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

Scope

When we use the term “personal information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of this CA Notice, personal information does not include:

  • Publicly available information from government records.

  • Deidentified, aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

  • Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

  • Information relating to our employees, contractors and other personnel.

Collection and use of Personal Information

In the last 12 months, we have collected the following categories of personal information from the categories of sources and for the purposes set forth below, which reference the personal information, sources and purposes described in the ‘Information We Collect and/or Receive’ and ‘How We Use and Share Information’ sections of our Privacy Notice:

Category of Personal Information Collected Collected Commercial or Business Purpose Categories of Sources
Identifiers, including your name, address, phone number, email address, date of birth or other similar identifiers.
  • To run the application
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • Understanding consumer shopping behavior
  • To fulfill orders
  • To communicate with you about your order
  • Addressing software issues
  • Updating your payment information
  • For customer service purposes
  • For quality assurance purposes
  • For regulatory compliance purposes
  • For collecting feedback
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • For marketing purposes
  • Product and services improvement
  • For contests and sweepstakes
  • Directly from you
  • Your browser or device
  • Our business partners and affiliates
  • Third parties you direct to share information with us
  • Push notification providers
  • Shipping providers
  • Customer service platforms
  • Data providers
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate, contact information and payment information.
  • To run the application
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • To fulfill orders
  • To communicate with you about your order
  • Updating your payment information
  • For customer service purposes
  • For quality assurance purposes
  • For regulatory compliance purposes
  • For collecting feedback
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • For marketing purposes
  • Product and services improvement
  • For market research purposes
  • Directly from you
  • Your browser or device
  • Our business partners and affiliates
  • Third parties you direct to share information with us
  • Shipping providers
  • Customer service platforms
Protected Classification Characteristics, including your age, race, veteran status, and gender.
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • Directly from you
Commercial Information, including shopping and purchase history.
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • To fulfill orders
  • For customer service purposes
  • For quality assurance purposes
  • For regulatory compliance purposes
  • For collecting feedback
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • Directly from you
  • Your browser or device
  • Our business partners and affiliates
Internet/Network Information, including device information, logs and analytics data.
  • To run the application
  • Understanding consumer shopping behavior
  • Addressing software issues
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • Product and services improvement
  • Directly from you
  • Your browser or device
  • Data providers
Geolocation Data, including precise location information from your device or generated based on IP address.
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • Directly from you
  • Your browser or device
Sensory Information, including recordings of phone calls with us, where permitted by law.
  • For customer service purposes
  • For quality assurance purposes
  • For regulatory compliance purposes
  • For collecting feedback
  • Product and services improvement
  • Directly from you
  • Your device
Professional/Employment Information, including your employment history, educational history, and degree relevant to your job application (applicants only).
  • For job application purposes
  • Directly from you
  • For applicants, from third parties you direct to share information with us
Other Personal Information, including loyalty program data, information you post on our social media pages or otherwise provide to us.
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • For market research purposes
  • Directly from you
  • Your browser or device
  • Third parties you direct to share information from us
Inferences, including predictions about your interests and preferences.
  • To generate recommendations for users
  • Shipment purposes
  • Monitor the use of products
  • Monitor habit formation and apply rewards
  • For financial and engagement analytics
  • Subscription forecasting purposes
  • Personalization purposes
  • For market research purposes
  • Directly from you
  • Your browser or device
  • Information generated or derived from your purchases, online browsing and usage activity

Disclosure of and Recipients of Personal Information

As described in the ‘How We Use and Share Information’ section in our Privacy Notice, we have disclosed personal information within Noho Health and with a variety of third parties for business purposes. In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose:

  • All of the categories of personal information we collect, explained in the table above.

We may from time to time, and we have in the last 12 months, exchanged contact information (Identifiers and CA Customer Records) we maintain for contact information our promotional and marketing partners maintain, which would constitute a “sale” as defined under the CCPA. In addition, as is common practice among companies that operate online, we do allow certain third-party partners and providers to collect information about consumers directly through our services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. For more information about how to opt out of personal information sharing that constitutes a “sale” under the CCPA, please refer to the ‘Your California Consumer Rights’ section below.

Your California Consumer Rights

California Consumer Rights

As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):

The Right to Know You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold about you (if any) and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or, if applicable, selling the personal information.
The Right to Request Deletion You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

How to Exercise your California Consumer Rights

To Exercise Your Right to Know or Right to Request Deletion

To exercise your Right to Know or your Right to Request Deletion, please submit a request by: - Emailing data-privacy@takecareof.com with the subject line “California Consumer Rights Request” and a description of your request in the body of the email; or - Calling our toll-free number: 1 (877) 227-3631.

We will need to verify your identity before processing your request, which will require you to log into your account, if you have one, and may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems.

To Exercise Your Right to Opt Out of Personal Information Sales

To initiate your request to opt out of personal information sales, please click the link below to email us at data-privacy@takecareof.com with the subject line “California Opt-Out” or call us at our toll-free number: 1 (877) 227-3631. To the extent that our third-party advertising and analytics providers’ collection of information from users of our websites and other online services constitutes a “sale” under the CCPA, please refer to the ‘Third-Party Analytics & Advertising’ disclosures in the ‘Information We Collect and/or Receive’ section of our Privacy Notice for more information about the choices and opt-out options you have in relation to those practices. By visiting www.privacyrights.info, you can also opt out from “sales” of this type of personal information by businesses that participate in the DAA’s CCPA Opt-Out Tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.

Do Not Sell My Personal Information
Minors Under Age 16

We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at data-privacy@takecareof.com to inform us if you, or your minor child, are under the age of 16.

California’s “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. In order to facilitate these rights, we do not disclose personal information of California residents to third parties for their direct marketing purposes, as defined under California’s “Shine the Light” law, where the resident opts out of such sharing. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, please click the Do Not Sell My Personal Information link above to email us at data-privacy@takecareof.com with the subject line “California Opt-Out.”

PLEASE NOTE: To opt-out of all disclosures to third parties for direct marketing purposes, you must provide your personal information to be added to our suppression list.

Additional Information

Updates to This CA Notice

We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to data-privacy@takecareof.com with “California Privacy Notice” in the subject line.

Alternatively, inquiries may be addressed to:

NoHo Health Inc. 9 Great Jones St., Suite 4 New York, NY 10012