Effective Date: Aug 25, 2021
Introduction and Overview
The Services include any services provided via this website, located at LIFEEN.com (the "Site" ), our mobile applications (the "Apps" ), our accounts and fan pages on social media platforms (the "Social Media Accounts" ), and any other websites, pages, features, or content owned and operated by the Company that hyperlink to this Policy.
The company selling the products via the Site and Apps and providing the Services (and therefore, the payment collection entity) is LIFEEN Distribution Corporation, acting as a joint controller of the information together with LIFEEN Ltd., . Therefore, the terms "Company", "we", "us" or "our" refer to different entities.
The Company is operating the Services and the sale of LIFEEN brand products, and therefore, is the controller of your personal data, and is also responsible for processing and protecting your personal data.
The joint controllers stated above have entered into a joint controller agreement, allocating the essential responsibilities as follows: LIFEEN Ltd. will be responsible for operating the Site and providing for its security. Lifeen Distribution Corporation will be responsible for using the Site in its respective territory to sell products to customers, collecting payment and processing returns. The joint controllership agreement is necessary because of the aforementioned separation of the technical and commercial levels, while at the same time processing your data is necessary for both companies, respectively, to provide you with the overall Services (consisting of both the sales and the Site and Apps).
Right to modify this Policy: We may change this Policy from time to time, to reflect how we are processing your data, and if we make changes, we will notify you by revising the effective date or last modified data at the top of this Policy. If we make significant changes that materially affect your privacy rights, we will provide advanced notice and make that clear on the LIFEEN website or other LIFEEN services, or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Services. Your continued access or use of our Services after receiving the notice of changes, constitutes your acknowledgement that you accept the updated Policy.
Instant information: In addition, we may provide you with real time disclosures or additional information about the personal information handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.
Click on the links below to go to a specific section of this Policy.
- 1. How We Collect and Use Your Personal Information >
- 2. Sharing Your Personal Information >
- 3. Cookies and Other Tracking Technologies >
- 4. Security Precautions >
- 5. Your Rights >
- 6. Retention >
- 7. Third-Party Websites >
- 8. Children >
- 9. Social Media Accounts >
- 10. Storage and Transfer of Your Personal Data >
- 11. California Privacy Rights >
- 12. Nevada Privacy Rights >
- 13. Contact Us >
1. How We Collect and Use Your Personal Information
We respect the privacy of the visitors to our digital properties and the users of our products and Services, and we are committed to protecting it through our compliance with this Policy. We collect personal information when you use our Services.
Personal Information does not include data that has been effectively irreversibly anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify you.
Your personal data is collected and used by us to support a range of different activities or business purposes. The purposes and types of information we collect are listed in the chart below, and should be understood to include uses of your personal data that are compatible with the purposes listed. In some jurisdictions, it is necessary to have an identified lawful basis of processing. To the extent such a requirement applies to the jurisdiction where you are a resident, the lawful basis for each processing purpose is indicated.
|Purpose||The Personal Data We Collect|
|To create an account with us and to manage your account, to provide you our Services;|
|To fulfill or process orders;|
|To provide customer service and support, or to provide you with service-related communications;|
|To undertake marketing, advertising or other promotional activities;|
|To improve our product or service, or for personalization;|
|To prevent and investigate fraud and other illegal activities;|
|To comply with legal or compliance requirements;|
Please note: When communicating with us by email or through forms on our Services, or when you publicly share content through our Services, we ask that you please do not send us any sensitive information pertaining to yourself or to others. We do not collect or store sensitive information or special categories of information.
2. Sharing Your Personal Information
We may disclose and share your personal information with the parties as described below.
- A.Within Our Corporate Organization . The Company is a part of a corporate organization that has several legal entities, business processes, management structures and technical systems. We may share your personal information to our related group companies and, in some cases, other affiliates of our corporate group for business maintenance and personalization continuity purposes, for instance so that you may enjoy a personalized user experience across our digital properties, to provide you with the Services, or to take actions based on your requests or preferences.
- B.Service Providers . We may share your personal information with the following types of third-party service providers as set out in the table below:
|IT system and software service provider||Website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, or system maintenance services.|
|Payment service provider||Third-party payment processing services.|
|Marketing and advertising services||Assistance in reaching potential new customers across multiple communications channels,or sharing with affiliated companies that promote our products on their websites.|
|Order fulfillment service provider||Provision of logistics, warehousing and distribution services, return and exchange services, and order status notification services for your purchased items.|
|Customer service provider||Assistance with customer services and support.|
|Fraud prevention and information security service provider||Identity verification, fraud prevention, or credit risk reduction services to protect our website/app and our business.|
|Other Service providers selected by you||Other third parties, such as size recommendations and fit prediction services providers, if you have chosen to help us provide you with product recommendations.|
- We strive to ensure that our third party service providers can only use your data for the purposes for which it was provided to them and to the extent necessary for such purposes, in accordance with our written instructions.
- C.To Maintain Legal and Regulatory Compliance . We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property or safety of the Company or our customers.
- E.Consent . We may disclose your personal information for any purpose with your consent.
- F.Corporate Transactions . We may disclose personal information—including account information, Wallet balance or points information—to a buyer, prospective buyer, corporate affiliate, or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which personal information held by us about our Services users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.
Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.
3. Cookies and Other Tracking Technologies
- A.Cookies . Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.
- Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
- We use the following types of cookies on our Services:
- Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
- Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
- Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.
- Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
- B.Your Choices . Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Services by taking the steps outlined below.
- First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org .
- Third-Party Cookies. If you wish to opt-in or opt-out of third-party advertising networks and similar entities that use advertising cookies, please click the "Manage Cookies" link in our website footer or visit https://www.aboutads.info/choices . For more information about third-party advertising networks and similar entities that use these technologies, please see https://www.aboutads.info/consumers . You may withdraw your consent or update your preferences at any time by clicking the "Manage Cookies" link within the Site footer or within the App menu.
- Mobile Applications. To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the Digital Advertising Alliance’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices .
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here: Google Chrome , Internet Explorer , Mozilla Firefox , Safari (Desktop) , Safari (Mobile) , Android Browser , Opera Mobile .
- C.Web Pixels . To see how successfully our marketing campaigns or other goals of the Services are performing we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g. a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.
- D.Analytics . We may use third-party service providers to monitor and analyze the use of our Services. Presently, we use Google Analytics . Google Analytics is a web analytics service that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en . Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout .
- E.Behavioral Remarketing . We also use remarketing services to advertise on third-party websites to you after you visited our Services. For this purpose, visitors are grouped by certain actions on our Services, e.g., by duration of a visit. This enables us to understand your preferences and to show you personalized advertising even if you are currently surfing on another website that also participates in the same advertising network. We utilize Google Ads, Bing Ads, and similar ad networks.
- Using Facebook Business Tools , we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences in addition to the Your Choices section below. We do not share any of your personal information with Facebook. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the "lookalike" audience, unless they choose to click on one of our advertisements.
- F.Other Tracking Technologies . We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
- Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or "cached" within your browser to store and retrieve data in HTML5 pages when the website is revisited.
- G.Do Not Track . Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Site does not currently process or respond to "DNT" signals.
- H.Location Information . You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.
4. Security Precautions
We maintain physical, electronic, and procedural safeguards designed to guard and prevent misuse of your personal information. Our security measures include industry-standard physical, technical and administrative measures to prevent unauthorized access to or disclosure of your information.
The Internet is not an absolutely secure environment. We strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account. We also strongly advise that you neither share your password with others nor re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of a credential stuffing attack or other malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us at our dedicated Privacy Center or as otherwise described in the "Contact Us" section below.
5. Your Rights
As explained in the "Overview" section above, the provider of Services varies depending on your country of residence when accessing and using the Services. The joint controllers have entered into a joint controller agreement, allocating the essential responsibilities as follows: will be responsible for operating the Site and providing for its security. Lifeen Distribution Corporation will be responsible for using the Site in its respective territory to sell products to customers, collecting payment and processing returns. The joint controllership agreement is necessary because of the aforementioned separation of the technical and commercial levels, while at the same time processing your data is necessary for both companies to provide you with the overall Services (consisting of both the sales and the Site and Apps).
We attach great importance to your attention to personal information, and do our best to protect your rights to access, correct, delete, cancel your account, and withdraw your consent to our processing your personal information, so that you have the full ability to protect your privacy and security. To exercise your rights, you may contact us at our dedicated Privacy Center (see section 13).
5.1 Access, Correction and Deletion of your Personal Information. You have the right to access, correct, or delete the personal information that we collect. To protect the privacy and the security of your personal information, we may request data from you to enable us to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. To exercise your rights, you may make updates within your customer account on the Site or App, or you may contact us our dedicated Privacy Center . We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
5.2 Unsubscribe from Our Marketing Communications. If you do not want us to use your email account to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you or contact us at our dedicated Privacy Center .
5.3 Lodging Complaints. If you believe we have infringed or violated your privacy rights, please contact us at our dedicated Privacy Center so that we may attempt to resolve any issues to your satisfaction.
We will retain your personal information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
If you no longer wish to be our customer, or cease using or accessing our Services, you can request us to close your account and delete all personal information we hold about you via Privacy Center (See section 13), subject to certain legal requirements.
If you send us correspondence, including emails, we retain such information electronically in the records of your account. We will also electronically retain customer service correspondence and other correspondence from us to you. We retain these records to measure and improve our customer service and to investigate potential fraud and violations. We may, over time, delete these records as permitted by law.
We will also retain Services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods.
7. Third-Party Websites
Our Apps or Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.
Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16 or minors (as defined by applicable national laws). If you are a minor, please do not attempt to fill out our forms or send any personal information about yourself to us. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us (See section 13) immediately to remove the relevant personal information and unsubscribe the minor.
If we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our files. As described further in our Terms and Conditions , please do not upload photographs showing other people, in particular if they are minors.
9. Social Media Accounts
We operate accounts and fan pages on different social media platforms (the "Social Media Accounts" ).
If you visit one of our Social Media Accounts you initiate a variety of data processing operations. Below we identify the other types of entities with whom you may interact when you visit one of our Social Media Accounts. If you do not provide us with your personal data, certain functionalities of the social networking platforms requiring such data will not be available to you or only to a limited extent.
As the owner of a Social Media Account, we can usually only see information stored in your public profile on such social media platform, and only insofar as you are logged in to your profile while visiting our Social Media Account. In addition, we may process data that you provide to us when you contact us through one of our Social Media Accounts (for example: if you create a post, or send us a private message via Facebook). If you visit one of our Social Media Accounts, the operator of the respective social network also processes your data, regardless of whether you yourself have a profile in the respective social network. The individual data processing operations and their scope differ depending on the operator.
In addition, the respective operator of the social network provides us with anonymous usage statistics, which we use to improve the user experience. We do not have access to the usage data that the operator of the social network collects to create these statistics. These data processing operations serve our legitimate interest in improving the user experience when visiting our profile in line with the target group.
You can withdraw your consent at any time with future effect and free of charge.
10. Storage and Transfer of Your Personal Data.
11. California Privacy Rights
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, as amended and pursuant to its regulations and successors (together, “CCPA”), below is a summary for the last twelve (12) months of the personal information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the personal information, where we obtain the personal information, and the third parties with whom we may share the personal information.
We generally collect the following categories of personal information when you use our Services:
- identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, and non-directly identifiable alphanumerical numbers associated with your devices;
- commercial information such as records of products or services purchased, obtained, or considered by you;
- Internet or other electronic information regarding your browsing activity, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
- audio recordings of your voice to the extent you call us, as permitted under applicable law;
- employment-related information; and
- inferences about your preferences, characteristics, behavior and attitudes.
We generally do not collect protected classifications about our users, biometric information, or education-related information. For more information about the personal information we collect and the purposes for which we use it, please refer to section 1 above.
The categories of third parties with whom we may share your personal information are listed above in section 2.
If you are a California resident, you have rights in relation to your personal information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our network systems. To assert your right to know or your right to delete your personal information, please see the "Contact Us" section below. To confirm your identity, we may ask you to verify personal information we already have on file for you or other documentation that verifies that you are whom you claim to be. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
- Right Against Discrimination . You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
- Right to Know . You have the right to request in writing a list of the information we have collected or disclosed about you, the business purposes involved, and the sources of such information. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.
- Right to Delete . You have the right to request that we delete any personal information we have collected from you or maintain about you, subject to certain exceptions.
- Right to Opt-Out of Selling . You have the right to opt-out of having your personal information sold. We do not sell your personal information as that term is generally understood but we recognize that the CCPA defines "personal information" in such a way that making available identifiers linked to you for a benefit may be considered a "sale." The CCPA broadly defines “personal information” and "selling" such that making available or sharing identifiers linked to you for a benefit may be considered a sale. In the previous 12 months, we were sharing identifiers and inferences about you with our partners, third parties and affiliates in such a way that, under the CCPA, may be defined as selling. Please see the "Cookies and Other Tracking Technologies" section above for a description of opting out of cookies and controlling browser settings, in addition to clicking the "Manage Cookies" link in our website footer to load a consent tool that will allow you to opt-out of the cookies on our Site.
- Use of an Authorized Agent to Submit a Request . Only you or a person you formally authorize to act on your behalf may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.
In addition, California Civil Code Section 1798.83 permits customers who are California residents to request certain information regarding our disclosure of personal information to third-parties for their direct marketing purposes. In your request, please specify that you want a "California Shine the Light Notice." Please contact us as described below and allow 30 days for a response.
12. Nevada Privacy Rights
This section applies only to Nevada residents. Although we do not "sell" "covered information" of Nevada "consumers" as those terms are defined by Chapter 603A of the
Nevada Revised Statutes, if you are a Nevada consumer, please go to our Privacy Center and inform us that you would like us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law.
You may contact us as described below. It is your responsibility to keep your notice contact information current.
13. Contact Us
You can also contact us via our customer service Platform on our Site.