Privacy policy.
Advanced Nutrition and Emotional Wellness (“ANEW”) respects the privacy of its users. ANEW uses data collection tools to enhance security, site functionality, performance, advertising, or user experience. The following Privacy Policy covers how ANEW collects, uses, and shares user data.
Unless ANEW links to a different policy or states otherwise, this Privacy Policy applies when users visit or use the ANEW websites, mobile applications, APIs, or related services (the “Services”). It also applies to prospective purchasers and users of ANEW products.
For purposes of this policy, the term “Users” includes individuals or entities that either visit or use the Services.
By using the Services, users agree to the terms of this Privacy Policy. Users should refrain from accessing ANEW websites and Services if they do not agree with this Privacy Policy or any other agreement that governs the use of the Services or purchase of ANEW products.
1. Type of Data Collected
ANEW collects data about user engagement in order to further its commercial goals and quality standards, perform its contractual obligations, and protect its interests (such as payment facilitation, fraud prevention and security, and compliance). Data collected is categorized, recorded, structured, stored, altered, retrieved, encrypted, pseudonymized, erased, combined, and transmitted. ANEW may collect different data from or about users depending on how users use the Services and products. The sources of the data collected include devices used to access the Services, as well as data from third-party platforms that connect with ANEW.
1.1 Data Provided
ANEW collects and uses information associated with a user account to operate and deliver products and services users have requested. ANEW may also use personally identifiable information to inform users of other products or services available from ANEW or its affiliates.
When users create an account and use the Services, including through a third-party platform, ANEW collects any data users provide directly, including names, addresses, phone numbers, dates of birth, email addresses, passwords, and credit card information.
ANEW does not collect any personal information about users unless users voluntarily provide it. Users may be required to provide certain personal information when users elect to use certain products or services. These may include: (a) registering for an account; (b) participating in an activity sponsored by ANEW, its affiliates, or its partners; (c) signing up for special offers from selected third parties; (d) sending ANEW an email message; (e) submitting credit card or other payment information when ordering and purchasing products and services. ANEW will use information for, but not limited to, communicating with users in relation to services and/or products users have requested. ANEW may also gather additional personal or non-personal information in the future.
ANEW may invite users to complete a survey or participate in a promotion (like a contest, sweepstakes, or challenge), either through the Services or a third-party platform. If users participate, ANEW will collect and store the data users provide. That data is subject to this Privacy Policy unless otherwise stated in the official rules of the promotion or in another privacy policy. The data collected will be used to administer the promotion or survey, such as for notifying winners and distributing rewards. To receive a reward, users may be required to allow ANEW to post user information publicly (like on a winner’s page). Where ANEW uses a third-party platform to administer a survey or promotion, the third party’s privacy policy will apply.
If users contact ANEW for support or to report a problem or concern (regardless of whether users have created an account), ANEW collects and stores user contact information, messages, and other data about users like user name, email address, messages, location, ANEW user ID, refund transaction IDs, and any other data users provide or that ANEW collect through automated means (which ANEW cover below). ANEW uses this data to respond to users and research user questions or concerns, in accordance with this Privacy Policy.
1.2 Data Collected through Automated Means
When users access the Services (including browsing content), ANEW collects data by automated means, including:
Technical data about user computer or device, like user IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain and other systems data, and platform types.
Usage statistics about user interactions with the Services, including content accessed, time spent on pages or the Service, pages visited, features used, user search queries, click data, date and time, referrer, and other data regarding user use of the Services.
An approximate geographic location, including information like country, city, and geographic coordinates, calculated based on user IP address.
The data listed above is collected through the use of server log files and tracking technologies and stored in association with the user account.
ANEW and service providers acting on its behalf (such as Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons when users access and use the Services. These tools automatically track and collect certain data when users use the Services. In some cases, ANEW ties data gathered through data collection tools to other data that ANEW collects.
ANEW may keep track of the websites and pages users visit, in order to determine what services are the most popular. This data is used to (a) deliver customized content and advertising to customers whose behavior indicates that they are interested in a particular subject area, (b) to maintain the quality of the Services, and (c) to provide statistical feedback regarding the use of the websites.
2. Use of Data
ANEW uses user data to
communicate with users,
troubleshoot issues,
secure against fraud and abuse,
improve and update Services,
analyze how users interact with Services,
personalize advertising,
comply with law or safety and integrity requirements.
process user requests and purchase orders for educational content, products, specific services, information, or features; and
provide and administer the Services, including to facilitate participation in educational content, issue completion certificates, display customized content.
ANEW retains user data for as long as it is needed to serve the purposes for which it was collected.
Based on this data, ANEW may, from time to time, contact users on behalf of external business partners about a particular offering that may be of interest to users.
2.1 Sharing Information with Third Parities
ANEW does not sell, rent, or lease its customer lists to third parties.
ANEW may share data with trusted partners to help perform statistical analysis, send users email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using personal information except to provide these services to ANEW and its affiliates, and they are required to maintain the confidentiality of information.
ANEW shares data about users with companies performing services, ANEW affiliates, business partners, analytics and data enrichment providers, user social media providers, companies helping run promotions and surveys, and advertising companies who help promote the Services. ANEW can share data in other ways if it is aggregated or de-identified or if ANEW obtains user consent. Furthermore, ANEW may also share user data as needed for security, legal compliance, or as part of a corporate restructuring.
ANEW may disclose personal information without notice, if required to do so by law or in its good faith belief that such action is:
reasonably necessary as part of a valid subpoena, warrant, or other legally valid request;
requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
reasonably necessary to assess disclosure obligations and rights under this Privacy Policy;
reasonably necessary to enforce the Terms of Use, Privacy Policy, and other legal agreements;
required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
reasonably necessary in discretion to protect against imminent harm to the rights, property, or safety of ANEW, users, employees, members of the public, or Services.
If ANEW undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, ANEW may share, disclose, or transfer all of user data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
ANEW may disclose or use aggregated or de-identified data for any purpose.
With user consent, ANEW may share data to third parties outside the scope of this Privacy Policy.
3. User Rights
Users have certain rights around the use of user data, including the ability to opt out of promotional emails, cookies, and collection of user data by certain third parties. Users can update or terminate the user account from within Services and can also contact ANEW for individual rights requests about user personal data. Parents who believe ANEW unintentionally collected personal data about their underage child should contact ANEW for help deleting that information. Users can choose not to provide certain data, but users may not be able to use certain features of the Services.
If users have any questions about user data, use of it, or user rights, please contact ANEW at connect@anew-insight.com.
3.1 Accessing, Updating, and Deleting User Personal Data
Users can access data that they provide directly by logging into their user account and update the information at any time.
Users can also request to view, correct, or delete user personal data by emailing connect@anew-insight.com with the request in the body of the message.
Please allow up to 30 days for a response. For user protection, ANEW may require that the request be sent through the email address associated with the user account, and ANEW may need to verify user identity before implementing user request. Please note, ANEW retains certain data where ANEW has a lawful basis to do so, including for mandatory record-keeping and to complete transactions.
To terminate the user account, please email: connect@anew-insight.com with “Terminate User Account” in the subject line. For user protection and verification, ANEW requires that the request be sent through the email address associated with the user account, and ANEW may need to verify users and/or user agent’s identity before fulfilling user request.
Subject to certain exceptions set out below, on receipt of a verifiable request from a user, ANEW will delete personal information from records and direct any service providers to delete personal information from their records.
Please note that ANEW may not be able to comply with requests to delete personal information if it is necessary to:
complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with law, provide a good or service requested by user, or reasonably anticipated within the context of an ongoing business relationship, or otherwise perform a contract between users and ANEW or its affiliates;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or present those responsible for that activity;
identify and repair errors that impair existing intended functionality;
exercise or ensure a right provided for by law;
comply with the California Electronic Communications Privacy Act;
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when ANEW’s deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided ANEW has obtained informed consent;
enable internal uses that are reasonably aligned with expectations based on relationship with ANEW or its affiliates;
comply with an existing legal obligation; or
otherwise use personal information, internally, in a lawful manner that is compatible with the context in which users provided the information.
Even after the user account is terminated, ANEW retains user data for as long as ANEW have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce agreements. ANEW may retain and disclose such data pursuant to this Privacy Policy after the user account has been terminated.
3.2 Opt-Out of Disclosure of Personal Information to Third Parties
In connection with any personal information ANEW may disclose to a third party for a business purpose, users have the right to know the categories of personal information that ANEW has disclosed about users for a business purpose.
Users have the right under the California Consumer Privacy Ad of.2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the disclosure of personal information. If users exercise the right to opt-out of the disclosure of personal information, ANEW will refrain from disclosing personal information, unless users subsequently provide express authorization for the disclosure of personal information. In order to opt out of the disclosure of personal information, please email connect@anew-insight.com.
3.3 Opt-Out & Unsubscribe from Third Party Communications
ANEW respects privacy and gives users an opportunity to opt-out of receiving announcements of certain information.
To stop receiving promotional communications from third-party partners of ANEW, users can submit a request to opt out by emailing connect@anew-insight.com.
To stop receiving promotional communications from ANEW, users can opt out by using the unsubscribe mechanism in the promotional communication users receive or by changing the email preferences in the user account.
To stop receiving in-app tailored advertising on their devices, browsers, and operating systems, users should review user privacy settings for their platform. Apple iOS, Android OS, and Microsoft Windows OS each provide their own instructions on how to control in-app advertising.
Please note that regardless of user email preference settings, ANEW will send users transactional and relationship messages regarding the Services, including administrative confirmations, order confirmations, important updates about the Services, and notices about policies.
3.4 Policy Concerning Children
ANEW recognizes the privacy interests of children and encourages parents and guardians to take an active role in their children’s online activities and interests. ANEW does not knowingly collect personally identifiable information from children under the age of consent in their jurisdiction to use online services (for example, the age of 13 in the United States). Individuals younger than the required age of consent may not use the Services. If ANEW learns that personal data from a child under those ages has been collected, ANEW will take reasonable steps to delete it. Parents who believe that ANEW may have collected personal data from a child under those ages can submit a request that it be removed to connect@anew-insight.com.
4. Data Security
ANEW takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of user personal data that ANEW collects and stores. These measures vary based on the type and sensitivity of the data. However, no system can be 100% secured. ANEW cannot guarantee that the Services, communications between users and ANEW, or any information collected by ANEW will be free from unauthorized access by third parties.
User password is an important part of security system, and it is the user’s responsibility to protect it. To minimize the risk of unauthorized access, users should take all reasonable measures to protect their password, including not sharing it with any third party. If users believe their password or account has been compromised or suspect any unauthorized access, users should change their password immediately and contact connect@anew-insight.com with any concerns.
5. Jurisdiction-Specific Rules
5.1 Users in California
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”). If users are an eligible California user, included in these rights are:
“Right to Know” — Users have the right to request to know more about the categories and specific pieces of personal information that ANEW have collected about users and access a copy of user personal information.
“Right to Correction” — Users have the right to have inaccurate personal information about users corrected.
“Right to Deletion” — Users have the right to request deletion of personal information that ANEW have collected about users.
“Right to Non-Discrimination” — If users choose to exercise any of user rights under CCPA, ANEW will treat users like all other users. In other words, there is no penalty for exercising user rights under CCPA.
“Right to Opt-Out” – Users have the right to opt out of the sale of user personal information.
CCPA has a specific definition of a “sale” and while ANEW does not, in the traditional sense, sell user personal information or the personal information of any user, ANEW do use cookies that make non-personally identifiable information available to select third-parties. To opt out of such a “sale” or to exercise any of these rights under CCPA, please email connect@anew-insight.com with “My Rights Under CCPA” in the subject line and the applicable request in the body of the email. CCPA allows users to designate an authorized agent to make these requests on user behalf. For user protection and verification, ANEW requires that the request be sent through the email address associated with the user account, and ANEW may need to verify users and/or user agent’s identity before fulfilling user request.
As a California resident, users also have the right to request certain details about what personal information ANEW shares with third parties for those third parties’ direct marketing purposes. To submit a request, users should send an email to connect@anew-insight.com with “California Shine the Light” in the subject line and include user mailing and residential address, including state of residence.
Since there is no widely accepted standard for the browser-initiated Do Not Track signal, ANEW do not currently recognize or respond to Do Not Track signals.
5.2 Users in Nevada
ANEW does not sell its users’ personal information or personal data. Nonetheless, Nevada residents have the right to request that ANEW not sell user’s personal information. To submit a request, users should send an email to connect@anew-insight.com with “Nevada Resident: Do Not Sell My Personal Information” in the subject line. For user protection and verification, ANEW requires that the request be sent through the email address associated with the user account.
5.3 Users outside of the United States
Users outside of the United States should note that in order to provide the Services to users, ANEW, its affiliates, its business partners, and its service providers, process user data and transactions, facilitates payments, and provides support services in and from the United States.
By submitting user data or using Services, each user consents to the transfer, storage, and processing by ANEW and its service providers of user data in and to the United States or other countries.
If users live in Australia, users have the right to make a formal complaint to the office of the Australian Information Commissioner (“OAIC”). Users can contact OAIC by visiting www.oaic.gov.au; forwarding an email to enquiries@oaic.gov.au; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001. Users may contact ANEW at connect@anew-insight.com to make a complaint about a breach of the Australian Privacy Principles which will be responded to within 30 days.
If users are located in the EEA or UK, users have the right to request access to user data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of user personal data. Users may request the information via an email to connect@anew-insight.com with the specifics of their request in the body of the message. Additionally, if users are located in the EEA, UK, or Switzerland, users also have the right to lodge a complaint with applicable supervisory authority.
For user protection, ANEW may require that the request be sent through the email address associated with the user account, and ANEW may need to verify users and/or user agent’s identity before fulfilling user request.
6. Updates & Contact Info
When ANEW makes a material change to this policy, ANEW will notify users via email, in-product notice, or another method required by law. Changes become effective the day they are posted.
6.1 Modifications to This Privacy Policy
From time to time, ANEW may update this Privacy Policy. If ANEW makes any material change to it, ANEW will notify users via email, through a notification posted on the Services, or as required by applicable law. ANEW will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.
As permitted by applicable law, if users continue to use the Services after the effective date of any change, then user access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.
6.2 Interpretation
Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, users agree that the English language version will control.
6.3 Questions & Contact Information
If users have any questions, concerns, or comments regarding this Privacy Policy, please feel free to contact: connect@anew-insight.com.