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ANCIENT BRANDS NOTICE OF COLLECTION OF PERSONAL INFORMATION AND PRIVACY POLICY UNDER THE CALIFORNIA PRIVACY RIGHTS ACT (CPRA)

Last Updated: December 30, 2022

Ancient Brands (“Ancient Nutrition” or the “Company”) is committed to maintaining the privacy and security of your personal information in compliance with California law and our Privacy Policy.

This Notice of Collection Of Personal Information and Privacy Policy (“CPRA Privacy Notice”) applies to the collection of personal information from California residents on and after January 1, 2023. This CPRA Privacy Notice supplements our “Privacy Policy” to provide California residents with information and rights required by the California Privacy Rights Act (“CPRA”).The Privacy Notice applies only to individuals residing in the State of California who are considered “consumers” under the CPRA and from whom we collect “personal information” as described in the CPRA.

This CPRA Privacy Notice describes the types and categories of personal information we collect, the business purposes for which we process, collect, use, store, disclose and share your personal information, with whom we share it, and your rights in personal information under the CPRA. We share your personal information with third party advertisers for cross-context behavioral advertising within the meaning of the CPRA (i.e., targeting of advertising based on personal information obtained across businesses, websites, applications or services, other than the Company’s website or services). We do not sell your personal information.

For purposes of this CPRA Privacy Notice, we refer to personal information according to the following definition given in the CPRA: “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that is de-identified or aggregate consumer information, or information or rights that are outside the scope of the CPRA.

By accessing our website or social media pages, submitting personal information to us, or purchasing our products or using our online services (collectively “Services”), you consent to the processing, collection, use, sharing and disclosure of such information as set forth in this CPRA Privacy Notice, as it may be updated from time to time. To opt out of sharing of your personal information with third parties, you may access our California Notice of Right to Opt Out of Sale or Sharinghttps://ancientnutrition.com/pages/cpra-opt-out

What categories of personal information do we collect about you?

We may collect personal information from you in various ways including:

● when you provide us with information (e.g., through your communications with us by email, chat or social media pages, or by answering our quiz);

● when you communicate with us concerning our Services;

● when you purchase our Services; and

● through automated means when you use our Site including by use of “cookies,” pixels and other similar tracking technologies.

We collect the following categories of personal information. This description also sets out personal information we have collected over the last twelve (12) months:

A. Identifiers.

Examples: This information may include your name and contact details (including mailing addresses, telephone numbers, email addresses, IP address, browser or device identifier, and other identifying information you provide to us). For example, we may collect your name and email address when you join our mailing list to receive information on our Services, to receive discounts, or establish an account.

Retention Period: Length of Customer relationship, plus six [6] years.

Share with Third Parties: Yes.

B. Customer Information under California Civil Code §1798.80(e).

Examples: This information comprises any information that identifies, relates to, describes or is reasonably capable of being associated with you or your household in our records. Examples include your orders and payment related information that we use to charge for our Services, including debit or credit card numbers. All debit or credit card transactions are securely processed by our debit or credit card processing payment vendors. We do not collect, store or maintain any credit card or debit card information on or through our website after the transaction is processed and verified. Instead, it is transiently collected, disclosed to and processed through these payment vendors using their platforms. Your credit or debit card information will be stored with our payment vendors if you elect certain Services so that we may periodically charge your card according to the Services you elected. We do not disclose your credit or debit card information with any vendors, other than our payment vendors. Some personal information in this category may overlap with other categories.

Retention Period: Length of Customer relationship, plus six [6] years.

Share with Third Parties: Yes.

C. Protected Characteristics under California or federal law.

Examples: This includes demographic information, such as age, race, gender or ethnicity, or information about your diet or health, that you may voluntarily provide to us.

Retention Period: Length of Customer relationship, plus six [6] years.

Share with Third Parties: No.

D. Commercial Information.

Examples: This category includes information concerning the Products or Services you purchased and your purchasing history and tendencies

Retention Period: Length of Customer relationship, plus six [6] years.

Share with Third Parties: Yes.

E. Internet and other electronic history.

Examples: This category comprises electronic information concerning your use of the website (www.ancientnutrition.com) and dependent pages (the “Site”). This information may include information we automatically collect as you browse the Site, including your IP address, device type or client/user identifier, browser type/identifier, operating system, pages visited, replays of your website session and other similar information. We may use services provided by third parties using third party cookies or tracking technology to provide us with information concerning your website activity and market products to you. We may collect information concerning your website usage through cookies.

Retention Period: Generally, for as long as one [1] year.

Share with Third Parties: Yes.

F. Geolocation data.

Examples: We may determine your approximate geographic location through your IP address.

Retention Period: Generally, for as long as one [1] year.

Share with Third Parties: Yes.

G. Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes.

Examples: We may accumulate the information you provide to develop a consumer profile concerning your behavior and interests, including for our marketing and advertising purposes, and to improve our Services.

Retention Period: Length of Customer relationship, plus six [6] years.

Share with Third Parties: Yes

We do not collect sensitive personal information for purposes of inferring characteristics.

Our Business Reasons For Collecting And Using Your Personal Information

Depending on the individual circumstances, we collect and use personal information for the legitimate business purposes of Ancient Nutrition. These purposes include to provide you with Services, to fulfill the purpose for which you provided us with your personal information, to communicate with you, to perform on a contract between you and the Company, to market our Services to you, to process payment and shipping and for account management, to improve the functionality and effectiveness of our Site, to protect the security of our Site, to protect against fraud, and to comply with applicable law, rules or regulations.

What are our categories of sources of personal information

The Company collects personal information from the following categories of sources:

● directly from you;

● service providers providing services on our behalf. We require our service providers who we provide your personal information to in order to provide services to maintain the privacy and security of your personal information; and

● third parties, including advertisers.

Who we disclose or share your personal information with

We do not sell your personal information to third parties.

We do share your personal information with third party advertising vendors for cross-contextual behavioral advertising purposes. We use information from cookies and tracking technologies (e.g., pixels, web beacons) in order to improve and customize your browsing experience, for analytics and metrics about your visits to our Site (e.g. the information concerning the length of your visit to our Site, where your visit originated from) and for marketing our Services to you. Other cookies are necessary for the Site to function properly or enhance the Site’s performance and functionality.

Third party advertising vendors use cookies and other technologies to serve ads based on your visits to the Site. Those third party cookies enable those advertisers to serve ads to our users based on previous visits to our Site and other sites on the Internet. These technologies are able to link your other Internet activity with our Site for purposes of providing you with advertising that you may be interested in.

By using our Site, you consent to the use of all cookies and tracking technologies. If you do not want your personal information shared for advertising purposes, including through third party cookies placed in your browser or other tracking technologies, please see our California Notice of Right to Opt Out of Sale or Sharing https://ancientnutrition.com/pages/cpra-opt-out

You may also be able permit or limit certain types of cookies by changing the settings on your browser. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept essential or functional cookies through your browser settings, the Site may not function properly and some features may not work as they were intended.

In some instances we may retain other companies and individuals to perform functions on our behalf as service providers or contractors, including, but not limited to, Information Technology and software providers, website analytics providers, shipping or direct mail organizations, credit and debit card processing companies, and e-commerce and web hosting platforms. Such service providers or contractors may be provided with access to your personal information to perform the functions for which they have been retained. We require our contractors and service providers, who provide services on our behalf (such as our e-commerce platform) to maintain the privacy and security of your personal information.

We may disclose any information, including personal information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, to protect ourselves from fraudulent or illegal activity, and to defend against legal claims.

In the past twelve (12) months, depending on the individual circumstances, we have shared the categories of personal information collected in Categories [A-B, D-G] with the following categories of third parties: advertisers.

In the past twelve (12) months, depending on the individual circumstances, we have not disclosed the categories of personal information collected in Categories [A-G] with outside organizations or entities who are not service provider or contractors providing services on our behalf.

Your rights regarding your personal information

Under the California Privacy Rights Act, you have the following rights in personal information held by us:

● You have the right to request that the Company disclose the personal information that the Company collects, uses, shares and discloses about you. You may “request to know”: (i) the categories of personal information that the Company has collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting or sharing your personal information; (iv) whether any categories of personal information were disclosed for a business purpose to third parties and the categories of third parties with whom the Company discloses your personal information; and (v) the specific pieces of personal information that the Company has collected about you. Your request may pertain to the personal information collected about you on or after January 1, 2022. If your request covers a time period beyond twelve [12] months from the date of your request, the Company may deny your request as to that time period where it would be impossible for the Company to provide you with the information or involve disproportionate effort. The Company may deny your request to search for certain information under certain circumstances (e.g., where the Company retains the information solely for legal and compliance purposes).

● You have the right under certain circumstances to receive specific pieces of your personal information in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine readable format that allows you to transmit the information to another entity.

● You have the right to correct inaccurate personal information.

● You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to complete the transaction for which the personal information was collected, perform on a contract with us, or to comply with a legal obligation. In addition, we may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a sale, disclosure, or commercial purpose.

● You have the right to know what information is shared with third parties, and to whom and to opt out of sharing for cross-context behavioral advertising. We do not sell your personal information.

● You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you or refuse to provide you Products or Services because you have exercised your rights.

You may submit verifiable requests concerning any of your rights by contacting us by e-mail to: privacy@ancientnutrition.com, by mail at the address below or by telephoning us at 855-949-0279. We will use reasonable methods for verifying that the person making a request to know, data portability, request to correct or a request to delete is the individual about whom we have collected personal information.

This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, you may be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.

We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten [10] business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five [45] calendar days of the request. If we need additional time to respond to your request beyond the forty-five [45] calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five [45] calendar days to respond to your request.

Reasonable Safeguards To Protect Your Personal Information

We are committed to maintaining the security of your personal information in compliance with all applicable laws and our policy. We take commercially reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction.

Access By Persons With Disabilities

Persons with disabilities who need assistance accessing this CPRA Privacy Notice may contact us as provided for above, and depending on your individual needs, the Company will grant reasonable requests to furnish this policy in an alternative format.

Children

Our Site is not intended for use by children under 16 years of age. No one under age 16 may provide any information to us through the Site. We do not knowingly collect or use personal information from children under 16 and have no actual knowledge that we sell or share the personal information of any children under 16 years of age. If you are under 16, do not access, use or provide any information on the Site or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us. We do not sell any personal information, including the personal information of minors under 16 years of age.

Notice of Financial Incentive to California Consumers

We may, at times, offer you various financial incentives such as loyalty programs, discounts and special offers when you provide us with contact information and identifiers such as your name and email address. When you sign-up for our loyalty program, email list or other discounts and special offers, you opt-in to a financial incentive. You may withdraw from a financial incentive at any time by opting out from our email or closing your loyalty member account. Generally, we do not assign monetary or other value to personal information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the personal information is related to the estimated cost of providing the associated financial incentive(s) for which the information was collected.

California Shine the Light Law/Online Privacy Protection Act

California Civil Code §1798.83 provides that California residents may request certain information concerning the disclosure of personal information to third parties for direct marketing purposes. Pursuant to California Business Code §§22575-22579, you may review and request changes to any of your personal information that we have collected. Should you wish to request this information or exercise these rights, please reach us at the contact information provided below.

If you permit us to share your personal information we are not responsible for third party tracking technologies that may be used on our Site. Such third parties may serve you content based on tracking you across different websites. You consent to potentially encountering third party tracking technologies when you use our Site.

Do Not Track Signals and Global Privacy Controls 

We recognize Do Not Track Signals and Global Privacy Controls associated with your browser. If your browser has these signals enabled, we will only lodge strictly necessary cookies if your browser permits those cookies.

Revisions to This CPRA Privacy Notice

We may update this CPRA Privacy Notice at any time, by posting the amended version on this Site including the effective date of the updated version. By accessing the Site or purchasing products after we make any such changes to this CPRA Privacy Notice, you are deemed to have accepted such changes. Please check this CPRA Privacy Notice regularly, and before you submit additional personal information via the Site.

Contact Us

If you have questions or comments regarding this CPRA Notice and Privacy Policy or if you would like to exercise your rights, please contact us at:

Mail: Ancient Nutrition, LLC Attn: Data Protection Officer Ancient Nutrition, LLC Attn: Data Protection Officer 3480 Summertown Hwy Summertown, TN 38483

Email: privacy@ancientnutrition.com

Telephone: 855-949-0279

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