Privacy Policy

Last Updated: November 12, 2025

1. Information We Collect

1.1 Personal Information

We collect the following categories of personal information:

• Identifiers: Name, email address, postal address, telephone number, IP address, and unique identifiers
• Protected Classifications: Age, date of birth, and health information (when voluntarily provided)
• Commercial Information: Records of products or services purchased, obtained, or considered
• Internet Activity: Browsing history, search history, and interaction with our website or applications
• Geolocation Data: Physical location information
• Professional Information: Current or past employment information (if provided)
• Health Information: Health conditions, medical history, and wellness data you choose to share
• Inferences: Preferences, characteristics, and behavioral tendencies drawn from your information

1.2 Sensitive Personal Information (CPRA)

We may collect sensitive personal information including:

• Health and medical information related to our services
• Precise geolocation data (with your consent)
• Account login credentials (encrypted)

1.3 How We Collect Information

We collect information through:

• Direct interactions (forms, emails, phone calls, chat)
• Automated technologies (cookies, web beacons, analytics tools)
• Third-party sources (service providers, business partners)
• Public sources (when applicable and lawful)

2. How We Use Your Information

We use your personal information for the following business and commercial purposes:

2.1 Service Delivery

• Providing digital health products and services
• Creating and managing your account
• Processing orders and transactions
• Delivering customer support and responding to inquiries
• Personalizing your health and wellness programs

2.2 Business Operations

• Improving our services and developing new features
• Conducting research and analytics
• Detecting and preventing fraud and security threats
• Maintaining and troubleshooting technical issues
• Enforcing our Terms of Service and legal obligations

2.3 Marketing and Communications

• Sending promotional materials and newsletters (with consent)
• Conducting surveys and market research
• Providing updates about our services
• Displaying personalized content and advertisements

2.4 Legal Compliance

• Complying with applicable laws and regulations
• Responding to legal requests and court orders
• Protecting our rights, property, and safety

3. Legal Basis for Processing (UK GDPR)

Under UK GDPR, we process your personal data based on:

• Consent: You have given clear consent for processing for specific purposes
• Contract: Processing is necessary to fulfill our contractual obligations
• Legal Obligation: Processing is necessary to comply with the law
• Vital Interests: Processing is necessary to protect someone's life
• Legitimate Interests: Processing is necessary for our legitimate interests (fraud prevention, improving services)

4. Disclosure of Your Information

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• Cloud storage and hosting providers
• Payment processors
• Email and communication service providers
• Analytics and data analysis services
• Customer support tools
• Marketing and advertising platforms

4.2 Business Partners

We may share information with healthcare providers, wellness professionals, and other partners who help deliver our services (with your consent).

4.3 Legal Requirements

We may disclose your information when required by law, regulation, legal process, or governmental request.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4.5 With Your Consent

We may share your information for other purposes with your explicit consent.

5. Your Privacy Rights

5.1 CCPA/CPRA Rights (California Residents)

If you are a California resident, you have the following rights:

• Right to Know: Request information about the categories and specific pieces of personal information we collect, use, and disclose
• Right to Delete: Request deletion of your personal information (subject to certain exceptions)
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: Opt-out of the sale or sharing of personal information for cross-context behavioral advertising
• Right to Limit: Limit the use and disclosure of sensitive personal information
• Right to Non-Discrimination: Exercise your rights without discriminatory treatment
• Right to Data Portability: Receive your personal information in a portable format

5.2 UK GDPR Rights (UK Residents)

If you are in the United Kingdom, you have the following rights:

• Right of Access: Obtain confirmation of data processing and access to your personal data
• Right to Rectification: Correct inaccurate or incomplete personal data
• Right to Erasure: Request deletion of personal data ("right to be forgotten")
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a structured, commonly used format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Rights Related to Automated Decision-Making: Not be subject to decisions based solely on automated processing
• Right to Withdraw Consent: Withdraw consent at any time (where processing is based on consent)
• Right to Lodge a Complaint: File a complaint with the Information Commissioner's Office (ICO)

5.3 PIPEDA Rights (Canadian Residents)

If you are in Canada, you have the following rights:

• Right to Access: Request access to your personal information we hold
• Right to Correction: Request correction of inaccurate personal information
• Right to Withdraw Consent: Withdraw consent for collection, use, or disclosure (subject to legal or contractual restrictions)
• Right to Challenge Compliance: Challenge our compliance with PIPEDA
• Right to File a Complaint: Lodge a complaint with the Office of the Privacy Commissioner of Canada

6. How to Exercise Your Rights

7. Data Retention

We retain your personal information for as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy
• Comply with legal, accounting, or reporting requirements
• Resolve disputes and enforce our agreements
• Maintain records for legitimate business purposes

Retention Periods:

• Account information: Duration of account plus 7 years
• Transaction records: 7 years from transaction date
• Health data: As required by applicable healthcare laws
• Marketing data: Until you opt-out or withdraw consent
• Technical data: 2 years from collection

8. Data Security

We implement appropriate technical and organizational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Employee training on data protection
• Incident response and breach notification procedures
• Regular backups and disaster recovery plans

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

9. International Data Transfers

9.1 UK GDPR Transfers

If we transfer your data outside the UK, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the UK ICO
• Adequacy decisions by the UK government
• Binding Corporate Rules (BCRs) where applicable

9.2 PIPEDA Cross-Border Transfers

When we transfer personal information outside Canada, we ensure the receiving jurisdiction provides comparable privacy protection or obtain your consent.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and user behavior
• Personalize content and advertisements
• Improve website functionality

Cookie Types:

• Essential Cookies: Required for website operation
• Performance Cookies: Collect anonymous usage data
• Functional Cookies: Remember your preferences
• Advertising Cookies: Deliver relevant advertisements

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

11. Children's Privacy

Our services are designed for adults aged 18 and older. We do not knowingly collect personal information from children under 18 (or the applicable age in your jurisdiction). If we learn we have collected information from a child, we will delete it promptly.

12. Do Not Sell or Share My Personal Information

We do not sell personal information as defined by CCPA/CPRA. We may share information for cross-context behavioral advertising. You have the right to opt-out of such sharing.

To Opt-Out:

• Click the "Do Not Sell or Share My Personal Information" link on our website footer
• Email privacy@clicktron.com with "Opt-Out" in the subject line
• Use the Global Privacy Control (GPC) signal in your browser

13. Automated Decision-Making

We may use automated decision-making, including profiling, to:

• Personalize health and wellness recommendations
• Detect fraud and security threats
• Improve service delivery

Under UK GDPR, you have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. You may request human review of such decisions.

14. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws. We will notify you of material changes by:

• Posting the updated policy on our website
• Updating the "Last Updated" date
• Sending email notifications (for significant changes)
• Obtaining fresh consent where required by law

15. Contact Information

16. State-Specific Disclosures

16.1 California Residents

Categories of Information Collected (Last 12 Months): See Section 1

Sources of Information: See Section 1.3

Business Purposes: See Section 2

Categories Disclosed: See Section 4

Sale/Sharing: We do not sell personal information. We may share for advertising purposes (opt-out available).

Retention: See Section 7

Shine the Light Law: California residents may request information about disclosure of personal information to third parties for direct marketing purposes once per year.

16.2 Other U.S. States

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have additional rights similar to those outlined above. Contact us to exercise your rights.

17. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you require this policy in an alternative format, please contact privacy@clicktron.com.

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This Privacy Policy is effective as of the date listed above and supersedes all previous versions.