Privacy Policy

Last updated: March 21, 2024

Thank you for your interest in New Chapter, Inc. (d/b/a New Chapter, Inc. and LifeShield), a Vermont-based company. This Privacy Policy sets forth the terms and conditions with respect to how New Chapter and its affiliated brands, including LifeShield, (collectively, the “Company,” “we” or “us”) each process personal information about you and other third parties.

For the avoidance of doubt, this Privacy Policy applies to the processing of personal information on the following websites:

New Chapter LifeShield

This Privacy Policy describes, among other issues, the types of personal information that we collect, the purposes for which we use it, the types of third parties with whom we share it, and any rights and responsibilities you may have with respect to such personal information.

This Privacy Policy applies to the personal information you provide us when you visit any website that we own, license, or otherwise operate and that links to this Privacy Policy (each, a “Site”), purchase or receive products, goods, or services from the Company, apply for a job with the Company, or otherwise contact or engage with us. For purposes of this Privacy Policy, the Site and all products, goods and services furnished by the Company shall be referred to collectively as the “Services.”

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT DESCRIBES YOUR RIGHTS, RESPONSIBILITIES, AND LIABILITIES. BY ACCESSING OR USING THE SERVICES OR OTHERWISE PROVIDING US WITH PERSONAL INFORMATION, YOU ARE CONSENTING TO THE TERMS OF THIS PRIVACY POLICY, COMPANY TERMS AND CONDITIONS, THE CONSUMER HEALTH DATA PRIVACY POLICY, AND COOKIE POLICY, EACH BEING INCORPORATED INTO, AND FORMING AND FORMING AN INTEGRAL PART OF, THIS PRIVACY POLICY.

This Site may only be used by individuals who are at least eighteen (18) years of age and who are located in the United States of America. If you are not eighteen (18) years of age and you are not located in the United States of America, you are prohibited from using this Site.

Please click on the cookie management tool (sometimes referred to as a “Do Not Sell or Share My Personal Information” link) on the footer of the Site to set your preferences for how our Site uses cookies, pixels, tags, and similar online tools. See our Cookie Policy for more information on how our Site uses such online tools.

This Privacy Policy applies to personal information that the Company receives during its business operations as a “data controller” - which means we determine the purpose and means of processing such personal information. For purposes of this Privacy Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual, household, or device and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual, household, or device and that is not otherwise subject to a data protection law, statute, or regulation. The Company may anonymize or de-identify personal information, and such data is not subject to this Privacy Policy, and the Company may use such data for any purpose.

The Company collects personal information in order to provide our Services, comply with our legal obligations, promote our business interests, and for the other reasons set forth in this Privacy Policy. When you do not provide personal information to the Company, we may not be able to provide you the Services or to complete a transaction you requested. Generally, we collect the following types and categories of personal information during our business operations:

When you access the Site, we collect certain data automatically using technical means and tools. This data relates to your device, and your experience on the Site and other websites, including the following:

Usage and Device Data. When you access and use the Site, we automatically collect details of your access to and use of the Site, including traffic data, usage logs and other communication data, and the resources that you access and use on or through the Site (e.g., browsing history, search history). We may also collect information about your device and internet connection, including the device’s unique identifier (e.g., device type, IMEI, Wi-Fi MAC, IP address), operating system, browser type, and mobile network information. The Site may collect “diagnostic” data related to your use of the Site, such as crash data and logs, performance data (e.g., launch time, hang rate, or energy use), and any other data collected for the purposes of measuring technical diagnostics.

Cookies and Tracking Data. We use “cookies” and other tracking technologies within the Site. A cookie is a small file placed on your smartphone or other device. It may be possible to refuse to accept cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting, some parts of the Site may become inaccessible or not function properly. In addition, the Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to analyze data on your use of the Site (e.g., recording the popularity of certain content and verifying system and server integrity). The Site may collect data about the advertisements you have seen or engaged. From time to time, we may use on our Site certain third-party cookies and pixels provided by our marketing partners, including social media companies. To the extent we use such third-party cookies and pixels, you hereby agree to the terms and conditions set forth by those third parties, which may include Meta, X (formerly Twitter), TikTok, and LinkedIn, among others. For more information, see our Cookie Policy, available on the footer of our Site.

Site Monitoring. Please be aware that we use cookies and other tracking technologies within the Site to monitor and record any and all activities and communications to, from, and on, the Site in order to safeguard, improve, and analyze usage of, the Site, and for the other purposes listed in this Privacy Policy. For the avoidance of doubt, you hereby acknowledge, agree, and consent to, such monitoring and recording.

We collect the personal information identified herein directly from you when you use our Services, through automated means when you are using the Site, and from third parties. More specifically, we collect personal information from the following sources:

First Party / Direct Collection. We collect personal information directly from you when you use our Services (e.g., account registration, completing purchases, signing-up for subscriptions), when you provide a Product Review (as defined below), or whenever you directly engage with us, such as when you visit our offices or premises or otherwise contact us.

Automated Collection. As described above, we may collect information and data, such as usage data and cookies, through automated means when you use the Site (see “Technical Data” above).

Third-Party Sources. We collect personal information from third parties, such as publicly available databases, social networking providers, advertising companies, our service providers, employment recruiters, and third-party references.

We may share your personal information with certain organizations and third parties in accordance with applicable law, including as set out below. However, we do not share personal information with third parties that we have reason to believe use such information for their own direct marketing purposes.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contacts us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

IntraGroup. Please note that the Company may share your personal information between the different Company brands for business development purposes. More specifically, New Chapter and LifeShield are one “business” for the purposes of collecting and disclosing personal information.

Service Providers. We may share your personal information with companies that provide services on our behalf, such as hosting and analyzing the Site, conducting surveys and marketing on our behalf, processing transactions (including rebates and returns), tracking and responding to consumer questions or complaints, and performing analyses to improve the quality of our Services.

Payment Card Transactions. All payments for purchases made through the Site are completed using a third-party vendor’s online payment system. The Company does not have access to your credit card information and does not store or disclose your full credit card information. Any personal or financial information you provide to our online payment system is subject to the third party’s privacy policy and terms of use, and we recommend you review these policies before providing any personal or financial information.

Distributors and Business Partners. We may share your personal information with third parties that distribute our goods, products, and marketing materials.

Business Restructuring. Circumstances may arise where, for strategic or other business reasons, the Company decides to sell, buy, divest, merge or otherwise reorganize our businesses. We may disclose your personal information to the extent reasonably necessary to proceed with the negotiation or with the completion of a merger, acquisition, divestiture or sale of all or a portion of the Company's assets.

Legal Requirements and Legitimate Interests. We may disclose personal information when we believe such disclosure is appropriate or necessary to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce a contract with us; (iv) protect our rights, privacy, health, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.

In the event that you facilitate a transaction with the Company, or request information from or otherwise engage with us, and such activities require the Company to share your personal information with a service provider or other third party, you hereby consent to such disclosure and/or direct the Company to intentionally disclose your personal information to the service provider or third party.

We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media’s direct message tools. Those communications to and from us are governed by this Privacy Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, and the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

As a resource to you, the Site may include links to third-party websites or provide you the opportunity to disclose information directly to third parties (e.g., credit card processors). Our Privacy Policy does not apply to such third-party websites or organizations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the Services. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.

Video Links. We may include videos on our Sites. By clicking on videos on our Sites, it may (i) take you to a third-party’s website to play the video, or (2) play the video on our Site and this functionality may be supported by a third party’s website or technology (e.g., YouTube, YouTube API, Vimeo, or another third-party site). In any such case, by playing the video you shall become subject to the third party’s terms and conditions, including, but not limited to, its terms of service and policies on privacy and the collection and use of your personal information. For the avoidance of doubt, you hereby agree to the legal terms from YouTube and Vimeo.

The period during which we retain your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with our Services, to facilitate transactions you have requested, or to engage in marketing activities, and for as long as is necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

The Company is based in the United States and the personal information that we collect and process is retained and stored in the United States. The Company uses service providers that store personal information on our behalf in the United States and in other third countries. Your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. By continuing to provide us such information, you hereby consent to your personal information being transferred to, and stored in, the United States and in such other third countries. This Site may only be used by individuals who are at least eighteen (18) years of age and who are located in the United States of America. If you are not eighteen (18) years of age and you are not located in the United States of America, you are prohibited from using this Site.

We seek to protect the security of your personal information and use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. HOWEVER, NO INFORMATION SYSTEM CAN BE FULLY SECURE AND WE CANNOT GUARANTEE THE ABSOLUTE SECURITY OF YOUR PERSONAL INFORMATION. MOREOVER, WE ARE NOT RESPONSIBLE FOR THE SECURITY OF PERSONAL INFORMATION YOU TRANSMIT TO THE SITE AND/OR THE SERVICES OVER NETWORKS THAT WE DO NOT CONTROL, INCLUDING THE INTERNET AND WIRELESS NETWORKS, AND YOU PROVIDE US WITH ANY PERSONAL INFORMATION AND DATA AT YOUR OWN RISK. TO THE EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE OR OTHERWISE RESPONSIBLE FOR ANY DATA INCIDENT OR EVENT THAT MAY COMPROMISE THE CONFIDENTIALITY, INTEGRITY, OR SECURITY OF YOUR PERSONAL INFORMATION CAUSED BY A THIRD PARTY. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a username and password to access our Services, you are responsible for maintaining the security and confidentiality of those credentials and not revealing them to others. You must contact us immediately if you have reason to believe that your username or password to our Services has been compromised. You acknowledge and agree that we may contact you via email or other electronic communications in the event we are legally required to notify you of a data security incident or event related to your personal information.

The Site is not directed at, nor intended for use by, children. As a result, if you are under the age of sixteen (16), you are prohibited from accessing or using the Services (including the Site) or from providing us with your personal information.

The Site may provide you with the ability to submit a comment on, provide an opinion about, rate, or otherwise discuss our Services (a “Product Review”) or provide other information (“Feedback”), and such Product Review or Feedback may be posted to a publicly available portion of the Site. Any information or content you post in a Product Review or in your Feedback will be available to other users of the Site (and our social media platforms) and may be retrievable by third-party search engines, and third parties may also be able to download or share your Product Review and Feedback to social media websites or elsewhere. We recommend that you guard your privacy and anonymity and not upload any information in your Product Review and Feedback that you wish to remain confidential. Any third party with access to your information via the Site will be permitted to use the information in the same manner as if you submitted the information directly to that third party. Publicly posting any information on the Site is entirely voluntary on your part, and we recommend you carefully consider the information you choose to make publicly available.

You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon a person’s data privacy rights or privileges. IF YOU PROVIDE PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO COMPANY, YOU EXPRESSLY REPRESENT AND WARRANT TO COMPANY THAT YOU HAVE THE FULL RIGHT AND AUTHORITY TO PROVIDE COMPANY WITH SUCH PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) AND THAT COMPANY’S USE AND PROCESSING OF SUCH PERSONAL INFORMATION AS SET FORTH HEREIN WILL NOT VIOLATE ANY PERSON’S RIGHTS OR PRIVILEGES, INCLUDING RIGHTS TO PRIVACY. YOU HEREBY AGREE TO FULLY AND COMPLETELY INDEMNIFY COMPANY FOR ANY CLAIMS, HARM, OR DAMAGES THAT MAY ARISE FROM YOUR PROVISION OF PERSONAL INFORMATION (INCLUDING PERSONAL INFORMATION CONCERNING A THIRD PARTY) TO COMPANY.

It is important that the personal information that you provide to us is accurate and reliable. You may have the ability to update your personal information at “Checkout” when you purchase a good or product. In certain circumstances, you may have the ability to directly edit your account to update and change your personal information (e.g., name, telephone number, email, shipping address), and you must do so when such changes are warranted. If your account does not contain such features, then you must directly notify the Company of any changes or updates to your personal information in accordance with the “Contact Us” section listed below.

You have the right to opt out of receiving email marketing communications from us. Generally, the email marketing communications that you receive from us will provide you an option to “unsubscribe” from receiving future email marketing communications from us. You may also unsubscribe from such email marketing by contacting us in accordance with the “Contact Us” section listed below. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use an email address to which you subscribed to receive email marketing from us.

the Company offers a Mobile Messaging Program in which we send participants text messages related to our Services, marketing programs, and discounts. By participating in the Mobile Messaging Program, you agree to receive autodialed or prerecorded marketing mobile messages and you understand that you are not required to make any purchase from us to participate in our Mobile Messaging Program. Message and data rates may apply to such communications. Please review our Messaging Terms & Conditions for more information. You hereby agree to immediately notify the Company, in writing, in the event you no longer own, license, or use the telephone number which you used to enroll in our Mobile Message Program.

Data Privacy Rights. Pursuant to the California Consumer Privacy Act of 2018, as amended (“CCPA”), as amended by the California Privacy Rights Act of 2020, California residents are entitled to certain data privacy rights, including the following:

• Right to Know : (Specific Pieces of Personal Information). You have the right to know the specific pieces of your personal information that we have collected about you.
• Right to Know : (Categories of Personal Information). You have the right to know (i) the categories of personal information we have collected from you; (ii) the categories of sources from which the personal information is collected; (iii) the categories of your personal information we have sold or disclosed for a business purpose; (iv) the categories of third parties to whom your personal information was sold or disclosed for a business purpose; and (v) the business or commercial purpose for collecting or selling your personal information.
• Right to Delete : You have the right to request that we delete your personal information that we have collected and retain.
• Right to Correct : You have the right to request that we correct inaccurate personal information that we have collected and retain.
• Nondiscrimination : The right not to be subject to discrimination for asserting your rights under the CCPA.

Submit a Privacy Request. To submit a privacy request, please contact us in accordance with the “Contact Us” section listed below. If you would prefer, you may designate an authorized agent to submit a CCPA privacy request on your behalf. An authorized agent must be registered with the California Secretary of State to conduct business in California.

Privacy Request Verification Process. If you (or your authorized agent) make any request related to your personal information under the CCPA, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. The Company will, to the extent required or permitted by law, require you (or your authorized agent) to verify your request via email or other means and match at least two or three pieces of personal information we have previously collected from you before granting you access to, erasing, or correcting, specific pieces or categories of personal information, or otherwise responding to your request. We may require written documentation that demonstrates a third party is authorized to serve as your agent for the purposes of submitting the requests set forth herein, unless you have provided the authorized agent with power of attorney pursuant to California Probate Code §§ 4121 to 4130. None of the CCPA’s rights are absolute, and they are subject to legal and regulatory exceptions and exemptions. For more information about the CCPA, please see: https://oag.ca.gov/privacy/ccpa.

Opt-Out Rights / Do Not Sell My Personal Information. California residents have the right to opt out of the sale of their personal information. The Company does not sell your personal information to third parties for profit or monetary or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Do Not Share My Personal Information. California residents have the right to opt out of the “sharing” of their personal information. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners, and such features, tools and marketing relationships involve the disclosure of your personal information to third parties and may constitute the “sharing” of your personal information for CCPA purposes. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. You, or your authorized agent, may also contact us in accordance with the “Contact Us” section listed below.

Children. The Site is not directed at, and should not be used by, minors under the age of sixteen (16), and therefore the Company does not knowingly sell or share the personal information of minors under sixteen (16) years of age.

Limit Use of Sensitive Personal Information. The Company does not use or disclose sensitive personal information regarding our employees, workers, contractors, and agents for reasons other than those set forth in the CCPA and therefore we do not provide individuals with the ability to limit how we use or disclose such sensitive personal information.

California “Shine the Light”. Under California Civil Code Section 1798.83 (“Shine the Light”), California residents have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal information, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties; however, we do not disclose personal data to third parties for their direct marketing purposes.

Data Privacy Rights. Pursuant to the Colorado Privacy Act (CPA), Colorado residents are entitled to the following data privacy rights:

• To confirm whether or not we are processing your personal information and access such personal information, unless such confirmation or access would require us to reveal a trade secret.
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• To delete personal information provided by, or obtained about, you.
• To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Submit a Privacy Request. To submit a CPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a CPA privacy request on your behalf.

Privacy Request Verification Process. If you make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, the Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision the Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Colorado Attorney General at: https://coag.gov/file-complaint/.

Opt-Out Rights / The Sale of Personal Information. Colorado residents have the right to opt out of the “sale” of their personal information. However, the Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Colorado residents have the right to opt out of having their personal information used for targeted advertising purposes. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. Colorado residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, the Company does not engage in such activities.

Data Privacy Rights. Pursuant to the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, also known as the Connecticut Data Privacy Act (CDPA), Connecticut residents are entitled to the following data privacy rights:

• To confirm whether or not we are processing your personal information and access such personal information, unless such confirmation or access would require us to reveal a trade secret.
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• To delete personal information provided by, or obtained about, you.
• To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means, provided we shall not be required to reveal any trade secret.

Submit a Privacy Request. To submit a CDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a CDPA privacy request on your behalf.

Privacy Request Verification Process. If you make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, the Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision the Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Connecticut Attorney General at: https://portal.ct.gov/DCP/Complaint-Center/Consumers---Complaint-Center.

Opt-Out Rights / The Sale of Personal Information. Connecticut residents have the right to opt out of the “sale” of their personal information. However, the Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Connecticut residents have the right to opt out of having their personal information used for targeted advertising purposes. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. Connecticut residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, the Company does not engage in such activities.

Consumer Health Data. Connecticut law regulates how certain organizations may collect, retain, and use “consumer health data,” which is defined as “any personal data that a controller uses to identify a consumer's physical or mental health condition or diagnosis, and includes, but is not limited to, gender-affirming health data and reproductive or sexual health data.” Please see our Consumer Health Data Privacy Policy for more information on how we may collect, retain, and use consumer health data. The term “consumer health data” is considered “sensitive data” for purposes of the CDPA (and “sensitive data” is subset of “personal data” as the term is so defined within the CDPA). The data privacy rights listed in this section apply to consumer health data. In the event you provide us with consumer health data, you hereby expressly consent to our use and processing of such consumer health data.

Data Privacy Rights. Pursuant to the Montana Consumer Data Privacy Act (MCDPA), Montana residents are entitled to the following data privacy rights:

• To confirm whether we are processing your personal information and access your personal information, unless such confirmation or access would require us to reveal a trade secret.
• To correct inaccuracies in your personal information, considering the nature of the personal information and the purposes of the processing of your personal information.
• To delete personal information about you.
• To obtain a copy of your personal information previously provided by you to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another controller without hindrance when the processing is carried out by automated means, provided we are not required to reveal any trade secret.

Submit a Privacy Request. To submit a MCDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a MCDPA privacy request on your behalf.

Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Montana Attorney General at: https://dojmt.gov/consumer/.

Opt-Out Rights / The Sale of Personal Information. Montana residents have the right to opt out of the “sale” of their personal information. However, Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Montana residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. Montana residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Company does not engage in such activities.

The Company does not currently conduct “sales” of personal information for purposes of Nevada law. Notwithstanding the foregoing, Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their information to others. If you would like to exercise this right, please contact us in accordance with the “Contact Us” section listed below.

Consumer Health Data. Nevada law regulates how companies may collect, retain, and use “consumer health data,” which is defined as “personally identifiable information that is linked or reasonably capable of being linked to a consumer and that a regulated entity uses to identify the past, present or future health status of the consumer.” Please see our Consumer Health Data Privacy Policy for more information on how we may collect, retain, and use consumer health data. In the event we collect your consumer health data, you have the right that we (i) confirm whether we are collecting, sharing or selling your consumer health data, (ii) provide you with a list of all third parties with whom we have shared or sold your consumer health data, (iii) cease collecting, sharing or selling your consumer health data, and (iv) delete consumer health data concerning the consumer. To exercise these rights, please contact us in accordance with the “Contact Us” section below. Once you submit such a request, we will authenticate your requests and process it as required by law. Please allow up to 45 days for a response. If we deny your privacy rights request, you may appeal that denial by undertaking the following, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may also file a complaint the Nevada Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.

Data Privacy Rights. Pursuant to the Oregon Consumer Data Privacy Act (OCDPA), Oregon residents are entitled to the following:

• To obtain from us confirmation as to whether we are processing or have processed your personal information and the categories of personal information we are processing or have processed.
• To obtain from us, at our option, a list of specific third parties, other than natural persons, to which we have disclosed (i) your personal information; or (ii) any personal information.
• To obtain from us a copy of all of your personal information that we have processed or we are processing.
• To require us to correct inaccuracies in personal information about you, taking into account the nature of the personal information and our purpose for processing the personal information.
• To require us to delete your personal information, including personal information you provided to us, personal information we obtained from another source, and derived data.

Submit a Privacy Request. To submit a OCDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a OCDPA privacy request on your behalf. Please note that notwithstanding your privacy rights, we are not required to disclose our trade secrets, as defined in O.R.S. 646.461.

Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Oregon Attorney General at: https://www.doj.state.or.us/consumer-protection/contact-us/.

Opt-Out Rights / The Sale of Personal Information. Oregon residents have the right to opt out of the “sale” of their personal information. However, Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Oregon residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. Oregon residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Company does not engage in such activities.

Data Privacy Rights. Pursuant to the Texas Data Privacy and Security Act (TDPSA), Texas residents are entitled to the following data privacy rights:

• To confirm whether we are processing your personal information and to access the personal information.
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• To delete personal information provided by or obtained about you.
• If your personal information is available in a digital format, to obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another party without hindrance.

Submit a Privacy Request. To submit a TDPSA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a TDPSA privacy request on your behalf. Please note that notwithstanding your privacy rights, we are not required to disclose our trade secrets.

Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, we will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Texas Attorney General at: https://www.texasattorneygeneral.gov/consumer-protection.

Opt-Out Rights / The Sale of Personal Information. Texas residents have the right to opt out of the “sale” of their personal information. However, Company does not sell your personal information to third parties for monetary consideration or other valuable consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Texas residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. Texas residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Company does not engage in such activities.

Data Privacy Rights. Pursuant to the Utah Consumer Privacy Act (UCPA), Utah residents are entitled to the following data privacy rights:

• To confirm whether or not we are processing your personal information and to access such personal information.
• To delete personal information provided by you to us.
• To obtain a copy of your personal data that you previously provided to us in a format, that to the extent technically feasible is portable, to the extent practicable is readily usable, and allows you to transmit the data to another entity without impediment, where the processing is carried out by automated means.

Submit a Privacy Request. To submit a UCPA privacy request, please contact us in accordance with the “Contact Us” section below.

Privacy Request Verification Process. If you make any request related to your personal information, Company will ascertain your identity to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, or erasing, specific pieces or categories of personal information or otherwise responding to your request, Company will, to the extent required or permitted by law, (i) require you to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions. For more information about the Utah Consumer Privacy Act, please see https://le.utah.gov/~2022/bills/static/SB0227.html.

Opt-Out Rights / The Sale of Personal Information. Utah residents have the right to opt out of the “sale” of their personal information. However, Company does not sell your personal information to third parties for monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Utah residents have the right to opt out of having their personal information used for targeted advertising purposes. Company uses third-party analytical and targeted advertising features on our Sites and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences. You may also contact us in accordance with the “Contact Us” section listed below.

Data Privacy Rights. Pursuant to the Virginia Consumer Data Protection Act (VCDPA), Virginia residents are entitled to certain data privacy rights:

• To confirm whether or not the Company is processing your personal information, and to access such personal information.
• To request the Company correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.
• To request the Company delete your personal information.
• To obtain a copy of the personal information that you previously provided the Company in a portable and, to the extent technically feasible, readily usable format that allows it to be transmitted to another entity without hindrance, where the processing is carried out by automated means.

Submit a Privacy Request. To submit a VCDPA privacy request, please contact us in accordance with the “Contact Us” section below. If you would prefer, you may designate an authorized agent to submit a VCDPA privacy request on your behalf.

Privacy Request Verification Process. If you make any request related to your personal information, the Company will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, the Company will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of Virginia’s privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision the Company has made with respect to your privacy request, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review. You may file privacy complaints with the Virginia Attorney General at: https://www.oag.state.va.us/contact-us/contact-info.

Opt-Out Rights / The Sale of Personal Information. Virginia residents have the right to opt out of the “sale” of their personal information. However, the Company does not sell your personal information to third parties for or monetary consideration, and therefore we do not provide opt-out request processes for the sale of personal information (because we do not undertake such activities).

Opt-Out Rights / Targeted Advertising. Virginia residents have the right to opt out of having their personal information used for targeted advertising purposes. The Company uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link) on the footer of the Site to set your cookie preferences.

Opt-Out Rights / Profiling. Virginia residents have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, the Company does not engage in such activities.

Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by the Company in accordance with this Privacy Policy and the Company’s obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you have a right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email, and we will request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal information, provided that we advise you of any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the information contains personal information of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

Some web browsers may transmit “do-not-track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Unless otherwise required by law, we currently do not take action in response to these signals.

The Company strives to ensure that every person has access to information related to our Services, including this Privacy Policy. Please contact us in accordance with the “Contact Us” section listed below if you would like this Privacy Policy provided in an alternate format, and we will seek to meet your needs.

We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs (“Rewards Programs”). We collect and use personal information, including personal information provided by a third party (e.g., refer-a-friend program), to administer and maintain our financial incentive, rewards, and loyalty programs.

California Rewards Program Rights. Pursuant to the CCPA, you may be entitled to be informed as to why financial incentive programs, or price or service differences, are permitted under the law, including (i) a good-faith estimate of the value of your personal information that forms the basis for offering the financial incentive or price or service difference, and (ii) a description of the method we used to calculate the value of your personally information. Generally, we do not assign monetary or other value to personal information. However, in the event we are required by law to assign such value in the context of Rewards Programs, or price or service differences, we have valued the personal information collected and used as being equal to the value of the discount or financial incentive provided, and the calculation of the value is based upon a practical and good-faith effort often involving (i) the categories of personal information collected (e.g., names, email addresses), (ii) the transferability of such personal information for us and our Rewards Programs, (iii) the discounted price offered, (iv) the volume of consumers enrolled in our Rewards Programs, and (v) the product or service to which the Rewards Programs, or price or service differences, apply. The disclosure of the value described herein is not intended to waive, nor should it be interpreted as a waiver to, our proprietary or business confidential information, including trade secrets, and does not constitute any representation with regard to generally accepted accounting principles or financial accounting standards.

As part of our recruitment and talent management process, we collect personal information with respect to individuals who are interested in working for us. In this context, we collect employment and application data, such as the following: contact information (e.g., name, title, residential or postal address, telephone number, and personal email address); information in a curriculum vitae, résumé, cover letter, or similar documentation; details regarding the type of employment sought, willingness to relocate, job compensation and benefit preferences; health data (e.g., medical conditions); information related to your background, education, criminal record, credit history and similar data; information provided about or by your references or other third parties related to your employment history, skills, qualifications, or education; and information related to previous applications to us or previous employment history with us. When permitted by law, we may collect information about your race and ethnicity to assist with our diversity and inclusion programs. We use this information for the following purposes: to identify and evaluate job applicants; to verify your information; to complete employment, education, background and reference checks; to communicate with you about the recruitment process and your application; to comply with our legal, judicial, regulatory, administrative, or other corporate requirements; to analyze and improve our application and recruitment process; to accommodate individuals who may have specialized needs during the employment process; and to protect the rights, interests, and property of our business, other job applicants, employees, or the public, as required, or permitted, by law. We share this personal information with third parties (see “Sharing Information / Third-Party Disclosures”), and we may also use this employment and application data for any other purpose set forth in this Privacy Policy.

The Company hosts and uses video teleconferencing platforms to facilitate conferences, meetings, training events, and other programs. We often use online platforms that are owned and administered by a third-party service provider (e.g., Google, Zoom, WebEx, Skype for Business). Please be aware that our video teleconferencing may record the content, conversations, and discussions thereon, and such records may be stored or retained by our third-party service providers. By participating in our events and video teleconferencing, you hereby consent to the collection and retention of any information provided therein, and you hereby consent to the recording of such activities.

In the event you call the Company, including our customer support representatives, you hereby acknowledge and agree that such telephone calls will be monitored and recorded to ensure quality of service and to create an accurate record of our conversation, and the content of such telephone calls may be disclosed to third parties.

We reserve the right to amend this Privacy Policy at any time. We will notify you if this Privacy Policy is amended by updating the “Last Updated” section listed above. It is your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto. Your use of the Services, and continued use of the Services after any amendments are made to this Privacy Policy, signifies your consent to this Privacy Policy and any amendments hereto. We may, in our sole discretion, provide you communications, including via email or text messages, about changes to our Privacy Policy; however, such communications do not abrogate or otherwise limit your responsibility to periodically review the Privacy Policy to determine whether any amendments have been made hereto.

If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at the following:

New Chapter: email us info@newchapter.com; mail us at New Chapter, ATTN: Privacy, 90 Technology Drive, Brattleboro, VT 05301, or please use our New Chapter interactive webform.

LifeShield: email us info@lifeshieldvitamins.com; mail us at LifeShield, ATTN: Privacy, 90 Technology Drive, Brattleboro, VT 05301, or please use our LifeShield interactive webform.