Privacy policy

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Last updated: October 12, 2022

 

Introduction

ELANZA Wellness (“we”, “our”, “us” or “ELANZA Wellness”) recognizes the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

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● Visit our website at www.elanzawellness.com, or any website of ours that links to this privacy notice

● Use other websites or web application(s) associated with us, such as our member portal, or any other application of ours that links to this privacy notice

● Engage with us in other related ways ― including any sales, marketing, or events

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HIPAA Notice

 

In addition, individually identifiable information that you provide to us for purposes of obtaining healthcare from ELANZA Wellness (such information is also referred to as “Protected Health Information” or “PHI”) will also be subject to ELANZA Wellness’s Health Insurance Portability and Accountability Act Notice of Privacy Practices (the “HIPAA Notice”), which is available here. The HIPAA Notice describes how ELANZA Wellness can use and share your PHI and also describes your rights with respect to your PHI. To the extent that there is a conflict between this Privacy Policy and the HIPAA Notice with respect to PHI, the HIPAA Notice will prevail.

 

Who we are:

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​ELANZA Wellness Ltd (“we”, “our”, “us” or “ELANZA Wellness”) is committed to protecting and respecting your privacy. ELANZA Wellness is a Delaware registered corporation with offices at: 2042 Bush St, San Francisco, California 94115, USA.

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Our data protection officer, for the purpose of applicable data protection law, is Catherine Hendy, who may be contacted at info@elanzawellness.com. If you have any questions or would like to discuss further, you can email us.

You can find more information about us by clicking here: www.elanzawellness.com/about

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Our approach:

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We take the collection, usage and security of your personal data seriously. We can only use your personal data under law if we have a good reason for doing so. The law provides examples of those reasons. These include:

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• To perform or fulfill a contract we have with you; or

• If we have a legal duty; or

• If it is within our legitimate business interest; or

• If there is a public interest reason for doing so; or

• If you have given your consent.

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A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

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Questions or concerns? 

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Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have any questions or concerns, contact us at info@elanzawellness.com.

 

Key points:

 

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with ELANZA Wellness and the Services, the choices you make, and the products and features you use.

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Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.

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Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

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How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

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In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. More information is provided below.

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How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

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What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. More information is provided below.

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How do I exercise my rights? The easiest way to exercise your rights is by making a data subject request by contacting us at info@elanzawellness.com. We will consider and act upon any request in accordance with applicable data protection laws.
 

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Types of personal data we collect about you

 

• Contact details of customers or customer connected parties (e.g. fertility clinics)

• Demographic data (e.g. date of birth)

• Lifestyle information (e.g. diet / smoking status)

• Financial data (for payment)

• Health data 

• Complaints information

• Technical Information (IP / Cookies)

• Location Data

• User login data

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You may give us information about you when filling in forms on our website https://www.elanzawellness.com/ (“our site”) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you subscribe to our services, complete a survey, sign up to a newsletter, post material on our site, report a problem with our site, request further services. The information you give us may include your name, address, email address, phone number, personal description, and fertility clinic and / or doctor name.

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IMPORTANT: For data privacy reasons, we will only collect information from you directly or via your authorized representative who has confirmed that they are authorized to provide this information on your behalf.

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Information we collect about you

 

We may collect the following kinds of information when you use the Services:

Information you provide directly to us. For certain activities, such as when you register, use our platform or telehealth services, subscribe to our communications or alerts, or contact us directly, we may collect some or all of the following types of information:

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• Contact information, such as your full name, email address, mobile phone number, and address;

• Username and password;

• Payment information, such as your credit card number, expiration date, and credit card security code;

• For health and coaching care recipients and platform users, information about your names, address details, authorized representative information, health information and payment card information;

• For health care providers, information about your employment, such as your job title, practice area, primary specialty, and medical license status, gender, date of birth, languages spoken, educational background, address, photograph, social security number, Tax ID, NPI number, professional license information and bank account information;

• Personal health information; and

• Any other information you provide to us.

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We may combine such information with information we already have about you.

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Information we collect automatically. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, information about the links you click and pages you view within the Services, and other standard server log information. We may also collect certain location information when you use our Services, such as your computer’s IP address, your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.

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We may use cookies, pixel tags, Local Shared Objects, and similar technologies to automatically collect this information. Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. Local Shared Objects (sometimes referred to as “Flash Cookies”) are similar to standard cookies except that they can be larger and are downloaded to a computer or mobile device by the Adobe Flash media player. By using the Services, you consent to our use of cookies and similar technologies.

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We may also collect technical data to address and fix technical problems and improve our Services, including the memory state of your device when a system or app crash occurs while using our Services. Your device or browser settings may permit you to control the collection of this technical data. This data may include parts of a document you were using when a problem occurred, or the contents of your communications. By using the Services, you are consenting to the collection of this technical data.

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Information we obtain from your health care providers and other sources. In connection with your treatment, we may collect medical records from your past, current, and future health care providers. This may include information about your diagnosis, previous treatments, general health, laboratory and pathology test results and reports, social histories, any family history of illness, and records about phone calls and emails related to your illness.

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What do we use your personal information for?

 

We generally use the information we collect online to:

• Provide and improve the Services;

• Contact you;

• Fulfill your requests for products, services, and information;

• Send you information about additional clinical services or general wellness from us or on behalf of our affiliates and trusted third-party partners;

• Analyze the use of the Services and user data to understand and improve the Services;

• Customize the content you see when you use the Services;

• Conduct research using your information, which may be subject to your separate written authorization;

• Prevent potentially prohibited or illegal activities and otherwise in accordance with our Terms of Use (which can be found at https://www.elanzawellness.com); and

• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

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We may also use your information in the following ways:​​​

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• To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.

• Maintain user relationships.

• Match a user with a mentor.

• Communicate with potential and existing users for marketing purposes.

• Providing and improving quality of services to users.

• To analyze and improve our website in order to better serve you.

• To allow us to better service you in responding to your customer service requests.

• To send periodic emails regarding your order or other products and services.

• To maintain user relationships.

• To administer a contest, promotion, survey or other site feature.

• To quickly process your transactions.

• Marketing and site metrics performance.

• Email marketing (with your consent).

• Accounting purposes.

 

How we share your personal data

 

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

• Healthcare providers, insurance companies, and other healthcare-related entities. We may share your information with other health care providers, laboratories, government agencies, insurance companies, organ procurement organizations, medical examiners or funeral directors, and other entities relevant to providing you with treatment options and support.

• Authorized third-party vendors and service providers. We may share your information with third-party vendors and service-providers that help us with specialized services, including billing, payment processing, customer service, email deployment, business analytics, marketing (including but not limited to advertising, attribution, mobile marketing, optimization and retargeting), performance monitoring, hosting, and data processing. These third-party vendors and service providers may not use your information for purposes other than those related to the services they are providing to us.

• Research partners. We may share your information with our research partners to conduct health-related research; such sharing may be subject to your separate written authorization.

• Corporate affiliates. We may share your information with our corporate affiliates that are subject to this policy.

• Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

• Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of ELANZA Wellness, our affiliates, users, or the public. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

•  With your consent or at your direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

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Outside of the use cases specified above, we will not provide your information to third parties. However, if you access third-party services, such as Facebook, Google, or Twitter, through the Services to login to the Services or to share information about your experience on the Services with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.

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If you choose to engage in public activities on the Site or third party sites that we link to, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these sites. We are not responsible for the information you choose to submit in these public areas.

 

Where we store your personal data

 

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and the United States ("USA"). It may also be processed by staff operating outside the EEA or USA who work for us or for one of our suppliers or business partners. By submitting your personal data, you agree to this transfer, storing and/or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

Personal Health Information (PHI)  provided by portal users will be held in a third party data center compliant with HIPAA laws.

 

Security of your personal data

 

We use reasonable measures, including strict procedures and security features, to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to our site; any transmission of your data is at your own risk.

Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information. Our site may, from time to time, contain links to and from the websites of our member and associate member organizations, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

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How long we keep your information

 

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. After you have terminated your use of our services, we will retain your personal information for up to 10 years and thereafter may store it in an aggregated and anonymized format.

 

Third party advertising links and content

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ELANZA Wellness uses third party vendors and service-providers that help us provide you the Services. These third party vendors and service providers only collect information about your use of our Platform in order to support us in providing you the Services. Some of our websites may contain links to content maintained by third parties that we do not control. We allow third parties, including business partners, advertising networks, and other advertising service providers, to collect information about your online activities through cookies, pixels, local storage, and other technologies to provide you interest based advertising. These third parties may use this information to display advertisements on our websites and elsewhere online tailored to your interests, preferences, and characteristics. Some of these third parties may participate in an industry organization that gives users the opportunity to opt out of receiving ads that are tailored based on your online activities. Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable targeted ad technologies in mobile apps.

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Many mobile devices allow you to opt out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

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To opt out of interest-based advertising across browsers and devices from companies that participate in the Digital Advertising Alliance or Network Advertising Initiative opt-out programs, please visit their respective websites. You may also be able to opt-out of interest-based advertising through the settings within the mobile app or your mobile device, but your opt-out choice may apply only to the browser or device you are using when you opt-out, so you should opt out on each of your browsers and devices if you want to disable all cross-device linking for interest-based advertising. If you opt out, you will still receive ads but they may not be as relevant to you and your interests, and your experience on our Services may be degraded.

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Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. 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 even are aware of them. We currently do not take action in response to these signals.

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Cookies

 

We may obtain information about your general internet usage by using cookie files stored on your computer or device (“cookies”). Cookies are text files containing small amounts of information which are downloaded to your computer or device when you visit a website. They help us to improve our site and to deliver a better and more personalised service.

We may use both “session” cookie and “persistent” cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

We will use the session cookies to: keep track of you whilst you navigate the website; keep track of your bookings; prevent fraud and increase website security; and other uses. We will use the persistent cookies to: enable our website to recognise you when you visit; keep track of your preferences in relation to your use of our website; and other uses.

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at http://www.google.com/privacypolicy.html. 

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You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. You may disable cookies by changing the settings on your browser. However, if you do so, this will affect your enjoyment of our site and we will no longer be able to offer to you a personalised service.

 

E-mail marketing and newsletters

 

We may make suggestions and recommendations to you that we think may be of interest to you or members of your team / organization. We will only contact you by electronic means (email) with information about services similar to those which you have shown an interest in.

We may also use your data, or permit selected third parties to use your data, to provide you with information about services which may be of interest to you and we or they may contact you about these by electronic means only if you have consented to this.

You have the right to ask us not to process your information for marketing purposes. You can exercise your right to prevent such processing by ticking the relevant boxes on the forms we use to collect your information, or you can opt out of receiving future marketing communications from us at any time by following the directions contained in the marketing email to unsubscribe. You can also exercise this right at any time by contacting us at info@elanzawellness.com.

 

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.

 

California Residents

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Under the California Consumer Privacy Act of 2018 (CCPA), California residents have additional privacy rights which are addressed in this Section VII.  If you are a California resident you may have certain rights under the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.).

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We do not sell your personal information, have not sold your personal information within the prior 12 months, and only use and disclose your personal information as stated in this Privacy Policy. You have the right to request we provide you with details about the information we collect and disclose about you within the prior 12 months, including: (i) the categories of personal information we collect about you, (ii) the categories of the sources of personal information we collect about you, (iii) our business or commercial purpose for collecting that information, (iv) the categories of personal information that were disclosed for a business purpose, (v) the categories of third parties to whom we disclosed that personal information, and (vi) the specific pieces of personal information we collect about you. You may also request that we delete your information. These rights are subject to certain exceptions and limitations permitted by CCPA. To submit an access or deletion request, you may email us at info@elanzawellness.com stating your request with sufficient detail and providing information that allows us to reasonably verify you as the person whose data is the subject of such request. We will not respond to more than two requests from you in a 12-month period.

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We will not discriminate against you if you exercise your rights under CPPA. By exercising your rights you will not be (i) subject to denial of goods or services, (ii) charged a different price or rate, or (iii) provided different quality of service.

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CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.

• Provide access to and/or a copy of certain information we hold about you.

• Delete certain information we have about you.

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The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request.

If you are a California resident and you would like to exercise any of your data rights under California law, please email us at info@elanzawellness.com. Please include your full name, email address and residential address associated with your use of our Services, along with the rights you would like to exercise, so that we can process your request in an efficient manner.

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Sale of Personal Information. The CCPA requires companies that "sell" (as defined in the CCPA) your personal information to provide you with notice and an opportunity to opt out. If you began using the Services prior to October 12th, 2022, ELANZA Wellness has not sold (and will not sell) information collected prior to that date that identifies you such as your name, email address, phone number, or postal address. Like many companies with an internet presence, we do work with third parties that provide marketing and advertising services to us, including interest-based advertising services, and these third parties may place tags, pixels, cookies, beacons, and other similar tracking mechanisms on our Website and App and collect your online identifiers. Because of the CCPA's broad definitions of "sale" and "personal information," making certain online identifiers available to these companies so that they can provide marketing and advertising services to Ro may be considered a "sale" under the CCPA . To opt out of sharing your information with participating third parties for interest-based advertising, please visit the Network Advertising Initiative's Consumer Opt-Out link, the Digital Advertising Alliance's Consumer Opt-Out link, or Your Online Choices. Please note that these opt-outs are device and browser based, so you will need to opt out on each of your devices and browsers. For more information, see the Online Analytics and Advertising Section above.

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If you began using the Services after our Privacy Policy was updated on October 12th, 2022, as discussed above in the "Online Advertising" section, we may also share information such as your email address with third-party advertising networks that use such information to better target advertising to you regarding ELANZA Wellness products and services, as well as other products and services, as you browse the internet. This sharing may be considered a "sale" under the CCPA. To opt out of the sale of your information under the CCPA as a California resident.

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Shine the Light Disclosure. The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

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Nevada Residents

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Under Nevada law, certain Nevada consumers may opt out of the sale of "personally identifiable information" for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by info@elanzawellness.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

International Users

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We maintain information in the United States of America and, where relevant, in Canada, in accordance with the laws of the United States or Canada, which may not provide the same level of protection as the laws in your jurisdiction. By using the website and providing us with information, you understand and agree that your information may be transferred to and stored on servers located outside your resident jurisdiction and, to the extent you are a resident of a country other than the United States, that you consent to the transfer of such data to the United States for processing by us in accordance with this Privacy Policy.

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Children

We do not knowingly allow individuals under the age of 18 to create accounts that allow access to our Services.

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Changes to the Privacy Policy

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

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Your rights

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• Access to information. The Data Protection Laws give you the right to access information held about you. Your right of access can be exercised in accordance with Data Protection Laws by contacting us at info@elanzawellness.com.

• Consent. You may withdraw your consent to any processing of your personal data at any time by contacting info@elanzawellness.com.

• Rectification. You have the right to rectify any personal data held about you that is inaccurate. Your right of rectification can be exercised by contacting us at info@elanzawellness.com.

• Erasure. You may have the right to erasure of personal data held about you by contacting us at info@elanzawellness.com.

• Complaints. In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at info@elanzawellness.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the UK’s Information Commissioner’s Office.

 

Questions?

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If you have any questions about this Privacy Policy or our practices, please email us at info@elanzawellness.com

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