Updated May 24, 2018

The following Privacy Policy governs the online information collection practices of Advesta Health Inc., referred to as “us” or “we” in this policy statement, which owns and operates advestaheath.com, aine-marie.com and HealthyLiving.

Specifically, it outlines the types of information that we gather about you while you are using any of our web sites (the “Site”), and the ways in which we use this information. This Privacy Policy, including our children’s privacy statement, does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, via telephone, or through the mail).

Your Consent

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.

Information We Collect and Why

We have access to the following categories of information regarding you and your visit to our web platform.

• Form Submissions
• Computer and Web Browser Profile
• Website Analytics (like Goo

Only some of these categories of information identify you directly, but each category offers some information about your interests and activities that could be used to make inferences about you. The next section of this policy describes how the Advesta Health uses the information we collect.

Google Analytics Advertiser Features to optimize our business. Some analytics features include:

• Remarketing with Google Analytics
• Google Display Network
• Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Information That You Voluntarily Provide

Site Registration: If an individual registers to use the website’s special features and member services that exist now or may be developed, either as a consumer or a health care professional, we will collect “personally identifying information” from you. Personally identifying information is information such as name, address, telephone number, and email address that could be used to contact you. We refer to the resulting information as “health-related personal information.”

Interactive Services: If you choose to participate in our interactive services such as health and wellness assessments and surveys, you may disclose health-related information as well as personal facts that could be used to identify you or your family members. We do not request or require you to disclose personally identifying information in these forums, but apart from warning you to be prudent in your statements, we do not have the ability to keep you from disclosing private facts. This is done however at your own risk.

Correspondence with the Advesta Health and Aine-Marie.com: You may use our websites to ask questions of health care professionals who work with the Advesta Health to address health topics. If you communicate with or request information from the Advesta Health’s personnel, they will have your email address as well as whatever health-related and/or personal facts you chose to include in your e-mail.

How We Use Your Information

We use the information about your use of the services and activities on our website to monitor user traffic patterns and try to analyse what our users prefer so that we can design better services for you. The personally identifying information and health-related personal information that you provide may be used to create customized offers, information, and services tailored to your interests and preferences. Outbound contact with you, however, will only be sent with your permission.

Personally Identifying Information: If you choose to register for any of our free services or become a member, we will use the personally identifying information you give us to send you an email confirming your registration with our website and/or inclusion into our membership program. We may also, from time to time, send you email with special promotions or newsletters with information that we think may be of interest to you.

Health-Related Information: If you choose to participate in our any of our interactive services, we will collect the information you may choose to disclose and analyse it to discover new facts that could help us better understand how our services. We may offer interactive services such as health assessments, questionnaires and wellness management tools that ask you to furnish health-related information about you or your family. We may choose to link information we collect from you from all the various parts of our website, which will be linked and provide us with personally identifying information about your health and health care.

Facebook

As advertisers who may conduct business on Facebook either directly or indirectly through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook’s Data Use Restrictions.

• Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
• We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
• We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
• We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

Children’s Privacy Statement

This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen,

and provides important information regarding their rights under federal law with respect to such information.

• This Site is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Site. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Site, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third parties.
• We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site.
• Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site’s online activities on providing personally identifiable information.

General Data Privacy Regulation (GDPR)

The GDPR takes effect on May 25, 2018, and is intended to protect the data of European Union (EU) citizens.

As a company that markets its site, content, products and/or services online we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us in the course of your use of our site, content, products and/or services is governed by GDPR, we will abide by the relevant portions of the Regulation.

If you are a resident of the European Economic Area (EEA), or are accessing this site from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the “right to be forgotten.”

To make any of these requests, please contact our GDPR contact at gdpr@advestahealth.com.

Community Tools

Some portions of our websites provide special services and offer interactive tools that allow users to input information for public consumption. In some cases, users can share experiences, give advice and connect with others in the member community. Please remember that any chat rooms, message boards and personal pages are public forums and personal information disclosed there will be seen by others. In addition, please exercise caution when posting information or providing information about yourself to others, especially contact information, such as street address, telephone number, or email address. All information entered into publically accessible forums is done at your own risk.

Our Relationship to Third Parties

We will not disclose your personally identifying information or health-related personal information to anyone other than Advesta Health’s employees and professional third parties with whom we have a business relationship. All third parties working for us are not authorized to use this information for any purpose that is not consistent with this Privacy Policy.

We pledge that we will not sell or disclose any personally identifying information or health-related personal information you provide on our web platform to an unrelated third party without your express permission, except as explained below:

Links to Other Sites: We may from time to time feature links to web properties that we believe you might find useful and informative. Please be aware, however, that we do not endorse or recommend these web properties content or services, and we are not responsible for the privacy practices of these other web properties. We encourage you to be aware of and read the Privacy Policy of each web property you visit. Remember, the statements in this Privacy Policy apply solely to information collected by the Advesta Health.

Advertisers: At this time, we do not have third-party advertising on our website. All editorial control remains with Advesta Health.

Opt-Out or Deletion Policy

When you access any interactive tool or service on our website, you will be asked to affirmatively choose (“opt-in”) to provide the requested information. You may always choose not to provide the requested information. You may also choose at any time to “opt-out” or delete this information.

The information that you provide through our websites is stored in computer servers that are operated and maintained by third parties under contract with Advesta Health. Website users should be aware that it is not technologically possible to remove from our servers each and every record of the information you have provided. The need to back-up our systems to protect information from inadvertent loss means that a copy of information about you or your health-related interests may exist in a non-erasable form that will be difficult or impossible for us to locate.

Our Security Measures

We want your personal information to remain as secure as reasonably possible.

Data Security: We use encryption practices to help insure the integrity and privacy of some of the personal and health related personal information you provide to us. As an added security precaution, all personal and/or health related personal information is kept physically behind firewalls that meet or exceed industry standards to prevent intruders from gaining access. Although we will make reasonable efforts to protect personal and/or health-related personal information from loss, misuse, or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could intercept an Internet transmission, or that thieves will find a way to thwart our security systems.

Changes in Our Privacy Policy

We will only use personal information in the manner described in the Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time by posting revisions to our web platform. If at any point, we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we would notify users by email to the extent that we have your current and valid email address. You will be given the choice at that time to “opt-in” for any additional uses or disclosures of your personally identifiable information that you made available to us prior to the change in our policy.

If you have any questions about this Privacy Policy, the privacy practices of this web platform or if you want to exercise any of the rights that you are given under this privacy statement you can contact: concierge@advestahealth.com.

Last updated: 05/24/2018
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