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LifeVantage Corporation (hereinafter “LifeVantage,” “Company,” “we,” or “us”) respects your concerns about privacy. LifeVantage complies with the EU-U.S. Privacy Shield framework (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union to the United States (“Personal Data”). LifeVantage has certified to the Department of Commerce that we adhere to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. If there is any conflict between the terms in this Policy or LifeVantage’s other privacy policies and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
This Privacy Shield Policy (“Policy”) describes how LifeVantage collects, uses, and discloses certain Personal Data received from the European Union in the United States. To view our certification and learn more about the Privacy Shield program, please visit www.privacyshield.gov.
LifeVantage also may collect the following types of Personal Data from Independent Distributors, in order to support their LifeVantage account and to execute any agreements with Independent Distributors in the United States (including for managing distribution and ensuring commission payments): company name (if applicable), name, birth date, gender, e-mail address, mailing address, phone and fax numbers, preferred language, sales data and banking information (bank name and account details), and other Personal Data provided by distributors
In addition, LifeVantage may obtain Personal Data, such as contact information and financial account information of its Suppliers. LifeVantage uses this Personal Data to manage its relationship with its Suppliers, to process payment, expenses and reimbursements and to carry out LifeVantage’s obligations under its contracts with Suppliers.
LifeVantage may also collect Personal Data in other ways for which LifeVantage provides specific notice at the time of collection (including but not limited to market research, surveys, etc.)
LifeVantage subjects to the Privacy Shield Principles all Personal Data it receives from the EU.
LifeVantage generally offers you the opportunity to opt out before we (a) disclose your Personal Data to a Third-Party Controller or (b) use your Personal Data for any purpose that is materially different from the purposes for which it was originally collected or you subsequently authorized. You may exercise your choice without any cost to you by contacting LifeVantage using the information supplied under “Contact Us” below.
Please note that LifeVantage may disclose your Personal Data to its subsidiaries. LifeVantage may disclose your Personal Data without offering you an opportunity to opt out, and may be required to disclose your Personal Data, to third-party Processors retained to perform services on the Company’s behalf and consistent with its instructions, if it is required to do so by law or legal process, or in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. LifeVantage may also transfer your Personal Data in the event of an audit or in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation.
Where required by the Privacy Shield, Third-Party Agents or service providers must contractually agree to limit their use of your Personal Data to the specified services provided on our behalf, provide at least the same level of protection that the Privacy Shield requires, and notify us if they can no longer provide the same level of protection required by the Privacy Shield. We also take reasonable and appropriate steps to ensure that our Third Party Agents and service providers process Personal Data in a manner consistent with our Privacy Shield obligations and to stop and remediate unauthorized processing. Under certain circumstances, we may remain liable under the Privacy Shield Principles if our agents process your Personal Data that we transfer to them in a manner inconsistent with the Privacy Shield Principles.
Transfers to Third Party Controllers. In some cases, LifeVantage may transfer your Personal Data to other third-party Controllers. As noted in Section IV and except as permitted or required by applicable law, LifeVantage requires third-party Controllers to whom it shares or discloses your Personal Data to contractually agree to process Personal Data for limited and specified purposes consistent with the consent provided by the Employee, provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and notify us and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if it cannot meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles.
Transfers within a Controlled Group of Entities. If we transfer your Personal Data to one of our LifeVantage affiliates or subsidiaries, we will ensure the continuity of protection of your Personal Data under the Privacy Shield.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including meeting national security or law enforcement requirements.
LifeVantage maintains reasonable and appropriate security measures in accordance with the Privacy Shield to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data
LifeVantage limits the Personal Data it processes to that which is relevant for the purposes of the particular processing. As such, LifeVantage will only process your Personal Data in ways that are compatible with the purposes that LifeVantage collected it for or was subsequently authorized by you. LifeVantage maintains reasonable procedures to ensure that Personal Data is reliable for its intended use, accurate, complete, and current for as long as LifeVantage retains such information. In this regard, LifeVantage depends on you to ensure your Personal Data is reliable, accurate, complete and current. Please contact the Company as provided in the “Contact Us” section below to update or correct Personal Data.
Subject to applicable law, LifeVantage retains Personal Data in a form that identifies or renders identifiable you or the relevant individual only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by you or the relevant individual.
You generally have the right to access your Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or has been processed in violation of the Privacy Shield. Accordingly, LifeVantage strives to provide you with reasonable access to your Personal Data, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in question, or where the rights of persons other than the individual would be violated.
We may request specific information from you to confirm your identity and to better understand your request. To request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request by using our “Contact Us” information provided below. In some circumstances, we may charge a reasonable fee for providing information about your Personal Data
LifeVantage has implemented mechanisms designed to effect compliance with the Privacy Shield Principles. We conduct an annual self-assessment of our Personal Data practices to verify that the attestations and assertions we make about our Privacy Shield privacy practices are true and that LifeVantage’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.
LifeVantage is committed to resolving complaints about our collection or use of your Personal Data In compliance with the Privacy Shield Principles. Please contact us by using our “Contact Us” information provided below with inquiries or complaints regarding this Policy or our Privacy Shield privacy practices.
If your complaint cannot be resolved through our internal processes, LifeVantage has committed to refer unresolved privacy complaints under the EU-U.S Privacy Shield Principles to JAMS: The Federal Trade Commission has jurisdiction over LifeVantage’s compliance with the Privacy Shield.
Binding Arbitration. Under certain conditions, it may be possible for you to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For additional information, see the U.S. Department of Commerce’s Privacy Shield Framework: Annex I (Binding Arbitration).
Effective Date: April 23, 2018
Last Motified: April 23, 2018
For purposes of the Policy, the terms set forth below have the following meaning:
If you have any questions about this Policy or LifeVantage’s collection practices or processing of your Personal Data or would like to request access to your Personal Data, please e-mail or call us at the below number:
Fax: (855) 836-4925
9785 S. Monroe Street, Suite 300
Sandy, UT 84070
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