Last Updated: January 2024
UPO LLC (DBA “NATUROPATHIC WEIGHT LOSS” and “NWL”) PRIVACY POLICY

Introduction

UPO LLC (“NWL,” “we,” or “us”) owns and operates the website located at www.getnwl.com and a related mobile application (collectively, the “Platform”). Your access and use of any part of the Platform, including its content (“Content”), any products or services provided by NWL, and any affiliated website, software or application owned or operated by NWL (collectively referred to as the “Service”) are subject to this Privacy Policy.

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy (“Privacy Policy”) to tell you how NWL collects, uses and discloses information to provide you with the Service.

By creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are automatically accepting and acknowledging the most recent version of this Privacy Policy. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the “Last updated” date of the Privacy Policy.

If you are using the Service on behalf of an individual other than yourself, you represent that you are authorized by such individual to act on such individual’s behalf and that such individual accepts and acknowledges the practices and policies outlined in this Privacy Policy.
 
Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the NWL’s Terms and Conditions (“Terms and Conditions”).
 
No Use outside of the US Permitted
 
The Service may not be used outside the US. This Privacy Policy, and our collection, use, and disclosure of your information, is governed by U.S. law.

No Use by Minors Permitted

Our Service is intended for use by individuals who are at least 18 years of age, or an older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. The Service is not intended for children under 18 years of age. If we learn that we have collected personal information through the Platform from a minor, we may remove that information from the Platform.  If you are a minor (or a parent or legal guardian of a minor), you may ask us to remove personal information about the minor by submitting a Request for Removal of Minor Information to either of the following:

By mail: UPO LLC, Attn: Privacy Officer, 9723 Sorbonne Loop Seffner, FL 33584, with a subject line of “Removal of Minor Information”. If you send by mail, please send by U.S. Certified Mail, Return Receipt Requested, to allow for confirmation of mailing, delivery and tracking.
 
For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body of the request:
• The nature of your request
• The identity of the information to be removed
• The location of the information on the Platform (e.g. by providing the URL)
• Your name, street address, city, state, zip code and email address, and whether you prefer to receive a response to your request by mail or email.
 
We will not accept any Request for Removal of Minor Information via telephone or fax. NWL is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires NWL to maintain the information; when NWL maintains the information on behalf of your Providers (as defined in our Terms and Conditions) as part of your electronic medical record; when the information is stored on or posted to the Site by a third party other than you (including any information posted by you that was stored, republished or reposted by the third party); when NWL anonymizes the information, so that you cannot be individually identified; when you do not follow these instructions for requesting the removal of the information; and when you have received compensation or other consideration for providing the information.

The section is a description of NWL’s voluntary practices concerning the unintended collection of personal information through the Service from minors, and is not intended to be an admission that NWL is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

What Information We Collect

We collect any information you provide when you use the Service, including, but not limited to:
• Personally identifying information such as your name and contact data such as your e-mail address, phone number, and billing and physical addresses
• Your login and password and other account (“Account”) registration details
• Demographic data (such as your gender, date of birth and zip code)
• Computer, mobile device and/or browser information (e.g., IP address, mobile device ID information, operating system, connection speed, bandwidth, browser type, referring/exist web pages, web page requests, cookie information, hardware attributes, software attributes)
• Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram)
• Usage activity concerning your interactions with the Service and/or third-party websites, networks or applications accessed through the Service (e.g., viewing habits, viewing preferences, viewing history, number of clicks on a page or feature, amount of time spent on a page or feature, identify of third-party websites, networks, etc.)
• Billing, payment and shipping information
• Electronic signature
• Photographic or video images submitted for identification or non-diagnosis or treatment purposes
• Information about third parties that you refer to us (e.g., name, email, and/or other contact information, relationship)
• Statements or content (e.g., comments, videos, photographs, images) and information about such statements or content, which you submit or publish on or through the Service or which are accessed via your public or linked social media pages (e.g., Facebook, Twitter, Instagram)
• Any other information you provide when you contact or communicate with us
 
If you use your mobile device to visit, access or use the Service, then additional categories of information that we collect may include:
• Your name associated with your mobile device
• Your telephone number associated with your mobile device
• Your geolocation
• Your mobile device ID information
• With your express consent, your contacts and/or contact information (e.g., names, telephone numbers, physical addresses, email addresses, photos) stored on your mobile device
• With your express consent, information about third-party software applications on your mobile device (including, without limitation, general software apps, downloadable software apps, social media apps)
 
We also collect information on behalf of your providers, which may include, but is not limited to:
• Health and medical data you submit for diagnosis or treatment purposes, including information in any questionnaires or surveys you complete for these purposes
• Information about previous doctors or other healthcare providers you visited
• Date of visit
• Images or videos you share for diagnosis or treatment purposes
• Communications with providers
 
How Information Is Collected

NWL might collect information directly from you when you use the Service; when you register with or subscribe to the Service or obtain any products or services available through the Service; when you “sign in,” “log in,” or the like to the Service; when you allow the Service to access, upload, download, import or export content, or otherwise interact with your computer, mobile device, or any other device to visit, access or use the Service or online accounts with third-party websites, networks, platforms, servers or applications (e.g., your online social media accounts, your cloud drives and servers, your mobile device service provider); or whenever NWL asks you for such information, for example, when you process a payment through the Service or when you answer an online survey or questionnaire. In addition, if you or a third party sends NWL a comment, message or other communication (for example email, letter, fax, phone call, or voice message) about you or your activities on or through the Site and/or the App, then NWL may collect any information provided therein or therewith.

In addition to the information we collect directly from you, we may also collect certain information from providers who provide treatment or other services to you in connection with the Service. This information may include, but is not limited to, diagnoses, treatment plans (including prescription details) and notes.

We may also receive information from third parties that pay for your care or provide you with treatment, laboratory care or prescription medication, which may include, for example, your prescription history, insurance policy, insurance eligibility and coverage, and laboratory test results.

Use of Information
 
NWL might use various tracking, data aggregation and/or data analysis technologies, including, for example, the following:
 
• Cookies, which are small data files (e.g., text files) stored on the browser or device you use to view a website or message. They may help store user preferences and activity and may allow a website to recognize a particular browser or device. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. Cookies may record information you access on one page of a website to simplify subsequent interaction with that website, or to help streamline your transactions on related pages of that website. Most major browsers are set up so that they will initially accept cookies, but you might be able to adjust your browser’s or device’s preferences to issue you an alert when a cookie is downloaded, or to block, reject, disable, delete or manage the use of some or all cookies on your browser or device. Cookies can be set by the website owner (i.e., us), or they can be set by third parties (e.g., Facebook, Google, etc.). Cookies are used to help us speed up your future activities or to improve your experience by remembering the information that you have already provided to us. Third party cookies may also be used to enable analytics (e.g. Google Analytics) or advertising functionality (e.g., ad re-targeting on third-party websites) that enables more customized services and advertising by tracking your interaction with our Service and collecting information about how you use the Service.
• Flash cookies, which are cookies written using Adobe Flash, and which may be permanently stored on your device. Like regular cookies, Flash cookies may help store user preferences and activity, and may allow a website to recognize a particular browser or device. Flash cookies are not managed by the same browser settings that are used for regular cookies.
• Web beacons, which are pieces of code embedded in a website or email to monitor your activity on the website or your opening of the email, and which can pass along information such as the IP address of the computer or device you use to view the website or open the email, the URL page on which the web beacon is located, the type of browser that was used to access the website, and previously set cookie values. Web beacons are sometimes used to collect advertising data, such as counting page views, promotion views or advertising responses. Disabling your computer’s, device’s or browser’s cookies may prevent some web beacons from tracking or recording certain information about your activities.
• Scripts, which are pieces of code embedded in a website to define how the website behaves in response to certain key or click requests sent by the user. Scripts are sometimes used to collect information about the user’s interactions with the website, such as the links the user clicks on. Scripts are often times temporarily downloaded to the user’s computer or device from the website server, active only while the user is connected to the Site and/or the App, and deactivated or deleted when the user disconnects from the website.
• Analytic tools and services, which are sometimes offered by third parties, and which track, measure and/or generate information about a website’s or program’s traffic, sales, audience and similar information, and which may be used for various reasons, such as, for example, statistical research, marketing research, and content ratings research, and conversion tracking.
• Advertising services: We may use data about how you browse and shop to show you ads for us or our advertising partners that are relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you, and ad networks to which we belong may use your browsing activity across participating websites to show you interest-based advertisements on those websites. Interest-based ads are ads presented to you based on your browsing behavior to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing the Platform or third-party sites not owned by us. Currently, we do not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. If you would like more information about these practices, please click, https://optout.aboutads.info/#!/
 
Examples of analytic tools and services and advertising services we use include:
 
• Meta Platforms. We use Meta platforms, such as Facebook and Instagram) (collectively called,“Meta”), for web analytics and advertising services. These services allow us to keep track of what users do after they see or click on a Meta  advertisement, keep track of users who access our Platform or advertisements from different devices, and better provide advertisements to our target audiences. The data from Meta is also saved and processed by Meta. Meta can connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Meta’s Data Policy which can be found at, https://www.facebook.com/about/privacy/.  Please click here if you would like to withdraw your consent for use of your data with Meta https://www.facebook.com/settings/?tab=ads#=.
 
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Platform. Google Analytics uses cookies, to help our Platform analyze how users use our Platform. You can find out more about how Google uses data by visiting “How Google Uses Data When You Use Our Partners’ Sites or Apps” located at www.google.com/policies/privacy/partners/. For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
 
• Other Third-Party Tools. We use other third-party tools that allow us to track the performance of our Platform. These tools provide us with information about errors, app and website performance, and other technical details we may use to improve our Platform and/or our Service.
        
• Please be advised that if you choose to block, reject, disable, delete or change the management settings for any or all of the aforementioned technologies and/or other tracking, data aggregation and data analysis technologies, then certain areas of the Platform might not function properly.

By visiting, accessing or using the Service, you acknowledge and agree in each instance that you are giving NWL permission to monitor or otherwise track your activities on the Service, and that NWL may use the technologies listed above, as well as other tracking, data aggregation and data analysis technologies.

In addition, in connection with providing the Service, we and our affiliates and service providers may use your information, for a number of purposes, including, but not limited to:
 
• Verifying your identity;
• Confirming your location;
• Administering your account;
• Fulfilling your requests;
• Processing your payments;
• Facilitating your use of the Service and/or products or services offered through the Service;
• Communicating with you by letter, email, text, telephone or other forms of communication;
• Providing you with information about the Service;
• Providing you with customer support;
• Providing you with information about third-party businesses, products and services;
• Developing, testing or improving the Service and content, features and/or products or services offered via the Service;
• Identifying or creating new products, services, marketing and/or promotions for NWL or the Service;
• Promoting and marketing NWL, the Service, and the products and/or services offered via the Service;
• Improving user experiences with the Service;
• Analyzing traffic to and through Service;
• Analyzing user behavior and activity on or through the Service;
• Conducting research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research, and other activities related to NWL, the Service or products and services offered via the Service;
• Monitoring the activities of you and others on or through the Service;
• Placing and tracking orders for products or services on your behalf;
• Protecting or enforcing NWL’s rights and properties;
• Protecting or enforcing the rights and properties of others (which may include you);
• When required by applicable law, court order or other governmental authority (for example, in response to a subpoena or other legal process); or NWL believes in good faith that such use is otherwise necessary or advisable (for example, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations or properties of NWL, a user of the Service, which may include you, or anyone else who may be harmed by such activities or to further NWL’s legitimate business interests).
 
We may de-identify your information and use, create and sell such de-identified information, or any business or other purpose not prohibited by applicable law.
 
Disclosure of Information

We may disclose your information to third parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, we may disclose your information to:
 
• Our third-party and service providers (collectively “vendors”) to assist us with the activities outlined in the “Use of Information” section above;
• Our vendors that provide services to enable us to provide the Service, such as the hosting of the Service, data analysis, IT services and infrastructure, customer service, e-mail delivery, and other similar services;
• Our vendors that provide services to enable us to run our business and administrative operations, such as legal and financial advisory services, auditing services, analytics and similar services;
• Our vendors that provide services to enable us to promote and advertise the Service and the products and/or services offered via the Service, such as ad platforms or ad-retargeting services, as well as comply with contact removal requests or requirements, such as mailing list removal services, do not call registries, and similar services;
• To pharmacies and providers to enable them to provide services to you via the Service and to collect payment on their behalf;
• Our vendors as we believe necessary or appropriate to comply with applicable laws; and
• Third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party.
 
We may de-identify your information and disclose such de-identified information for any purpose not prohibited by applicable law.

Data Retention

We may retain your information for as long as we believe necessary; as long as necessary to comply with our legal obligations, resolve disputes and/or enforce our agreements; and/or as long as needed to provide you with the products and/or services of the Service. We may dispose of or delete any such information at any time, except as set forth in any other agreement or document executed by us or as required by law.

Transactions

In connection with any transaction that you conduct through the Service (for example, the purchase or sale of any products or services through the Service), you may be asked to supply certain information relevant to the transaction, such as your credit card number and expiration date, your billing address, your shipping address, your phone number and/or your email address. By submitting this information, you agree that we may disclose that information to third parties for the purpose of facilitating the transaction.

All credit card, debit card and other monetary transactions through the Service occur through an online payment processing application(s) accessible through the Service. This online payment processing application(s) is provided by NWL’s third-party online payment processing vendors, which currently are Stripe (“Stripe“).

Additional information about Stripe, its privacy policy and its information security measures (collectively, the “Stripe Policies”) should be available on the Stripe website located at https://stripe.com/privacy or by contacting Stripe directly. Reference is made to the Stripe Policies for informational purposes only and are not incorporated into this Privacy Policy. NWL has a contract with Stripe but does not control Stripe or its operations.

Third Parties

We are not responsible for the privacy practices of any third parties, including, without limitation, the manufacturer of your mobile device, and any other third-party mobile application or website to which our Service may contain a link. These third parties may at times gather information from or about you. We do not control and are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of each website and application you visit and use.

Consumer Privacy Rights
Residents of certain states may have additional personal information rights and choices. To learn more about any rights that may be applicable to you as a resident of one of these states and how to exercise those rights, please see our State Privacy Law Addendum. We will not discriminate against you for exercising your privacy rights.

Consent to telehealth
We provide a website through which you can obtain an online visit with an independent, licensed health care professional (a “Provider“) and mail order pharmacy services for any medications prescribed to you (collectively, the “Services“). The Services constitute a form of telehealth, which involves the delivery of health care services using electronic communications between a health care provider and a patient who are not in the same physical location. We believe that telehealth has the potential to provide a number of benefits, including convenient, discreet, and affordable care. Telehealth may be used for diagnosis, treatment, follow-up and/or patient education. Telehealth may include, but is not limited to:
• Electronic transmission of medical records, photo images, personal health information or other data between a patient and a Provider;
• Interactions between a patient and a Provider via audio, video and/or asynchronous data communications, such as secure messaging and email; and
• Use of data from remote monitoring devices, medical devices, and sound or video files.
The website and information systems used in the Services incorporate network and software security protocols to protect the privacy, security, and integrity of your health information.

Possible Benefits of Telemedicine
• Telehealth can make accessing medical care easier, more efficient, and less expensive.
• You can obtain medical care and treatment at times that are convenient for you.
• You can interact with providers without the necessity of an in-office appointment.
Possible Limitations of Telehealth
• Information transmitted to your Provider may not be sufficient to allow for appropriate medical decision making or your Provider may not be able to provide medical treatment for your condition via telehealth, and you may be required to seek alternative care.
• The inability of your Provider to conduct certain tests or assess vital signs in person may in some cases prevent the Provider from diagnosing or treating you or identifying that you need urgent medical care.
• Your medical care could be delayed due to technological failures that interrupt the Services.
• Data security protocols or safeguards could fail and cause a breach of your identified health information.
• Due to the nature of the Services and regulatory requirements in certain jurisdictions, your treatment options, especially pertaining to certain prescriptions, may be limited.
By accepting this Consent to Telehealth, you acknowledge your understanding and agreement to the following:
• I have read this Consent to Telehealth carefully, and understand the risks and benefits of the use of telehealth in my medical care and treatment.
• I give my informed consent to receive medical care and treatment by telehealth from Providers affiliated with NWL.
• I understand that the delivery of health care services via telehealth is an evolving field and that the use of telehealth in my medical care and treatment may include uses of technology not specifically described in this consent.
• I understand that while the use of telehealth may provide potential benefits to me, as with any medical care service no such benefits or specific results can be guaranteed. My condition may not be cured or improved, and in some cases, may get worse.
• I understand that I have a duty to answer questions about my health and medical history honestly and accurately, and to keep all of my health care providers, including my Provider, up-to-date on any changes in my health, symptoms, treatments, or medications.
• I understand that withholding or providing inaccurate information about my health and medical history in order to obtain treatment may result in harm to me, including, in some cases, death.
• I understand that my Provider may determine in his or her sole discretion that my condition is not suitable for treatment using telehealth, and that I may need to seek medical care and treatment in-person or from an alternative source.
• I understand that the Services enable coordination and communication with a Provider and do not replace my relationship with any existing health care provider.
• I understand that I cannot obtain emergency care through the Services, and I should call 9-1-1 and seek immediate medical treatment if I am experiencing a medical emergency.
• I understand that my information, including my identified health information, will be collected, used, shared, and protected as described in the Privacy Policy.
• I understand that I have access to all of my health and wellness information pertaining to my telehealth consultation with my Provider in accordance with applicable laws and regulations.
• I understand that NWL my Provider will share my telehealth record with my other health care providers only with my consent and at my request. I understand that I can have my telehealth record sent to my other health care providers by emailing NWL at support@getnwl.com and providing my consent along with my health care provider’s name, address, and phone number.
• I understand that a technical failure affecting the Services may result in the loss of my information and/or interrupt my online visit. In addition to any disclaimers that I agreed to by accepting the Terms of Use, I agree to hold NWL harmless for any loss of information or delay in care resulting from a technical failure.
• I understand that I can withhold or withdraw this consent at any time by emailing NWL at support@getnwl.com with such instruction. Otherwise, this consent will be considered renewed upon each new telehealth consultation with a Provider.
• I agree and authorize NWL and my Providers to collect, use, and share my information, including my identified health information and other information regarding the telehealth exam, as described in NWL Privacy Policy and for any other purposes permitted by law, including for treatment, payment, and health care operations purposes.
All capitalized terms used in this Consent to Telehealth but not defined herein have the meanings assigned to them in the Terms of Use. For avoidance of any doubt, the terms “NWL“, “we“, “us“, or “our“ refer to NWL and the terms “you“ and “yours“ refer to the person using the Services.

Miscellaneous

We strive to use reasonable physical, technical and administrative measures to protect information under our control. However, you must keep your Account password secure and your Account confidential, and you are responsible for any and all use of your Account. If you have reason to believe that the security of your Account has been compromised, please notify us immediately in accordance with the “Contacting Us” section below.

When using the Service, you may choose not to provide us with certain information, but this may limit the features you are able to use or may prevent you from using the Service all together. You may also choose to opt out of receiving certain communications (e.g., newsletters, promotions) by emailing us your preference. Please note that even if you opt out, we may still send you Service-related communications. We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy.
 
NWL may supplement, amend, or otherwise modify this Privacy Policy at any time. And changes will be posted on the NWL website and will be effective as of the “Last Updated” date. It is your responsibility to carefully review this Privacy Policy each time you visit, access or use the Service.

Contacting Us

If you have any questions about this Privacy Policy, please contact us by email at support@getnwl.com or by regular mail at:

NWL
9723 Sorbonne Loop, Seffner, FL 33584
Attn: Privacy Officer

We will attempt to respond to your questions or concerns promptly after we receive them.

Last Updated: January 22, 2024