NUTRINOS PRIVACY POLICY

This Privacy Policy explains how Nutrinos handles personal information that we collect online, through our websites (referred to as “Nutrinos Websites”) and apps and through our offline interactions with you (collectively, the “Services”). This Privacy Policy does not apply to information collected from residents of countries other than the Thailand, or to third-party websites to which Nutrinos Websites may link. Your use of Nutrinos Websites and Services which link to this Privacy Policy are subject to this Privacy Policy.

Please read this Privacy Policy before using Nutrinos Websites, or Services or submitting personal information to us.

On occasion, Nutrinos may offer apps, special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that

explain how any information you provide will be collected or processed in connection with the Programs. You should review the terms applicable to these Programs before interacting or participating in the Program.

“Personal information” is information that identifies you as an individual, or could reasonably be used to identify you and is collected by Nutrinos or its third-party partners. Examples of personal information include your name, your postal address and your telephone number. “Personal information” does not include information that is aggregated with other users’ information (other than members of your household) or is anonymized and not associated with you or your household, such as your device or usage information.

Nutrinos collects information in a few different ways:

• Information you submit or choose to provide. Nutrinos collects Personal Information that you enter into data fields on Nutrinos Websites
• Information you give us permission to collect from you or another source
• From healthcare professionals
• Through our websites and mobile apps
• From contract research organizations and clinical trial investigators
• From your participation in Nutrinos programs or clinical trials
• From third party service providers, data brokers or business partners
• From industry and patient groups and associations
• Automatically from devices you use to connect to our Services (See “Cookies and Other Tools” below)
• Information provided by Nutrinos partners
• From public sources including, but not limited to, social media and other websites that enable social sharing
• Information from government agencies, public or third-party information sources

From time to time, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties. We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online. To protect your privacy, you should not provide Nutrinos with any information that is not specifically requested.

You may also give us permission to access certain personal information maintained by other service providers. For example, you may link your social media or Google account to Nutrinos, which allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check those policies before granting Nutrinos access. You agree that we are not responsible for any acts or omissions by these social media service providers.

If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Policy.

• Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
• Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
• Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history and medications     an individual may take, including the dosage, timing, and frequency, pregnancy status and due date) we collect in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports
• Information regarding parents or legal guardians
• Any information you provide in connection with applying to or participating in a patient assistance or support program (such as financial need information)
• Payment-related information we need to complete a transaction (such as credit card number and financial account information)
• Personal Information provided on Business Reply Cards to enrol in programs or Services
• Information provided for Sweepstakes, Coupons, or Giveaways
• Personal Information provided at consumer and healthcare professional conferences and/or trade shows
• Username and password that you may select in connection with establishing an account on our websites or mobile apps
• Your photograph, social media handle or digital or electronic signature
• Publicly available information
• Internet activity, such as your Internet Protocol (“IP”) address, browsing history, your search history and information on your interaction with the Services and our advertisements
• Device information
• Geolocation data, e.g., your physical location or movements (See “Cookies and Other Tools” below)
• Inferences are drawn from other personal information listed above, to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes
• If you are accessing Nutrinos websites or apps on your mobile device, you may also choose to provide us with location data. To protect your privacy, you should not provide Nutrinos with any information that is not specifically requested
• Any adverse event information

• Professional credentials, educational and professional history, institutional and government affiliations, information included on a resume or curriculum vitae, education and work history (such as work experience, education and languages spoken)
• Information about the Nutrinos programs, products and activities with which you have engaged
• Details about our interactions with you, your prescribing of our products and the agreements you have executed with us
• Any information you choose to provide about yourself or your household
• Information collected in connection with Nutrinos hosted events or activities you attend or participate in
• Professional licensure/accreditation information needed to provide and maintain continuing education certification of attendance and records
• Publicly-available information related to your practice, such as license information, disciplinary history, prior litigation and regulatory proceedings, and other due diligence related information

We may use the personal information we collect about you with information obtained from other sources, such as public databases, social media platforms and other third parties. For example, we may use public information, information collected through other third-party data aggregators and other third-party sources, to confirm contact or financial information, to verify licensure of healthcare professionals or to better understand your interests by associating demographic information with the information you have provided.

How Nutrinos uses your information depends on how you interact with our Services. Nutrinos will use the Personal Information you provide through Nutrinos Websites to respond to your questions and to provide you efficient customer service.

Nutrinos may also use your information for other purposes, such as to:

• Provide our products and services to you and make them better
• Develop new products and services
• Fulfill your requests
• Provide customer service
• Send you administrative communications regarding Nutrinos’ products or services
• Notify you about special promotions or offers
• Invite you to participate in surveys about our products, services or other market research
• Better understand the interests of our customers and visitors who use our Services
• Maintain Nutrinos’ online Services such as our websites and apps
• Monitor, detect and prevent fraud, improper activity and ensure Company policy compliance
• Conduct research including secondary and follow-on research
• Determine an individual’s eligibility to participate in Nutrinos programs
• Process payments
• Evaluate how you and other users interact with our online services
• Protect Nutrinos and our users
• Secure our online services including our network, websites and apps
• Conduct research related to our current interactions with you
• Debug the site and service to identify and repair errors that impair existing intended functionality
• Defend ourselves in litigation and investigations and to prosecute litigations
• Comply with our legal and regulatory obligations

Nutrinos may also use information collected from you or about you to offer you customized content, including to:

• Recognize new or past visitors to our websites or apps
• Remember your personal preferences
• Show you more relevant and meaningful advertisements based on your interests

Nutrinos may also use your information for other purposes disclosed to you from time to time.

In addition, some of our applications and mobile-optimized sites may have location- based features. To deliver these features, we may collect and use location data provided  by your mobile device. For example, we may offer shopping features that allow you to get information about local merchants. By using such applications, you consent to the collection and use of your mobile device location data for purposes of delivering these location-based features.

We may use personal information collected from any of the sources listed in the “How Does Nutrinos Collect Personal Information?” section of this policy for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our Services, identifying usage trends and determining the effectiveness of our promotional campaigns.

We may aggregate and/or de-identify data about customers and site visitors and use it for any purpose, including product and service development and improvement activities. We may also combine information we gather about you on our Nutrinos Websites and Services with our offline records, as well as records provided by third parties. We use this consolidated information to help us better design Nutrinos websites, products and services to communicate information to you, to enhance our marketing and research activities, to serve you more relevant advertising and for other purposes, as disclosed to you from time to time.

Nutrinos may share your information within the Nutrinos family of companies.

We do not sell your personal information. However, we share personal information with our vendors, contractors, business and service partners, or other third parties

(collectively, “Service Providers”). Examples of Service Providers include analysis firms,

advertisers, payment processing companies, customer service and support providers, email, IT services and SMS vendors, web hosting and development companies and fulfillment companies. Service Providers also include our co-promotion partners for products that we jointly develop and/or market with other companies.

Some Service Providers may collect personal data on behalf of Nutrinos. These third parties may be provided with access to personal data needed to perform their functions. In addition, Nutrinos’ practice is to require its Service Providers to keep your personal information confidential and to use personal information only to perform functions for Nutrinos.

If Nutrinos sells all or part of one of its product lines or divisions, your information may be transferred to the buyer. Nutrinos reserves the right to disclose your information to respond to authorized information requests from government authorities, to respond to valid judicial requests, to address national security situations, to provide security and investigate potential fraud, or when otherwise required by applicable law.

Nutrinos may also disclose your personal information as required by law to any competent law enforcement body, regulatory or government agency, court or other third party where we believe the disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request or legal process served on us, or to protect the safety, rights, or property of our customers, the public, Nutrinos or others, and to exercise, establish or defend Nutrinos’ legal rights.

Nutrinos may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose. Nutrinos may disclose your non-personal information to third parties for those third parties’ own advertising or marketing purposes.

Nutrinos, its vendors and partners, may collect information about you by using

cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). Nutrinos does this on Nutrinos Websites and in emails that we, or our third-party partners, send you. We use this information to better understand, customize and improve user experience with our websites, Services and offerings as well as to manage our advertising. This information can make your use of our Services (including our websites) easier and more meaningful by allowing Nutrinos and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide you with more relevant advertisements based on your interests, analyze trends and otherwise administer and improve our Services. Such information may be collected by Nutrinos’ advertising vendors and other third-party partners. If we have collected your personal information, we may associate this personal data with information gathered through these tools.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org.

You can also control Flash cookies which we may use on certain Nutrinos websites and apps from time to time by clicking here. Why? Because Flash cookies cannot be controlled through your browser settings. Choices you make are both browser and device-specific.

Here are some of the types of information collected when visiting Nutrinos Websites:

Log data: When you use Nutrinos websites and apps, our servers automatically record information (“log data”), including information that your browser sends whenever you visit an Nutrinos website or app or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the webpages you visited that had Nutrinos features, browser type and settings, the date and time of your request, how you used websites and cookie data.

Cookie data: Depending on how you are accessing Nutrinos’ online Services, we and our Service Providers may use “cookies” (a small text file sent by your computer each time you visit our sites, unique to your Nutrinos account or your browser) or similar technologies, to record log data. When we use cookies, we may use “session” cookies (that last until you close your browser) or “persistent” cookies (that last until you and/or your browser delete them). For example, we may use cookies to remember your personal preferences, such as sections of the website that you visit frequently, your user ID, or other settings so you do not have to set them up every time you visit Nutrinos Websites, and we may use cookies to serve you relevant advertising tailored to your interests. Some of the cookies we use are associated with your Nutrinos account (including personal information about you, such as the email address you gave us), and other cookies are not.

We may use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Social media plugins and data. In addition, our websites and apps may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit any of our online Services, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our websites. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our Services, the social plugins allow that social media website to receive information that you have visited our Services. The social plugins also allow the social media website to share information about your activities on Nutrinos Websites with other users of their social media services. Nutrinos does not control any of the content from the social plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

If you choose to link your social media or Google account to Nutrinos, this allows us to obtain information from those accounts (such as your friends or contacts). The information we obtain from these services often depends on your settings or the applicable provider’s privacy policies, so please check these policies before granting us access. You agree that we are not responsible for any acts or omissions by these social media service providers. If you give us permission to access this information, we will use it for the purposes described in this Privacy Policy.

Device information. In addition to log data, we may also collect information about the device you are using to access our Services, including what type of device it is, what operating system you are using, device settings, unique device identifiers and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. For example, different types of information are available depending on whether you are using a Mac or a PC, or an iPhone or an Android phone. To learn more about what information your device may make available to us, please also check the policies of your device manufacturer or software provider.

Interest Based Advertising. Nutrinos hopes to deliver to you advertising for products and services you need or want. Nutrinos, its vendors and partners, use common tracking tools, such as cookies, pixels, web beacons, and similar technologies, to automatically collect information about users for purposes of enhancing their online experience and delivering more meaningful advertisements. Like many companies, Nutrinos may also utilize third-party advertising vendors and other partners to collect this information.

Like most companies, we place advertisements where we think they will be most relevant to customers. One way we do so is by allowing network advertising companies with whom we work to place their own Tools when an individual visits Nutrinos websites and apps. This enables the network advertising company to recognize individuals who have previously visited Nutrinos websites and apps and to serve you ads based on your web browsing activity, purchases, interests and/or other information—a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”).

These advertising companies may also use these types of technologies to recognize you  across the devices you use, such as a mobile phone or a laptop, and serve you ads on websites you visit and applications you use.

Retargeting. One way in which we deliver more meaningful advertisements is through a common form of online advertising known as “retargeting” or “remarketing.”

Retargeting works by serving ads on one site based on an individual’s online activities on a different, unrelated site. For example, if you look at StediPlus® products on an Nutrinos Website, you may later see an advertisement for SteadiPlus® products when you visit third-party sites. To do this, Nutrinos or its advertising vendors may use a device ID, cookie, pixel, web beacon or similar technology placed by Nutrinos or our third-party vendor when you visit Nutrinos websites or apps or third-party websites or apps. The placing of these cookies or other technologies on your device may enable you to be identified across multiple websites. You should consult the privacy policies of our vendors and other websites that you visit to understand how they collect and use your data.

Nutrinos’ Do Not Track Policy. Some browsers have Do Not Track (“DNT”) features that allow you to tell a website not to track you. These features are not all uniform, and some browsers may not be set up to honor such requests. Nutrinos honors the AdChoice DNT signals. Options you select are browser and device specific. Please be aware that limiting the ability of websites to set cookies, however, may worsen your overall user experience, and in some cases Nutrinos Websites will not work properly without cookies, local storage and similar technologies.

Certain Nutrinos Services may ask whether you wish to opt-out or opt into our contact lists for offers, promotions and additional services that may be of interest to you.

Marketing

If you no longer wish to receive promotional marketing materials from us on a going- forward basis, you may opt-out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from Nutrinos by following the instructions included in the relevant programs. We will endeavor to comply with your request as soon as reasonably practicable. Please be aware that once you have opted out of these programs, you will no longer receive any associated discounts, coupons or promotional offers that are part of the program.

However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our Privacy Policy or Terms of Use).

Your Privacy Choices

You may have certain rights and choices regarding our processing of your personal data. Depending on your jurisdiction, applicable law may entitle you to additional consumer rights, including the right (with certain limitations and exceptions) to:

• Know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed, and with whom your personal information was shared
• Access a copy of the personal information we retain about you
• Request deletion of your personal information

We reserve the right to verify your identity in connection with any requests regarding Personal Information to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals, or their authorized representatives, to exercise rights with respect to that information. If you are an authorized agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorized to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request, in whole or in part, we will endeavour to inform you of the denial and provide an explanation of our actions and the reasons for the denial.

We will not restrict or deny you access to our Services because of choices and requests you make in connection with your Personal Information. Please note, certain choices may affect our ability to deliver the Services. For example, if you sign up to receive marketing communications by email, then ask Nutrinos to delete all of your Personal Information, we will be unable to send you marketing communications, including applicable offers and promotions.

You may exercise any of your rights in relation to your personal information by contacting us using the details provided under the “How Can I Contact Nutrinos”.

It is Nutrinos’ practice to take steps to secure our Services; however, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the Internet, especially personal information related to your health. Nutrinos cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to Nutrinos Websites or apps, you must weigh both the benefits and the risks. Nutrinos Websites or apps may link to third-party websites that are not controlled by Nutrinos or subject to an Nutrinos privacy policy. You should check the privacy policies of such third-party websites before submitting personal information.

Nutrinos does not knowingly collect or use any information from children (we define “children” as minors younger than 13). We do not knowingly allow children to order our products, communicate with us, or use any of our online services. If you are a parent and become aware that your child has provided us with information, please contact us using one of the methods specified below and we will work with you to address this issue.

We may provide links to websites and other third-party content that is not owned or operated by Nutrinos. The websites and third-party content to which we link may have separate privacy notices or policies. Nutrinos is not responsible for the privacy practices of any entity that it does not own or control.

If you provide any Personal Information through a third-party site, your interaction and your personal information will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this privacy policy.

Any information you provide to Nutrinos may be stored and processed, transferred between and accessed from Thailand, where Nutrinos is headquartered, and other countries which may not guarantee the same level of protection of personal data as the one in which you reside. However, Nutrinos will handle your personal data in accordance with this privacy policy regardless of where your personal data is stored/accessed.

If you have questions about your information, please contact us by clicking on the “Contact Us” or “Connect with Us” link on the website you are visiting. Alternatively, you may send a letter to the following address:

Nutrinos Limited
Attention: 44/419, Ammarin Nivet 1, Phahonyothin Road, Anusawaree, Bangkhen, Bangkok 10220 Thailand

Phone number: +66 81 818 0886
Hours: Monday through Friday, 9:00 a.m. to 6 p.m. GMT+7 (Bangkok, Thailand)

In all communications to Nutrinos, please include the email address used for registration (if applicable), the website address or the specific Nutrinos program to which you provided Personal Information (e.g., nutrinos.co, steadilife.com, academy.nutrinos.co, etc.) and a detailed explanation of your request. We will do our best to respond to all reasonable requests in a timely manner.

Nutrinos reserves the right to amend this Privacy Policy at any time. If Nutrinos changes its privacy practices, a new Privacy Policy will reflect those changes and the effective date of the revised Privacy Policy will be set forth in this paragraph. This Privacy Policy was last updated on July 20, 2021 and is effective as of that date.