Privacy Policy

Updated: November 28, 2023 

 

This Privacy Policy governs the manner in which NGW Holdings, LLC, its affiliates, and subsidiaries,
(collectively “NGW,” “we,” “us,” or “our”) collects, uses, maintains and discloses personal information
collected when users (“you,” “your”) visit this website and the websites controlled by us. This Privacy
Policy applies to the site and communications generated via the site. This Privacy Policy also applies when
you interact with us offline. For example, if you provide your contact information to us inside a store or
a live event. Please read this Privacy Policy carefully so that you understand our privacy practices.

Table of Contents

1. Scope
2. Personal Data We Collect
3. How We Use Personal Data
4. Disclosures of Personal Data
5. Cookies and Other Tracking Mechanisms
6. Security
7. How Long We Retain Personal Data
8. Your Privacy Choices
9. Personal Data of Minors
10. External Links
11. Changes to this Policy
12.  Contact Us

1. Scope

This privacy policy (“Policy”) explains how we process personal data from customers and visitors to our
websites (“Sites”) and users of our products and services (“Services”).

This Policy does not apply to the personal data of employees or job applicants or to information that is
exempt under applicable laws. We may provide additional notices when needed to clarify our privacy
practices in specific circumstances.

2. Personal Data We Collect

While the personal data we collect varies depending upon your use of our Services and our interactions
with you, we may collect personal data from you, from third-party sources, and automatically:

Personal Data Collected Directly from You. We may collect the following personal data from you:

• Customer Service and Support. When you contact us for support or other customer service
requests, we maintain support tickets and a record of your request or related communications.
For example, where you use one of our support request forms, we may collect details about you
including your name, phone number, email address, and the nature of your request.
• Account Services. When you register or create an account, we may collect your name, email
address, address, phone number, company name, whether you work in the industry, account
name, and password.

• Communications. We collect the information you provide such as contact information and
records of our communications.
• Sweepstakes, contests and promotions. If you participate in the sweepstakes, contests and
promotions that we offer, we may collect your name, age, email address, and other registration
information related to sweepstakes, contests, and promotions.
• Surveys. When you fill out a survey, we collect your response, which depends on the type of
survey, but may include satisfaction with a product or Service.
• Events and Other Information. We collect personal data related to your registration for and
participation in our events.
• Other Information. We may collect other personal data that you consent to or would reasonably
expect based on the nature of the circumstances, including by not limited to Name, Date of Birth,
Demographic information, Driver’s License or Other Government ID, Address, account
credentials, purchase information, email address, phone number.

Personal Data Collected from Third Parties. We may collect personal data about you from third party
sources such as public databases, advisors and agents, affiliates and subsidiaries, Internet service
providers, operating systems and platforms, regulators, government entities and law enforcement, data
brokers and analytics providers, advertising and marketing companies, business partners, business
customers, social media platforms, or other third parties.

• We may receive lead and prospect information from third parties about prospective customers
that may be interested in our Services. We may also engage with third parties to enhance or
update our customer information.
• If you post information about us or engage with us on third party platforms, we may collect
personal data about you from that third party platform or account. These third-party platforms
and services control the information they collect and share about you. For information about
how they may use and disclose your information, including any information you make public,
please consult their respective privacy policies.

Personal Data Collected Automatically. When you visit our Sites or Services, we and third parties may
collect information, including personal data, through the use of cookies, pixel tags, and other similar
technologies such as:

• Device and Browsing Information. When you visit our Site, we may collect information, which
may be considered personal data under certain laws, such as IP address, browser type, domain
names, access times, date/time stamps, operating system, language, device type, unique or online
identifiers, Internet service provider, referring and exiting URLs, clickstream data, and similar
device and browsing information.
• Activities and Usage. We also collect activity information related to your use of the Site, such as
information about links clicked, searches conducted, features used, items viewed, time spent on
certain pages, your interactions with us, log file information, and other activity and usage
information.

• Location Information. We may also collect or derive general location information about you, such
as through your IP address.

3. How We Use Personal Data

Generally, we use personal data for the following purposes:

• Providing Services and Support. To provide and operate our Services, communicate with you
about your use of our Services, provide troubleshooting and technical support, respond to your
inquiries, fulfill your orders and requests, process your payments, communicate with you, and for
similar Service and support purposes.
• Communications. To respond to your questions and fulfill your orders and requests, to allow you
to participate in interactive features, to seek your views or comments and to send you
communications, which you have requested or that may interest you, and to notify you of changes
to our Services.
• Analytics and Improvement. To better understand how users access and use the Services, and
our other products and offerings, and for other research and analytical purposes, such as to
evaluate and improve our Services and business operations, to develop our Services and features,
and for internal quality control and training purposes.
• Customization and Personalization. To tailor the content we may send or display on the Services,
including personalized help and instructions, and to otherwise personalize your experiences.
• Marketing and Advertising. To send you information about our Services such as offers,
promotions, newsletters, and any other information that you sign up to receive, and to manage,
analyze, measure, and improve our advertising campaigns.
• Loyalty/rewards program. If you are a member of our loyalty/rewards program, we use your
personal information to administer that program.
• Planning and Managing Events. For event planning and management, including registration,
attendance, connecting you with other event attendees, and contacting you about relevant
events and Services.
• Research and Surveys. To administer surveys and questionnaires, such as for market research or
customer satisfaction purposes.
• Security and Protection of Rights. To protect the Site and Services and our business operations,
to prevent and detect fraud, unauthorized activities and access, and other misuse, where we
believe necessary to investigate, prevent or take action regarding illegal activities, suspected
fraud, situations involving potential threats to the safety or legal rights of any person or third
party, or violations of our terms or this Policy.
• Legal Proceedings and Obligations. To comply with the law and our legal obligations, to respond
to legal process and related to legal proceedings.
• General Business and Operational Support. Related to the administration of our general
business, accounting, auditing, compliance, recordkeeping, and legal functions.

4. Disclosures of Personal Data

In general, we may disclose and make available personal data to third parties in the following ways:

• Corporate Affiliates. We may disclose personal data to corporate affiliates as part of our
business operations, for purposes of administering our loyalty/rewards programs, and for
purposes and uses that are consistent with this Policy.
• Processors and Service Providers. We may disclose personal data to our service providers who
perform services on our behalf such as IT service providers, hosting providers, call centers, etc.
• Third-Party Advertising Networks, Analytics Providers and Social Media Platforms. We and
third-party advertising networks, search engines, social media platforms, sponsors and/or traffic
measurement services use information, that may be considered personal data in some
jurisdictions, to understand and improve the use of our Sites, for analytical purposes, to serve
targeted ads and personalize content, and to improve and measure the effectiveness of ads on
third-party sites and platforms. For more information, including how to opt out of interest- based
advertising, see Section 5 Cookies and Other Tracking Mechanisms below.

• Loyalty and rewards program. If you are a member of our loyalty/rewards program, we may
disclose your personal data to the third parties that we work with to bring you special offers.
• Compliance, governance and legal requirements. We may disclose personal data to comply
with legal and compliance obligations and to respond to legal process and related legal
proceedings. For example, we may disclose personal data in response to subpoenas, court
orders, and other lawful requests by regulators and law enforcement. We may also disclose
information, including personal data, related to litigation and other legal claims or proceedings,
for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Business Transfers. We may disclose personal data as part of commercial transactions (e.g.,
mergers, acquisitions, bankruptcy, or other similar business transactions) and in contemplation
of such transactions (e.g., due diligence).
• Other Disclosures. We may disclose your personal data for other purposes, which we will notify
you of and/or obtain your consent when required.

Aggregate and/or Deidentified Data. We may use and disclose aggregate, deidentified, and other non-
identifiable data related to our business and Services for quality control, analytics, research, development

and other purposes.

5. Cookies and Other Tracking Mechanisms

We and other third parties use cookies, pixel tags, session replay technology, and other similar tracking
mechanisms to automatically collect information about browsing activity, device type, and similar
information within our Site and Services. This information, which may be considered personal data in
some jurisdictions, is used, for example, to analyze and understand how you access, use, and interact with
our Site and Services; to identify and resolve bugs and errors in our Site and Services; to assess, secure,
protect, optimize, and improve the performance of our Site and Services; for marketing, advertising,
measurement and analytics purposes; and to personalize content on our Site and Services. We may also
deidentify or aggregate such information to analyze trends, administer our Site and Services, gather broad
demographic information for aggregate uses and for any other lawful purpose.

Cookies. Cookies are alphanumeric identifiers used for tracking purposes. Some cookies allow us to make
it easier for you to navigate while others are used to enable a faster log-in process, to support the security
and performance of the Site, or to allow us to track activity and usage data within the Site and across
websites.

Pixel Tags and Similar Technologies. Pixel tags (sometime called web beacons or clear GIFs) are tiny
graphics with a unique identifier, similar in function to cookies. We may use these tracking technologies
to understand users’ activities, help manage content and compile usage statistics, and in emails to let us
know when they have been opened or forwarded so we can track response rates and gauge the
effectiveness of our communications.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third
party companies to evaluate usage and traffic on our Sites and Services. These third-party analytics
companies use cookies, pixels, and other tracking technologies to collect usage data to provide us with
reports and metrics that help us analyze, improve, and enhance performance and user experience. To
learn more about Google’s privacy practices, please review the Google Privacy Policy at

https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-
out Browser Add-on to prevent your data from being used by Google Analytics at

https://tools.google.com/dlpage/gaoptout.

Cross-Device Tracking. We and third parties may use the information we collect about you within our Site
and on other third-party websites and services to help us and these third parties identify other devices
that you use (e.g., a mobile phone, tablet, other computer, etc.) to interact or engage with us or the Site.

6. Security

No data transmission over the Internet is guaranteed to be 100% secure. As a result, while we strive to
protect your personal data, we cannot guarantee or warrant the security of any information collected
through our Site. You use our Site and provide us with your personal data at your own risk.

7. How Long We Retain Personal Data

Your personal data will be retained until such time as needed to fulfill the purposes and uses for which it
was collected as outlined in this Policy. If you request that we delete your personal data from our
databases, please note we may still retain your personal data as necessary to comply with our legal
obligations and regulatory requests, to resolve disputes, and to enforce our agreements.

8. Your Privacy Choices

Marketing Communications. We may send periodic promotional and operational emails, or other similar
communications to you in accordance with applicable law. You may change your preferences by following
the instructions provided to you in the communication. If you opt-out of receiving promotional emails
from us, we may still send you communications about your account or any Services you have requested
or received from us.

Industry Ad Choice Programs. You can also control how participating third-party ad companies use the
information that they collect about your visits to our Site and those of third parties, in order to display
more relevant targeted advertising to you. You can obtain more information and opt-out of receiving
targeted ads from participating third-party ad networks as outlined below.

• U.S. Users: aboutads.info/choices (Digital Advertising Alliance).

• EU Users: youronlinechoices.eu (European Interactive Digital Advertising Alliance)
• Canada Users: youradchoices.ca/choices/ (Digital Advertising Alliance of Canada)

Cookie Settings. You can set your browser to block certain cookies or notify you when a cookie is set; you
can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent
your device from accepting new cookies, how to have the browser notify you when you receive a new
cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site,
but some features may not function. If you come to our Site from a different device or from a different
browser on the same device, you will need to apply your cookie settings for that browser and/or device
as well.

9. Personal Data of Minors

This site is intended for persons 21 years of age and older. The Site and Services are not designed for
minors, and we do not knowingly collect personal data from individuals under 21 years of age, children or
minors.

If you learn that your child has provided us with personal information without your consent, you may alert
us at legal@naturesgraceandwellness.com. If we learn that we have collected any personal information
from anyone under 21 years of age, we will promptly take steps to delete such information.

10. External Links

Our Sites and Services may contain links to third-party websites or features. Any access to and use of such
linked websites or features is not governed by this Policy, but instead is governed by the privacy policies
of those third parties. We are not responsible for the information practices of such third parties, including
their collection of your personal data. We encourage you to review the privacy policies and terms for any
third-party websites before proceeding to those websites or using those features.

11. Changes to this Policy

If we decide to change or update our Policy, we will post those changes on this page. Your continued use
of the Site and our Services is subject to our most up-to-date Policy, posted here. If we make any material
changes, we will notify you by an update on our Site.

12. Contact Us

If you have any questions about this Policy or our privacy practices or if you need assistance relating to
your personal data, you may contact us via email at legal@naturesgraceandwellness.com or by phone at
309-784-2056.