In addition to the purposes for processing Personal Data listed above, we may process your Personal Data for our business and commercial purposes, including:   

 

• The Personal Data we collect allows us to conduct marketing activities and keep you posted on Willow’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences here.  

• We also use Personal Data to help us create, develop, operate, deliver, and improve our products, services, content, and advertising, and for loss prevention, anti-fraud purposes and complaint handling purposes.  

• We may use your Personal Data, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Willow        account holders.  

• From time to time, we may use your Personal Data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this administrative and service-related information is important to your interaction with Willow, you may not opt out of receiving these communications.  

• We may also use Personal Data for internal purposes such as accounting, auditing, data analysis, and research to improve Willow’s products, services, and customer communications.   

  

How Does Willow Collect Personal Data?   

  

We collect Personal Data and other information from or about you in connection with the products and services that we provide to you, including our mobile applications. This information may be collected directly from you or automatically from your interactions with us such as when you browse our website, download our mobile applications, use our products and services, contact us for additional information, and/or otherwise interact with us. This may include the contents of messages you send in chats and message boards in our mobile apps.   

  

When you access and engage with websites and mobile applications or interact with our online media and content including advertisements, we automatically collect information about your browser, device, and activity. We (and our service providers) may use various tracking technologies (e.g., cookies, pixel tags (or web beacons), etc.) to collect information automatically. The information collected may include details about your behavior on our website and mobile application. These technologies may also be used to collect information about you over time and across different websites, mobile applications, and devices.  

  

To learn more about our use of cookies and other similar tracking technologies and how you can control them, please review “Willow’s Use of Cookies and Other Tracking Technologies.”   

  

We may also collect Personal Data from or about you via other online sources, including:  

 

• Blogs/Forums. Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your Personal Data from our blog or community forum, contact us at privacy@willowlabs.ai  In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so and why.  

• Testimonials. We display personal testimonials and other endorsements of satisfied customers on our website. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@willowlabs.ai.  

• Social Media Features and Widgets. Our website includes social media features and widgets, such as the Facebook Like button, sharing features from Twitter, LinkedIn or Google+, or interactive mini programs that run on our website. These features and widgets may collect your IP address, which webpage you are visiting on our website, and may set a cookie to enable the feature and widget to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.  

  

Automated Processing and Decision Making  

  

We may use automated processing without human intervention to provide AI-based coaching, food selection identification, personalized information and fitness recommendations for sustainable habits.   

  

Under certain applicable data protection laws, you may have the right to oppose or request the cessation of  certain automated decision making and to request the review of decisions made based on automated processing by following the procedure described in the “Your Rights and Choices and How to Exercise Them” section, to the extent that it produces undesired legal effects to you or significantly affects your interests, rights or freedoms.  

  

Willow’s Use of Cookies and Other Tracking Technologies   

  

We and our partners, affiliates, or analytics or service providers, may use any of the tracking technologies listed below to analyze trends, administer the website and mobile application, track users’ movements around the website and mobile application, learn about user behavior, improve our product and services, and gather demographic information about our user base as a whole. Willow may also use this information in our marketing and advertising services.   

 

• Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.  

• Local Storage (HTML5). Local Storage (HTML5) to provide certain features on our website, to display advertising based on your web browsing activities, and/or to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.  

• Social Media Features and Widgets. Our website includes social media features and widgets, such as the Facebook Like button, sharing features from Twitter, LinkedIn or Google+, or interactive mini programs that run on our website. These features and widgets may collect your IP address, which webpage you are visiting on our website, and may set a cookie to enable the feature and widget to function properly.   

• Web Beacons. Pages of our website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Willow, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics such as recording the popularity of certain website content and verifying system and server integrity. Willow also uses cookies and other technologies (beacons, scripts, and tags) to remember Personal Data when you use our website, online services, and applications. Our goal in these cases is to make your experience with Willow more convenient and personal.  

• Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data and from where the application was downloaded. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.  

  

We may maintain or associate the Personal Data we collect using these tracking technologies with Personal Data we collect in other ways or receive from third parties, including through purchased marketing data about our customers. This helps us to improve our website and to deliver a better and more personalized service, which enables us to:

 

• Estimate our audience size and usage patterns.  

• Store information about your preferences, allowing us to customize our website according to your             individual interests.

• Speed up your searches.  

• Recognize you when you return to our website.  

• Analyze trends in the aggregate and administer the website.   

  

Please review “Your Rights and Choices and How to Exercise Them” below for information on how to control our use of cookies and other tracking technologies.   

  

Can I opt out of behavioral tracking and how does Willow respond to browser signals and other mechanisms that enable me to exercise choice about behavioral tracking (*Do not track disclosure)?  

  

We partner with third parties to display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies to gather information about your activities on this website and other sites to provide you advertising based on your browsing activities and interests.   

  

If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here. If you are located in the European Union, United Kingdom or Switzerland, click here. Please note this does not opt you out of being served ads; you will continue to receive generic ads. Please review “Your Rights and Choices and How to Exercise Them” below for additional information.   

  

*Do Not Track Disclosure: Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites visited by the user about the user's browser DNT preference setting. Willow does not currently commit to responding to browsers' DNT signals with respect to the Willow’s websites, in part, because no common industry standard for DNT has been adopted, including no consistent standard of interpreting user intent.  

  

Is data collected from Children? Can data collected inadvertently from children be deleted?  

  

Willow does not knowingly collect Personal Data from children under the age of 18.  If you are a parent or guardian who knows or has discovered that your child under the age of 18 has submitted his or her Personal Data or other information without your consent, permission, or authorization, upon your request, we will promptly remove your child’s Personal Data or other information from our database, cease the use of such information, and direct any other party with access to such information to do the same.  

  

How Does Willow Share Information It Collects?  

  

We will share your Personal Data, such as, your IP address, mailing address, phone number, email address, contact preferences, and credit card information with third parties only in the ways that are described in this Privacy Policy. We do not sell your Personal Data to third parties.   

  

As stated above in “What Data Does Willow Collect?” and “How Does Willow Use and Disclose Such  

Information?”, we share Personal Data with our service providers and marketing and advertising entities so that they can provide services on our behalf. For example, they may provide services on our behalf to help us with our business activities such as fulfilling your orders, delivery of product, processing credit card payments, conducting marketing surveys or offering customer service.   

  

We may also disclose your Personal Data.  

 

• As required by law, such as to comply with a subpoena or similar legal process.   

• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.   

• If Willow is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.   

• To any other third party with your prior consent.   

  

Your Rights and Choices and How to Exercise Them   

  

Depending upon where you reside, certain choices and rights with respect to your Personal Data may be available to you under applicable data protection laws. Please note any rights described in this Privacy Policy are subject to exemptions and other limitations under applicable law. If you have questions about what rights may apply to you, please contact us.   

 

• Request Access, Deletion or Changes to Personal Data. We take reasonable steps to keep your data accurate and complete. If you would like us to consider providing you access to, or making a correction to, your Personal Data maintained in our records, please send your request to us at privacy@willowlabs.ai. To protect your privacy and security, we may take reasonable steps to verify your identity before granting access or making corrections. Moreover, if you believe that one of your contacts has provided us with your Personal Data and you would like to request that it be removed from our database, you may delete your Personal Data by contacting us at privacy@willowlabs.ai.   

  • Mobile App: You can also easily access certain information at https://www.willowlabs.ai or via our mobile app including up-to-date information regarding recent orders, Personal Data (including name, email, health/wellness data, communications, and personalized preferences), payment settings (including credit card information, promotional certificate, and gift card balances), e-mail notification settings (including product availability alerts, deliveries, and newsletters). When you contact us, please include “Privacy Rights Request” in the subject line of your email.  

​

• Marketing Communications. We may use your Personal Data to inform you about our products or services that we believe will be of interest to you and/or to provide you with our newsletter. If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or contacting us at privacy@willowlabs.ai. You may also choose not to provide the Personal Data that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.  

​

• Control Cookies and Other Tracking Technologies. You can withdraw your consent to allow for our use of certain Cookies, change your browser settings, and delete the Cookies already stored on your computer at any time. Please note that if you delete, or choose not to accept, Cookies, you may not be able to utilize the features of the Sites to their fullest potential.   

  

In addition to the cookies Willow delivers to your computer or mobile device through this website or the Services, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons. For example, we may use a web analytics tool that helps us understand how visitors engage with our Services. Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this website or on other websites or Services. You can make choices about how we use cookies and tracking technologies here.  

  

You can control Cookies in several ways:   

 

• Browser Settings: You may be able to control Cookies through your browser settings. You may be able to set your browser settings to use our Sites without cookie functionality. Please note that if you block Cookies, some services functions and Sites may be unavailable, and we will not be able to present personally tailored content and advertisements to you. Your browser may provide you with some options regarding Cookies here.  

  

Your browser provider may also use certain Cookies or other tools that we cannot control. For more detailed information about how to disable or administer your cookie settings in your web browser, please refer to the applicable page for the browser you are using:  

​

• Safari: https://help.apple.com/safari/mac/8.0/#/sfri11471   

• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en   

• Microsoft Edge / Internet Explorer: https://support.microsoft.com/en-us/windows/manage-cookiesinmicrosoft-edge-view-allow-block-delete-and-use-168dab11-0753-043d-7c16-ede5947fc64d  

• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences o Third Party Tools: Certain tools or organizations provide options to limit online tracking:  

  • Network Advertising Initiative: https://optout.networkadvertising.org/?c=1 

  • Google Analytics Optout Browser Add-on, click here.  

  • Adobe Analytics, click here.

• ​Cookie Management System: You can control Cookies used on the website through the “Your Privacy Choices” icon and https://www.willowlabs.ai/privacypolicy   

​

• Mobile Application Controls. We may collect certain location-based information from your device when you use our mobile application, and we may also use information to send you push notifications. You can control these features as follows:

  • Turn off Location Services: Mobile devices provide users with the ability to disable location services. These controls are located in the device's settings menu. You may opt-out of location-based services at any time by editing the setting at the device level.  

  • Push Notifications: We send you push notifications to enable link loss, a notification to let you know that your phone may not be in pairing distance with Willow’s device. Mobile devices provide users with the ability to disable push notifications. These controls are generally in your device's settings menu. You may opt-out of push notifications at any time by editing the setting at the device level.  

  

Depending on where you are located or where you are a resident, you may have certain additional rights to your Personal Data. For a description of your rights, please see the appropriate policy for additional disclosures:  

 

• ​California Residents:  Please review this Policy and see “Additional Information for California Residents” below, which provides additional information about your privacy rights [including your right to submit a “Do Not Sell or Share My Personal Information” request (i.e., to opt of the “sale” or “sharing” of your Personal Information (as defined below) by us)]. [Residents of California may also, under §1798.83, known as the “Shine the Light” law, request and obtain from us, once a year and free of charge, information about categories of Personal Data (as defined under the law) (if any) we disclosed to our affiliates for direct marketing purposes and the number of affiliates with which we shared Personal Data in the immediately preceding calendar year. As stated above, we do not sell your Personal Data to third parties for monetary compensation or as that term is traditionally defined. If you are a California resident and would like to make such a request, please submit your request and identify that you are requesting information under “Shine The Light” and send the request in writing to us at privacy@willowlabs.ai.]

​

• EU and UK Visitors. Please Review this Policy and see “Additional Information for EU and UK Residents” below.  

  

How Secure Is Information About Me?  

  

We maintain reasonable administrative, technical and physical safeguards designed to protect the Personal Data submitted to us, both during transmission and once it is received, against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. If you have any questions about the security of your Personal Data, you can contact us at privacy@willowlabs.ai.  

  

How Long Do We Keep Personal Data.   

  

We keep Personal Data for as long as your account is active or as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law, to resolve disputes, and enforce our agreements (e.g. for tax, legal, accounting or other purposes), whichever is the longer.  

  

International Transfers.   

  

Willow Laboratories is headquartered in the United States and Personal Data you provide may be processed within the United States. We may also transfer your Personal Data to an affiliate or to a third party that is located in a jurisdiction other than the one from which we collected it, including to countries that have not been deemed to have an adequate level of protection for the rights and freedoms of data subjects. If we do transfer your Personal Data to another jurisdiction, we will do so following due diligence and provided that the data recipient is subject to contractual agreements imposing obligations on it to ensure appropriate technical and organization measures are implemented and maintained at all times to prevent the unauthorized and unlawful processing of Personal Data, and the accidental loss or destruction of, or damage to, Personal Data, consistent with our obligations under applicable data protection laws. See Additional Information for EU and UK Residents for information specific to data transfers from these regions.  

  

What About Links to Third Party Sites?  

  

Our website may include links to other websites whose privacy practices may differ from those of Willow. If you submit Personal Data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.  

  

Region Specific Information.  

  

This Privacy Policy contains information on our use of your Personal Data with applicable laws and regulations including the:  

 

• EU General Data Protection Regulation (2016/679) (“EU GDPR”);  

• EU GDPR as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act  2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (the “UK GDPR”, and, together with the EU GDPR, the “GDPR”);   

• California Consumer Privacy Act (as amended with any implementing regulations, the “CCPA”);    

• Washington State’s My Health My Data Act;   

• Switzerland’s Federal Act on Data Protection (“FADP”);   

• Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”);   

• Quebec’s Private Privacy Act as amended; and   

• Mexico’s Federal Law on Protection of Personal Data Held by Private Parties (“LFPDPPP”).  

  

If you are a Washington State, Nevada, or Connecticut resident, in addition to this Privacy Policy, please review our Consumer Health Data Policy below.  

  

Please review this Privacy Policy carefully to understand what we do regarding your Personal Data and where applicable, the following sections:  

 

• If you are a California resident, please review “Additional Information for California Residents” below, for additional disclosures, our notice at collection, and a description of your rights under the CCPA.  

• If you are a resident of Canada, please review “Additional Information for Canadian Residents” below.  

• If your Personal Data is subject to the GDPR, please review “Additional Information for EU and                                 UK Residents” below.   

• If your Personal Data is subject to the Mexican data protection law, please review “Additional Disclosure for Mexico Residents” below.  
   

Additional Information for California Residents

  

This section of the Privacy Policy provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the CCPA. This section does not address or apply to our handling of publicly available information or “Personal Data” (as defined under the CCPA) that is otherwise exempt under the CCPA. Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices. Terms used in this section have the meaning ascribed to them in the CCPA.   

  

Notice at Collection and Use of Personal Information  

  

Information We Collect and How We Use Collected Information

  

Depending on how you interact with us, we may collect the categories of Personal Data listed in “What Data Does Willow Collect and How Does Willow Use and Disclose Such Information?” We may use Personal Information from you for the purposes described above in the section “What Data Does Willow Collect and How Does Willow Use and Disclose Such Information?”  

  

Sale or Sharing of Personal Information

  

We do not “sell” your Personal Data under the CCPA, meaning we do not rent, release, disclose, transfer, make available, or otherwise communicate Personal Data to another business or third party for monetary or other valuable consideration. We may disclose certain information to our service providers, advertising and marketing companies, our business partners, and other third-party vendors as directed by you. We may “share” your Personal Data, as defined under the CCPA to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, Personal Data to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, unless you opt-out either through our website or through your use of an opt-out preference signal such as global privacy control (GPC)  

  

How Long We Keep Information  

  

We retain your Personal Data as described above in the section “How Long We Keep Personal Data.”  

  

Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information                 

  

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

  

We may sell or share your Personal Data (as those terms are defined under the CCPA) for purposes of advertising and re-targeting unless you choose to opt-out as explained below. We do not knowingly sell or share the Personal Data of California Residents under 18 years old. In the preceding 12 months, we may have disclosed for business purposes the categories of Personal Data to the categories of third parties as described above in “What Data Does Willow Collect and How Does Willow Use and Disclose Such Information?”. We may also share your Personal Data with third parties as described in “How Does Willow Share Information It Collects?”  

  

Our Use and Disclosure of Sensitive Personal Information

  

Under the CCPA, certain Personal Data we collect and process may be considered “sensitive Personal Data.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive Personal Data in certain circumstances. Currently, we are not using your sensitive Personal Data for purposes that would require that we provide you with a right to limit.  

  

Your Rights Under the CCPA 

  

The CCPA provides you with the following rights, subject to certain exceptions and limitations:

 

• Right to Delete: You have the right to request we delete your Personal Data.   

• Right to Correct: You have the right to request that we correct inaccuracies in your Personal Data.   

• Right to Know: You have the right to request the categories of Personal Data we have collected about you, the categories of sources from which the Personal Data is collected, the business or commercial purpose for collecting, selling, or sharing Personal Data, the categories of third parties to whom we disclose Personal Data, and the specific pieces of Personal Data we have collected about you.   

• Request to Opt-Out of Sale or Sharing: You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. You can let us know your preference through our website (via cookie banner) or by using an opt-out preference signal such as Global Privacy Control (GPC). While we do not “sell” Personal Information in the traditional sense (i.e., for money), our use of third-party analytics and advertising Cookies may be considered “selling” and “sharing” under CCPA.    

• Right to Limit Use: You have the right to limit the use and disclose of your Sensitive Personal Information. We do not engage in uses or disclosures of Sensitive Personal Information that would trigger the right to limit use of Sensitive Personal Information under the CCPA.  

• Right to Non-Discrimination: You have the right not to be subject to discriminatory treatment for exercising your rights under the CCPA.    

  

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like Personal Data collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain Personal Data after receipt of a Request to Delete from you were permitted by the CCPA or another law or regulation.  

  

How to Submit a CCPA Consumer Rights Request   

  

To submit an access, correction, or deletion request (“Consumer Rights Request”), please email privacy@willowlabs.ai, call us at +1 (800) 610-8522, or through our website at https://www.willowlabs.ai.  

  

Before responding to certain of your request, we must first verify your identity using the Personal Data you have provided to us. You must provide us with your full name and email address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny certain requests and, if so, will explain the basis for the denial.  

  

You may designate someone as an authorized agent to submit requests and act on your behalf. With certain requests, authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.   

  

We reserve the right to reject: (1) authorized agents who have not fulfilled the above requirements, or (2) automated CCPA requests where we have reason to believe the security of the requestor’s Personal Information may be at risk.  

  

For more information about our California-privacy practices, please contact us using the details listed in the “Contact Us” section below.