Imprint

Privacy Policy

Your privacy matters to us.

Last Updated: [10/17/2024]

Welcome to 21 Impact—creator of the xponetiq app, which has been developed with the intention of providing users tools that may enhance brain health, helping users boost their focus, bring mental clarity and promote overall well-being. This Privacy Notice explains how 21 Impact Labs, Inc. (collectively referred to as “21 Impact”) collects, uses, discloses, and otherwise processes personal data in connection with the xponetiq mobile application, the xponetiq website, as well as any other product, service, or application that references or links to this Privacy Notice. We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. Please refer to the Region-Specific Disclosures section below for additional disclosures that may be applicable to you.

This Privacy Notice does not address our privacy practices relating to 21 Impact job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you sign up for our mailing list, register for an account, make an online purchase, or otherwise contact us or interact with us.

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us:

Contact Information, including email address and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
Account Information, including email address, username, account credentials or one-time passcodes, age, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for customer support purposes.
Health and Wellness Information, including information about your sleep, exercise, and eating habits. We use this information to provide you with our products and services.
Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number). Please note that we use third-party payment providers, including Stripe, to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy notice. To view Stripe’s privacy policy, please click here.
Feedback and Support Information, including the contents of custom messages sent through the forms, including our email addresses or other contact information we make available to customers. We use this information primarily to investigate and respond to your inquiries, to communicate with you via email and to improve our products and services.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time.

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.
Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, to offer communications features such as live and automated chat, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties:

Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across all 21 Impact entities. To provide our products and facilitate our services, 21 Impact entities receive personal data from other 21 Impact entities for purposes and uses that are consistent with this Privacy Notice.
Single Sign-On: We may provide you the ability to log in to our services through certain third-party accounts you maintain. When you use these single sign-on protocols to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system (such as by your username) and confirm you successfully authenticated through the single sign-on protocol. This information allows us to more easily provide you access to our products and services.
Mobile Sign-On: We may provide you the ability to log in to our mobile applications or authenticate yourself using facial, fingerprint, or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint, or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials. For more details, please refer to the biometric authentication guides offered by your device provider.
Social Media: When you interact with our services through other social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.
Advertisers, Influencers, and Publishers: We engage in advertising both on our services and through third-party services. Advertisers, influencers, and publishers may share personal data with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser.
Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services as a part of or in connection with our services. For example, certain of our products and services allow our customers to integrate third-party services. If you choose to leverage these third-party service integrations, we may receive confirmation from our business partner regarding whether you are an existing customer of their services.
Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
Manage our organization and its day-to-day operations;
Communicate with you, including via email;
Facilitate the relationship we have with you;
Request you provide us feedback about our product and service offerings;
Address inquiries or complaints made by or about an individual in connection with our products or services;
Create and maintain accounts for our users;
Verify your identity and entitlement to our products and services;
Market our products and services to you, including through email and social media;
Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services;
Identify and analyze how you use our products and services;
Infer additional information about you from your use of our products and services, such as your interests.
Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Use), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of 21 Impact and others;
Facilitate business transactions and reorganizations impacting the structure of our business;
Comply with contractual and legal obligations and requirements;
Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:

To Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across 21 Impact entities. To provide our products and facilitate our services, 21 Impact entities disclose personal data to other 21 Impact entities for purposes and uses that are consistent with this Privacy Notice.
To Marketing Providers: We coordinate and share personal data with our marketing providers in order to advertise and communicate with you about the products and services we make available.
To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
To Business Partners: We may share personal data with our business partners, or we may allow our business partners to collect personal data directly from you in connection with our services. Our business partners may use your personal data for their own business and commercial purposes, including to send you information about their products and services.
To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.
To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services.
In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.
To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
- to detect, suppress, or prevent fraud;
- to reduce credit risk and collect debts owed to us;
- to protect the health and safety of us, our customers, or any person; or
- as otherwise required by applicable law.
With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.

Your Privacy Choices

The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal data depending on your location or residency. Please refer to our Region-Specific Disclosures below for information about additional privacy choices that may be available to you.

Communication Preferences

Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails).
Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended.

Withdrawing Your Consent

Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.

Automatic Data Collection Preferences

You may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

Targeted Advertising Preferences

We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform.

In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.
Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://www.optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program.
European Interactive Digital Advertising Alliance: The European Interactive Digital Advertising Alliance similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://www.youronlinechoices.eu to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the European Interactive Digital Advertising Alliance’s program.
Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://www.optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program.
Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services. Instead, it means that the online ads you do see from relevant program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

Modifying or Deleting Your Personal Data

You may delete your account by choosing the “Delete Account” option in your Account Settings menu. If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at [email protected]. We may not be able to modify or delete your personal data in all circumstances.

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:

Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as you mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Children’s Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.

Retention of Personal Data

We will usually retain the personal data we collect about you for no longer than reasonably necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time as required under applicable law or as needed to resolve disputes or protect our legal rights.

To determine the appropriate duration of the retention of personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal data is no longer reasonably necessary for the purposes outlined above, we will either delete or deidentify the personal data or, if that is not possible (for example, because personal data has been stored in backup archives), we will securely store the personal data and isolate it from further active processing until deletion or deidentification is possible.

Third-Party Websites and Services

Our services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (Member States of the European Union together with Iceland, Norway, and Liechtenstein), the United Kingdom, or Switzerland, please click here for additional European-specific privacy disclosures, including a description of the personal data rights made available to individuals located in those jurisdictions under applicable law.
Washington and Nevada Residents: If you are a resident of Washington or Nevada, please click here for additional consumer health data disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please email [email protected].

ADDITIONAL EUROPEAN ECONOMIC AREA, UNITED KINGDOM, AND SWITZERLAND PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Notice by providing additional information about our personal data processing practices relating to individuals who access our services or otherwise interact with us from the European Economic Area (“EEA”), United Kingdom (“UK“), and Switzerland. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Notice.

Controller Details and Privacy Contacts

EEA, UK, and Swiss Controller

21 Impact Labs, Inc. (“21 Impact”), a company duly incorporated and organised under the laws of the United States, having its registered address at 21 Impact Labs AG, Unter Altstadt 28, 6300 Zug, Switzerland, is the “controller” responsible for the processing of personal data in connection with our EEA, UK, and Swiss services and operations. This means 21 Impact determines and is responsible for how your personal data is used. You may contact 21 Impact via email [email protected].

Additional Questions or Complaints

If you have a concern about our processing of personal data, you have the right to lodge a complaint with the Data Protection Authority where you reside, where you work, or where an alleged violation of the law has occurred. Contact details for applicable Data Protection Authorities can be found using the links below:

European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en
United Kingdom: https://ico.org.uk/global/contact-us/
Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

We would, however, appreciate the chance to handle your concerns directly prior to a complaint being filed, so please contact us directly at [email protected] if you have any concerns.

Purposes and Legal Bases of Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

Contract: Where the processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract with you. This applies to any processing where you sign a contract with us, for example when you become our customer or deliver services to us as a vendor or contractor. This may also include processing necessary for the performance of our Terms of Use.
Legitimate Interest: Where the processing is necessary for the purposes of a legitimate interest that are not overridden by your interests or fundamental rights and freedoms (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you regarding our services).
Vital Interest: Where the processing is necessary to protect the vital interests of you or another person (e.g., to protect your physical safety).
Public Interest: Where the processing is necessary to perform tasks carried out in the public interest or in the exercise of official authority vested in us (e.g., to cooperate in an ongoing law enforcement investigation).
Legal Obligation: Where the processing is necessary to comply with our legal obligations (e.g., to maintain a record of your personal data to comply with laws and regulations related to bookkeeping, accounting, taxation, and employment).
Consent: Where we have your consent for the processing (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw your consent at any time.

You are not required to provide personal data to us, but we do rely on your personal data to provide certain of our products and services. For example, we need your personal data to facilitate and deliver an order that you request. If you choose not to provide us with your personal data, we may not be able to provide you with a service or product you request. We will inform you at the point that we collect personal data from you if the provision of certain personal data is mandatory or optional for receipt of our products and services.

Automated Decision-Making and Profiling

We do not conduct automated processing of personal data, including profiling, for the purposes of making decisions about you.

Retention of Personal Data

The criteria used to determine the period of time for which personal data about you will be retained varies depending on the legal basis under which we process your personal data:

Contract: Where we are processing personal data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Legitimate Interest: Where we are processing personal data based on legitimate interests, we generally will retain the information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects.
Vital Interest: Where we are processing personal data based on vital interests, we generally will retain the information for the period of time necessary to protect the vital interests of the relevant person plus some additional limited period of time that represents any applicable statute of limitations for legal claims that could arise out of the related events.
Public Interest: Where we are processing personal data to perform tasks carried out in the public interest or in the exercise of official authority vested in us, we generally will retain the information for a reasonable period of time based on the public interest / official authority, taking into account any obligations we may have to retain the information for a longer period of time.
Legal Obligation: Where we are processing personal data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfill the legal obligation plus some additional limited period of time that represents the statute of limitations for legal claims that could arise from the legal obligation.
Consent: Where we are processing personal data based on your consent, we generally will retain the information for the period of time necessary to fulfill the purposes for which you have provided your consent.

In certain circumstances, we may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved. In all cases, in addition to the purposes and legal bases identified above, we consider the amount, nature and sensitivity of personal data, as well as the potential risk of harm from unauthorized use or disclosure of personal data, in determining the relevant retention period.

International Transfers of Personal Data

We operate and engage third-party partners and providers in various jurisdictions. Therefore, we and our third-party providers may transfer personal data to, or store, access, or process personal data in, a country other than the one in which it was collected, including, but not limited to, the United States. The country to which personal data is transferred may not provide the same level of protection for personal data as the country from which it was transferred.

We may transfer personal data about you outside of the EEA, UK, and Switzerland, and when we do so we rely on appropriate or suitable safeguards recognized under applicable law, including adequacy decisions, standard contractual clauses, and the EU-US Data Privacy Framework. If you would like more information on the specific safeguards we use (and obtain a copy of such safeguards, where applicable), please contact us at [email protected].

Adequacy Decisions

We may transfer personal data about you to countries that the relevant regulatory authority have deemed to adequately safeguard personal data, either automatically or in connection with a specific safe harbor framework.

Standard Contractual Clauses

Certain regulatory authorities have adopted standard contractual clauses, which provide safeguards for personal data transferred outside of the originating jurisdiction. We may use these standard contractual clauses when transferring personal data to a third country that has not been deemed to adequately safeguard personal data.

Your Additional EEA, UK, and Swiss Privacy Choices

Subject to certain limitations at law, you may be able to exercise the following rights:

Right to Access: The right to obtain confirmation of whether we are processing personal data about you, access to and a copy of the personal data we are processing about you, and information relating to its processing, including:
- The categories of personal data being processed;
- The purposes of the processing;
- The categories of the sources of the personal data;
- The categories of recipients to whom the personal data have been or will be disclosed;
- The envisaged period for which the personal data will be stored, or the criteria used to determine that period;
- Any automated decision-making or profiling performed in connection with your personal data; and
- The safeguards relied upon for the transfer of personal data to any third country.
Right of Portability: The right to obtain a copy of the personal data we have collected about you in a structured, commonly used, and machine-readable format, and the right to transmit that personal data to another controller without hindrance.
Right to Rectification: The right to correct or update any personal data about you that is inaccurate or incomplete.
Right to Restriction of Processing: The right to require us to limit the purposes for which we process your personal data if the continued processing of the personal data in this way is not justified, such as where the accuracy of the personal data is contested by you.
Right to Withdraw Consent: The right to withdraw your previously provided consent to our processing of your personal data. Please note withdrawing your consent will not affect the lawfulness of our use of your personal data before your consent was withdrawn, nor our processing of personal data pursuant to a different lawful basis for processing.
Right to Erasure: The right to have us erase your personal data if the continued processing of that personal data is not otherwise justified.

Please note that if the exercise of these rights limits our ability to process personal data, we may not be able to provide our services to you, or otherwise engage with you in the same manner.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by completing our online form found here.

To exercise your right to object as it relates to the use of automatic data collection technologies (including cookies) that facilitate our online targeted advertising activities, please follow the steps set forth in the Automatic Data Collection Preferences section of the Your Privacy Choices section of our Privacy Notice to further exercise control over automatic data collection technologies.

Before processing your request to exercise certain rights (taking into account the confidential nature of any personal data we maintain), we will need to verify your identity and confirm you are accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form to include email address and/or the date of your last transaction with us].

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity as needed to protect your personal data or locate your information in our systems, or where you are not accessing our services or otherwise interacting with us from the EEA, UK, or Switzerland.

Washington and Nevada Consumer Health Data Privacy Notice

Effective Date: 10/17/2024

This Consumer Health Data Privacy Notice (the “Consumer Health Notice”) supplements the 21 Impact Privacy Notice and applies to personal information relating to your health, including personal information defined as “consumer health data” and similar terms (collectively referred to as “Health Information”) under applicable laws, including but not limited to Washington State’s My Health My Data Act and Nevada’s similar statute (SB 370) (collectively, the “Consumer Health Privacy Laws”).

Our Collection and Use of Consumer Health Data

The term “Consumer Health Data” as used in this Consumer Health Privacy Notice means any personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status as defined in the Consumer Health Privacy Laws. We collect Consumer Health Data that you voluntarily provide to us and that is reasonably necessary for us to provide you with the products and services that you request. For example, when signing up for an account, of if you otherwise share with us such data, we may collect certain limited information about your eating, sleeping, and exercise habits.

We may process and/or use your Consumer Health Data (including with your consent where required by the Consumer Health Privacy Laws) for the following purposes:

To manage and provide the Service.
To manage, provide, maintain, and improve the business.
To respond to your questions, concerns, and other requests for assistance.
To customize your browsing experience on the Service.
For market research and providing insights into consumer health behaviors/conditions.
To build and enhance consumer profiles.
To create anonymous, aggregated, or de-identified data

We may also combine your Consumer Health Data with other personal information we collect directly from you or receive from other sources.

Sources of Consumer Health Data

The Consumer Health Data we collect depends on the context of your interactions with our Service and, in most cases, is information that you decide to share with us.

Our Disclosure of Consumer Health Data

We may share the categories of Consumer Health Data set forth above as follows:

Service Providers: We work with a variety of service providers who help us process your Consumer Health Data, such as to facilitate the operation of our Sites and Services and to support our communications, and advocacy programs.
Business Transactions: We may take part in or be involved with a business transaction, such as a merger. We may disclose Consumer Health Data to a third-party during the negotiation of or in connection with such a transaction.
Legal Obligations and Rights: We may disclose Consumer Health Data to third parties: in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal processes; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law.
With Your Consent: We may disclose Consumer Health Data about you to other service providers or publicly with your consent or at your direction. For example, with an individual’s consent or at their direction we may post their testimonial on our Sites or Services-related publications.

Your Privacy Rights

You may have the following rights with respect to your Consumer Health Data:

Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.
Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent.
Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all third parties to whom we have disclosed your Consumer Health Data delete such data.

How to Exercise Your Privacy Rights

To exercise any of the privacy rights set forth above or to review data, please submit a request to [email protected].

Before processing your request, we will need to authenticate your identity. To authenticate your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional information from you, including, but not limited to, your email address and phone number.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to authenticate your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for our decision.

Appealing Privacy Rights Decisions

If your request to exercise a right under the Laws is denied, you may appeal that decision by contacting us at [email protected].

Changes to this Consumer Health Data Privacy Notice

We may update this Consumer Health Notice from time to time. When we make changes to this Consumer Health Notice, we will notify you by changing the date at the beginning of this Consumer Health Notice. All changes shall be effective from the date of publication unless otherwise specified.