Privacy Policy

SCOPE OF THIS PRIVACY POLICY

In accordance with the regulation on personal data protection issued by the Federal Trade Commission (FTC), together with the California Online Privacy Protection Act (CalOPPA), Ragasa International, LLC (hereafter RAGASA) informs you that RAGASA is responsible for the personal data directly provided through the web site www.nutrioli.com (hereafter “the web site”) or through other sources permitted by law. By doing so, the “User” authorizes RAGASA to use and automatically manage your personal data and all information provided, which will form part of our data base with the objective of sharing it with our marketing and advertising supplier, “The Brand Industry México, S.A. de C.V.”, which will use it for the following purposes (among others):

Provide online services to the “User”,
Communicate with the “User”,
Carry out research and development activities,
Enforce our terms of use and agreements and prevent misuse, and
Comply with applicable laws of the United States of America.

The "User" may get in touch with The Brand Industry México, S.A. de C.V. at any time by writing to the email info@tbi.com.mx Personal data will be protected and safeguarded to avoid its damage, loss, theft, destruction, alteration, or unauthorized use.

PERSONAL DATA COLLECTED

“Personal data” is the information that identifies, is related with, describes or can reasonably be associated or linked with —directly or indirectly— any person that accesses the “web site”.

The information must always be accurate and complete. The user will always be answerable for the data provided and in no case will RAGASA be liable for its accuracy.

The information requested from the user in the “web site” or through other means permitted by law can be, without implying limitation, the following:

Personal information of the “User”, such as full name, telephone number, postal address, email, gender, photographs, date of birth, social security number,
Financial information,
Self-reported information: Information of the “User” provided through opinion surveys, participation in contests, promotions or other devices or marketing forms of potential sales entities, suggestions to improve services, references, reviews, deliveries or any other action carried out through online services,
Information on skills and abilities: By using our mobile app we can collect information provided voluntarily regarding your physical state and nutrition, such as eating and exercise habits, weight and height, and
Demographic information. If you decide to send it, we can anonymously combine personal non-identifiable information with similar information from other users.
Internet of network activity, such as browsing history and interactions with our web site.
Classifications protected under federal or the state of California laws, such as disability conditions and other characteristics
Geolocation data, such as device location.
Inferences based on previous data to create a profile on you, including your preferences and characteristics.

EXCLUSIVE USE OF OBTAINED INFORMATION

Operate, manage and maintain our commercial activities,
Provide and improve our products and services,
Get in touch with you,
Determine your eligibility to participate in programs,
Manage our employees and suppliers,
Personalize, publicize, develop, improve and sell our products and services,
Improve quality and safety and carry out research and data analysis,
Detect and prevent fraud and safety incidents,
Preserve our facilities, systems and infrastructure,
Establish commercial registries,
Carry out research and comply with legal obligations,
Exercise our defense against legal claims and to protect us, you and third parties,
Utilize for purposes which we notify you of or for which we obtain your consent, and
Use lawfully in a way compatible with the context in which the information was provided.

With respect to information collected on the utilization of our online services by the “User”, we gather personal data and on the devices used to access online services, as described below:

Service data. Information on “User” interactions with online services, such as web pages or other content, as well as actions carried out while using said services,
Registration and device information. Information on the device of the “User”, including the device’s ID, IP address, hardware model, operating system and version, name of the device, data on the use of the mobile app and aggregate information, such as “click stream”, which represents entry and exit points (including domains and URL references), statistics on traffic, web page visits and views, all of which are collected automatically,
Geolocation information. The location of the device based further to voluntary consent
Cookie information, collected through cookies, web beacons, pixel labels and other technologies that are described in more detail in the cookies and web beacons section of this privacy policy.

All data and information will be treated on the basis of the principles of legality, consent, information, quality, purpose, loyalty, proportionality and responsibility, in accordance with applicable legislation. The confidentiality of all personal data will be preserved by establishing and effectively maintaining administrative, technical and physical measures to avoid its damage, loss, alteration, destruction, misuse, illicit access or unlawful disclosure.

TRANSFER AND USE OF DATA AND INFORMATION

The owner of the personal data authorizes RAGASA to transfer the data provided to third parties that require it as part of the commercial relation with RAGASA to comply fully with business objectives and, in particular, to its marketing and advertising supplier “The Brand Industry México, S.A. de C.V.” The owner of the personal data understands and accepts that at no time will financial and other sensitive information be transmitted. In case of disagreeing with the aforementioned sharing of information, the owner must email to: contacto@nutrioli.com, in a period no longer than 5 (five) business days starting with the publication of the present notice. Failure to do so during said period means that he/she authorizes RAGASA to transmit said information.

To provide the “User” our services

We may divulge the information to external service suppliers to obtain services such as payment processing, hosting of web sites, professional services —including those related to information technology and related infrastructure—, customer service, email delivery, auditing and other similar activities required for online services and others that may be requested.

Transactions or corporate events

We may divulge information to third parties in the context of a corporate reorganization, merger, sales process, joint venture, cession, transfer or any other provision concerning a part or the whole of our business, shares or assets, including with relation to any bankruptcy proceeding or the like.

Legal compliance

We may use or divulge personal information as we deem appropriate or necessary: (1) according to applicable law, including laws with jurisdiction outside the country of residence; (2) to respond to requests by public and governmental authorities, including outside the country of residence; (3) to comply with subpoenas and other legal procedures; (4) to seek available resources or limit potential damages; (5) to protect our operations or those of our affiliates; (6) to protect our privacy, safety and legal rights, and (7) to enforce our terms and conditions.

Disclosure to third parties

We may use or divulge personal information collected for commercial purposes related to marketing and third-party access to online services. We do not share with third parties personal information related to commercial or financial dates. The later use of any personal information shared with third parties will be governed by the privacy policy of any such parties.

COOKIES, WEB BEACONS AND ONLINE ADVERTISING

What are cookies?

RAGASA and its marketing and advertising suppliers use small text files called “cookies” and other types of web site tracking technology similar to cookies such as pixel labels, web beacons and transparent GIF archives (which taken together will be referred to as “cookies”). Cookies are text files with small pieces of data that our agents and ourselves place in your computer’s browser to store your preferences. Cookies may be linked to personal information provided as a result of online interaction. A cookie usually will contain the name of the domain (internet location) where the cookie comes from, the “lifespan” of a cookie (that is to say, when it expires) and a value, generally a number generated randomly.

For more information on the use of cookies, access the site All About Cookies or visit our cookie policy on our website.

Types of cookies

Each cookie carries out one or more of the following functions:

Essential cookies: They allow the use of online services, such as remaining connected or making a purchase.
Analysis cookies: They can be first-party or third-party cookies. They track information on how online services are used, allowing RAGASA and its marketing and advertising suppliers to make improvements and performance reports. RAGASA can also use those cookies to test new functions or advertisements.
Preference cookies: They store user preferences with respect to online services.
Targeting cookies: These third-party cookies (also known as “behavioral” or “targeted” publicity) are placed by platforms or publicity networks to deliver advertisements and track performance or to deliver advertisements based on user activity.

How?

We use cookies to improve your online experience, for example, by remembering the “User” when he/she returns to visit, as well as making the content more relevant. Cookies also allow us to trace online purchases carried out through online services and to send you relevant advertisements.

Google Analytics

We use third-party analysis such as Google Analytics to collect and analyze anonymous information on the “User”. Google analytics is an analysis service provided by Google, Inc. (“Google”) to collect information on the use of online services. Google can use cookies to gather information on a user’s purchase history, visualized content, web sites visited immediately before and after viewing online services, as well as the user’s system and geographic information. The information generated by the Google cookies on the use of online services will be stored and transmitted by Google. Such information collected by Google allows us to analyze the use of online services but does not identify the “User”.

Online Advertising

We use cookies to help manage our online advertising program. These technologies (or the third-party advertising services with which we work) allow us to know which advertisements lead the user to online services. They (or the third-party advertising services with which we work) can also permit us to trace the online activity of users through time and in various web sites and online platforms, to gather statistics on our marketing efforts and deliver electronic advertisements that may be more relevant for individual consumers, thus improving customer experience. To obtain information on how tracing with advertising purposes works, and what happens when you choose the option to cancel tracing, please visit http://www.aboutads.info/choices. Also, some third-party companies may provide a mechanism to voluntarily avoid using their technologies.

SOCIAL MEDIA AND THIRD-PARTY SITES

When a user begins session in our site or enters online services through any social media service, any information provided then (or previously) is subject to the privacy policy of such social networking service. We do not control nor are responsible for the privacy policies of such networks or services. The user must consult the privacy policies of said services. If an individual publishes information in a public forum, it becomes public information. Also, we may divulge personal information to identify you to any person to whom you send communications through online services. Moreover, online services may provide links to other sites and services. If you utilize these, please consult their privacy policies. We are not responsible for the privacy practices of external sites or services.

SAFEGUARDING OF SOCIAL SECURITY NUMBER

Our policy is to use all reasonable technical, physical and administrative means to safeguard and preserve the confidentiality of your social security number, while prohibiting its illegal disclosure and/or use, by restricting access to said information. When RAGASA ceases to preserve said information, it will be shredded, destroyed, deleted or encrypted to maintain confidentiality.

UNDERAGE PERSONS

Online services are not intended for use by persons of less than 18 years. We will not knowingly collect any personal information of underage persons. If we discover that such information has been collected, we will delete it.

VERIFIABLE REQUESTS FOR DELETION, ACCESS/COPY, EXCLUSION AND DISCLOSURE

Subject to some exceptions, all users of the web site have the right to make the following requests free of charge:

RIGHT TO DELETION.

The right to request the deletion of personal information, with some exceptions, and to delete such personal information, excepting when it is necessary to preserve it for the following reasons:

Finalize the transaction for which the personal information was collected, comply with the terms and conditions of a written guarantee or to retire a product from the market, provide a product or service requested by the consumer or that can be reasonably expected in the context of an ongoing commercial relation between the company and a consumer or sign a contract between the company and the consumer.
Detect safety incidents, protect against malicious, fraudulent, deceitful or illegal activities or file a lawsuit against entities responsible for said activity.
Suppress failures to identify and repair errors that impair expected operation.
Exercise the right to free expression, assure the right of other consumers to exercise his/her right to free expression or to enjoy other rights foreseen by law.
Comply with communication laws that prohibit deletion of personal information.
Participate in public research or research endorsed by the community which is of a scientific, historical or statistical nature and in the public interest and that adheres to all the ethical guidelines and applicable privacy laws, when the deletion of the information on the part of private companies could completely impede or gravely affect the finalization of said research, if the consumer had provided informed consent.
Enable for internal uses only in case they are reasonably aligned with the consumer’s expectations, on the basis of the relation of the consumer with the company.
Comply with a legal obligation.
Use internally the personal information of the consumer lawfully in any other way that is compatible with the context in which the consumer provided said information.

Keep in mind that the large majority of personal information we collect falls within the exceptions mentioned above.

RIGHT TO ACCESS/COPY

The right to request a copy of specific personal information collected during the 12 previous months by sending an email to: contacto@nutrioli.com, to be sent without cost be it through a) electronic means in portable format and, whenever technically possible, ready to send to another entity, or by b) post. For safety reasons and in order to comply with the CalOPPA, certain types of highly sensitive personal information will not be provided, such as social security, driver license and bank account numbers. However, we will inform you if we have collected such type of information during the 12-month period.

RIGHT OF EXCLUSION/TO OPT-OUT FROM SALE

The right to exclude your personal information from sale or transmission to third parties (if applicable).

RIGHT TO KNOW/DISCLOSURE

For a maximum of twice a year, the right to request information on how we have handled your personal information during the previous 12 months, including the following:

Categories of collected personal information,
Categories of sources of personal information,
Business and/or commercial purposes for the collection or sale of personal information,
Third-party categories with whom we may have shared your personal information,
Categories of personal information we have disclosed or shared with third parties for business purposes,
The right to solicit the specific personal data collected (see above), and
Third-party categories to whom personal information of California residents has been sold and the specific category of personal information sold to each third-party category.

DATA MODIFICATION OR DELETION

We inform the “User” that he can at any time exercise his right to Revoke his Consent for the Use of his Personal Data, with respect to his Personal Data, in the following way:

Request the form to Revoke Consent and Use by writing to the following email address contacto@nutrioli.com, which you must them return properly filled-out and accompany with documents that confirm your identity and, if necessary, accredit your legal representative.
1. In case that the data provided is insufficient to locate the requested information, or if it is erroneous and imprecise, in a period of three working days we will contact you with questions or to request additional information. If we do not receive reply or if the information is erroneous or unclear, the petition will be considered as not submitted, and the request dismissed.
2. If the request is considered unfounded, our response time is of 20 working days, starting from the date of receipt of the request. The timespan to send required information will occur during 15 working days after an affirmative reply to the request has been communicated.
The information will be delivered electronically and free of charge to the email that was provided in the form to Revoke Consent and Use. The only charge that may apply is in case of justifiable delivery costs stemming from photocopies or the printing of other templates and forms. Such costs will be previously informed to the petitioner.

The petition must contain at least the following information: (a) name and address or other means to communicate the reply; (2) documents that give proof of identity or of a legal representative; (c) clear and precise description of the personal information of which a modification or deletion is requested; (d) the express petition to revoke consent for the use of your personal data and as such to cease its use; (e) any other information that facilitates the location of your personal data. The petition must be accompanied by the grounds on which the revocation of consent is requested, as well as an official identification of the owner of the data or legal representative.

RAGASA requests the “User” to update his/her information whenever it changes, as this will allow offering an efficient and personalized service.

The area responsible for handling and administering personal data is managed by: __________, who can be contacted through the following email contacto@nutrioli.com . Our business address is: 2001 Timberloch Place, Suite 500, The Woodlands, TX, 77380.

TRANSFER OF INFORMATION BY JUDICIAL ORDER

RAGASA only transmits data to fulfill obligations with customers. It will only share data as a result of a judicial order to comply with legal proceedings.

TRACKING

RAGASA takes privacy and safety very seriously. We will never use technology to track our “users” nor use as supplier third-party sites that use tracking to send out targeted advertising. RAGASA respects Do-Not-Track (DNT) configurations and will not implement and restriction regarding access to the web site’s content for users that utilize such configurations.

CHANGES TO THE PRIVACY NOTICE

We reserve the right to modify or update this privacy notice at any time, in order to take into consideration legal or judicial developments or changes to internal policies, new requirements for the offering or supply of services or products, as well as market practices. Such modifications will be notified by email that will contain a direct link to the updated Privacy Policy and be available to the public in the “web site”, under the Privacy Policy section.

ACEPTANCE OF TERMS AND CONDITIONS

This privacy notice is subject to the terms and conditions of the aforementioned RAGASA web site, constituting a legal agreement between the user and RAGASA. If the user utilizes the services of the RAGASA site, it means that he/she has read, understood and agreed to the aforementioned terms and conditions.

LEGAL AUTHORITY

If the user/customer considers that his/her data protection rights have been violated, he/she has the right to seek assistance and protection from the proper legal authority, which in this case is the Federal Trade Commission (FTC).

Drafted on: September 13, 2022.

Last update: November 14, 2022.

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