INTRODUCTION

Vitacoach Solutions Inc. and our affiliates and subsidiaries ("Company" or "We") respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:
· How we collect, use, disclose, and protect the personal information of our customers and website users ("you").
· Describes the types of information we may collect from you or that you may provide when you visit the Vitacoach website at www.vitacoach.com, (our "Website").
· Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:
· On this Website.
· In email, text, and other electronic messages between you and this Website.
· Through mobile and desktop applications you may download from this Website.
· When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

This policy DOES NOT apply to information that:
· We collect offline or through any other means, including on any other Company or third-party website.
· You provide to or is collected by any third party, through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. We will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:
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· Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you ("personal information").

We provide an opportunity for any user to unsubscribe from our services or to opt-out of contact on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails.
· Business-related information, namely information that related to your business duties, including:
· title;
· duties;
· business address;
· business email address; and
· business telephone number.
· Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
· Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
· Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:
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· Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
· User contributions. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties.
· Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
· Third parties or publicly available sources, for example, our business partners.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:
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· Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
· Records and copies of your correspondence (including email addresses), if you contact us.
· Your responses to surveys that we might ask you to complete for research purposes.
· Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
· Your search queries on the Website.

You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.


Information We Collect Through Cookies and Other Automatic Data Collection Technologies  

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
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· Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
· Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
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· 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.
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The technologies we use for this automatic data collection may include:
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· Cookies (or browser cookies). A cookie is a small 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.
· Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
· 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 the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

HOW WE USE YOUR INFORMATION
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We use information that we collect about you or that you provide to us, including any personal information:
· To present our Website and its contents to you.
· To provide you with information, products, or services that you request from us.
· To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
· To provide you with notices about your account/subscription, including expiration and renewal notices.
· To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
· To notify you about changes to our Website or any products or services we offer or provide though it.
· To improve our Website, products or services, marketing, or customer relationships and experiences.
· To allow you to participate in interactive features, social media, or similar features on our Website.
· To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.]

DISCLOSURE OF YOUR INFORMATION

We do not sell or otherwise disclose your personal information to any other third party organization, except as required or permitted by law or noted below.
· To our subsidiaries and affiliates.
· In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Vitacoach's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Vitacoach about our customers and users is among the assets transferred.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

CONSENT
Depending on the nature and sensitivity of your personal information, your consent to the collection, use or disclosure of such information can be express and positive (express and positive consent may be oral, in writing or electronic) or implied (by your conduct, which may include your not exercising an option after reading our notice regarding such collection, use or disclosure – “opting out”) in which case we assume that you consent. You may withdraw your consent at any time.

DATA SECURITY
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

INDEPENDENT TRAINERS
From time to time, Vitacoach products and services may be referred to you by coaches, personal trainers and other operators (“Trainers”). Trainers are not considered employees or contractors of Vitacoach or the Vitacoach website and as such are not parties to this Privacy Policy. To the extent that Trainers choose to collect, store, use or disclose your personal information on their own behalf, Vitacoach takes no responsibility for any liability which may result from such actions.

CHILDREN UNDER THE AGE OF 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any information to or on the Website.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
Upon request, you shall be informed of the existence, use and disclosure of your personal information and shall be given access to that information. If you want to review, verify, correct, or withdraw consent to the use of your personal information you may contact us to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE
We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:
Nishant Shah
Nishant.shah@vitacoach.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

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