Life Extension
Global Privacy Notice
Effective Date: April 16, 2024
This Global Privacy Notice (“Global Notice”) describes how Life Extension Foundation Buyers Club, Inc. and its group of affiliated companies and subsidiaries (“Life Extension,” “our,” “us,” or “we”) collect, use, and disclose personal information about natural persons (“consumer,” “you,” or “your”), including the categories of personal information we collect, our purpose for using this information, whether such information will be sold or shared, the length of time we intend to retain this information, data rights available to you for your personal information, and how to exercise those rights.
This Global Notice applies to personal information collected by us and through our group of affiliate companies and subsidiaries, clinics, data processors, service providers, retail stores, wholesalers, and workplaces, and on or through our business systems, career center, contests & sweepstakes, electronic communications (including emails, live chat, telephone and video calls, and text messages), events, life safety & loss prevention solutions, learning management platform, live casts, mail, media players, podcasts, shopping carts, social media, webinars, websites and other offerings (each a “service,” together, the “services”).
- If you encounter difficulty accessing this Global Notice, we provide additional resources to help you in our Accessibility Notice available at www.lifeextension.com/legal/accessibility-notice.
Sections:
- What is Personal Information
- Collection and Use of Information
- Information about Children
- Sharing and Disclosure of Information
- Retention of Information
- Protection of Information
- Manage your Account Information, Orders, and Settings
- Manage your Contact Preferences & Marketing Communications
- Opt-out from Automated Decision-Making
- Opt-out from Cookies & Interest-based Advertising
- Opt-out from Marketing Communications
- Opt-out from the Sale or Sharing of Information
- Opt-out using Universal Opt-Out Mechanisms
- Data Rights & Your Privacy Choices
- Non-Discrimination for exercising your Data Rights
- Privacy & Data Protection Impact and Risk Assessments
- Breach of Personal Information
- International Data Transfers
- Country and Regional-specific Supplemental Privacy Notices
- Additional Terms Incorporated or Excluded by Reference
- Privacy Questions, Issues, and Complaints
- Controller Contacts
- Privacy & Data Protection Officer Contacts
- Changes to this Global Privacy Notice
1. What is Personal Information
When we use the term “personal information” (and its equivalent term “personal data” as defined by applicable data protection laws), we mean any information relating to an identified or identifiable natural person, and information linked or linkable to an identified or identifiable natural person. “Natural person” means a living human being.
Personal information does not include data that is publicly available or has been “aggregated” or “de-identified” (and its equivalent term “anonymized” as defined by applicable data protection laws). Aggregated and de-identified data is non-personal information. This means we have removed any personally identifiable information (including names, email addresses, postal addresses, and telephone numbers), and the remaining data cannot be reasonably used to identify you or link you to the information in question.
2. Collection and Use of Information
We collect personal information that is relevant, adequate, and necessary to accomplish the purpose for which it is collected, and we minimize the amount of personal information we collect by using privacy-enabling technologies (including key coding, pseudonymous, de-identified, anonymous, and aggregated anonymous data management practices) when it would be reasonable to do so.
We use the following legal bases when we collect and use personal information:
- With Your Consent to collect and use your personal information for one or more purposes.
- In Performance of a Contract between you and Life Extension, or for the implementation of pre-contractual measures taken at your request.
- To Comply with Legal Obligations, including: (i) to comply with applicable laws, rules, and regulations; (ii) to respond to and comply with court orders, subpoenas, and warrants, and criminal, civil, or regulatory investigations; (iii) to cooperate with government bodies and law enforcement requests; and (iv) to enforce our legal interests, exercise, prepare for, or defend our legal claims.
- To Protect the Vital interests of an Individual, including where there are reasonable grounds to believe that our failure to act (by not disclosing certain personal information) could result in risk of death or serious bodily harm to you or others.
- In Pursuit of Legitimate Interests, including to conduct business activities related to the products and services that we provide to you and others, and to operate our business.
We collect personal information about the following categories of natural persons:
- Buyers, Customers, Shoppers, and Users.
- Children, Parents and Legal Guardians (where we provide a service with parental consent).
- Clinical Trial Volunteers.
- Content Contributors and Writers (to our magazine, website, and other publications).
- Consultants, Contractors, and Interns.
- Data Recipients (for individuals receiving personal information from us).
- Distributors, Resellers, and Wholesalers(for individuals using our services).
- Employees, Former Employees, and Covered Family Members.
- Job Applicants.
- Service Providers, Suppliers, and Third-Party Partners (for individuals supporting our services).
- Speakers and Brand Ambassadors (at our events, live casts, podcasts, and webinars).
- Visitors (to our clinics, events, retail stores, and workplaces).
- Web Visitors (to our live casts, podcasts, webinars, websites and other online services).
We collect personal information from the following categories of sources:
- Information we collect directly from you depending on which services you request from us, how you engage with our services (including what personal information you choose to share on or through our services, and when communicating with us), and what specific personal information we need from you to provide these services (including information as required by applicable law).
When you create an account to access our online services, you will be asked to provide us with certain personal contact information (including your name, email address, and telephone number), which we will use to manage our relationship with you. If you intend to make a purchase, we will also need your postal address and payment information to process your orders and deliver our products to you. Furthermore, when you purchase certain restricted items from us (including laboratory tests and age-restricted supplements), we are required to collect your birth date or other personal identifying information, which we will use to confirm your age before processing these orders and to verify your identity prior to discussing your laboratory test results with you.
- Information your organization provides to us that is necessary for you to use our services under a contractual agreement we have with your organization. We require your organization to obtain your individual consent before they disclose your personal information to us, and inform you about your data rights, including your right to withdraw consent to us using your personal information.
Your employer may provide us with your personal contact information (including your name, email address, and telephone number), which we will use to create and maintain an account for you to access our online services and allow you to place orders on behalf of your employer. We may also send you transactional messages about these orders and services, and other promotional and marketing communications based on your contact preferences.
- Information we collect automatically depending on which services you request from us, how you engage with our services, and how you configured your device, browser, and email client to allow your data to be collected by our services, and when communicating with us (including emails, live chats, telephone and video calls, and text messages), which you can manage and control through your device, browser, and email client settings, and through other privacy choices described in this Global Notice.
When you visit our website, we automatically log usage data and may collect online identifiers about you, including certain information about your device, browser, non-precision geolocation, and interactions with our services. We use this information to sell and deliver our products, services and content to you and operate our business, including to prevent fraud, enable secure online purchasing, effectively use advertising campaigns and strategies, personalize content and offers, and improve offerings and customers’ experience.
- Information we collect through our Life Safety & Loss Prevention Solutions including through our access control, CCTV video surveillance, inventory management, and visitor management systems when you physically enter our clinics, retail stores, and workplaces, including in surrounding parking lot areas.
We use CCTV video surveillance systems in and around our clinics, retail stores, and workplaces to monitor and record events relating to fraud detection, theft prevention, and security. This means you should expect to be recorded where security cameras are in plain sight.
- Information we receive from other parties including our advertising, measurement and analytics, and social media partners, courier and postal delivery services, collection agencies, credit reporting agencies, data brokers, data processors, financial institutions, insurers and underwriters, government and regulatory bodies, payment processors, public records, resellers, service providers, staffing and recruiting services, and wholesalers. We may also receive personal information from persons you have designated as your authorized agent.
We take precautions before responding to requests from persons claiming to be your authorized agent by requiring them to provide us with written documentation to verify that they are authorized to act on your behalf. Depending upon the documentation they provide to us, it may contain your name, email address, postal address, telephone number, court case number, and other personal information about you, which we will only use for the purpose of verification.
We collect and use the following categories of personal information. Not all categories or examples listed are collected for all persons. Some examples may fall under more than one category depending on context.
Category of Personal Information | Examples | Sold or Shared to Third Party |
---|---|---|
Account Information | including name, contact preferences, customer number, email address, mobile SMS address, postal address, telephone number, user id and password. | Yes |
Biometric Data | including physiological, behavioral, and biological characteristics and health or exercise data that contains identifying information. | No |
Characteristics of Protected Classifications under California or Federal law | include age, citizenship, disability, gender identity, gender expression, medical conditions, military or veteran status, national origin, race, religion, and sexual orientation. | No |
Child Data | including name, birth date, Consumer Health Data, Clinical Trial Data, and Diagnostics Laboratory Data --where we provide a service with parental consent. | No |
Clinical Trial Data | including dose-ranging, health history, observations, patient-reported outcomes, safety and efficacy of biologics, trial findings, and volunteer id. | No |
Commercial Information | including records of property ownership, buying preferences, products and services purchased, obtained, or considered, other purchasing or consuming histories or tendencies, testimonials, and wish lists. | Yes |
Consumer Health Data | including personal information that is linked to a consumer and is used to identify the health condition or status of the consumer. | No |
Contact Information | including name, contact preferences, email address, mobile SMS address, postal address, and telephone number --for non-account holders. | Yes |
Credentials | including authentication keys and tokens, user id and password, password hints and challenge questions --for internal business users. | No |
Criminal Records | including self-reported records and publicly available records --used only for employment purposes. | No |
Diagnostics Laboratory Data | including data derived from analysis of biospecimens intended to detect or identify a substance, report outcomes, reference ranges, and subject id. | No |
Demographics and Socioeconomic Data | including age, birth date, ethnicity, gender, household income, marital status, number of children, occupation, preferred language, race or ethnicity --some which may include Characteristics of Protected Classifications. | No |
Device Data | including device id, device type, screen resolution, usage data, and MAC address --for devices used with our services. | Yes |
Electronic Communications | including calendaring, emails, live chats, telephone and video calls, and text messaging that we may process when communicating with you. | No |
Financial Information | including payment card information and wire transfer information --depending on which method of payment you have selected for your purchases, including expense report and payroll records --for employees. | No |
Fraud & Investigations Data | including fraudulent claims, police reports, and stolen credentials obtained from other parties --for fraud, theft, and security events. | No |
Genetic Data | including genetic sequence, inherited and acquired genetic traits data. | No |
Geocoding Data | including to convert your postal address into latitude, longitude, and map coordinates to provide you directions to or locate the nearest service provider from your home or business. | No |
Non-Precision Geolocation Data | including latitude, longitude, and map coordinates at a country, regional or city-level based on your Internet Protocol (IP) address or postal code. | Yes |
Government Identifiers | including social security, driver’s license, identification card, and passport numbers --used only for employment purposes. | No |
Health Data | including immunization and vaccination records --used only for employment purposes. | No |
Identifiers | including name, alias, electronic signature, email address, Government Identifiers, Internet Protocol (IP) address, mobile SMS address, Online Identifiers, postal address, and telephone number. | Yes |
Inferences & Profiling Data | including inferences drawn from or created based on personal information and automated processing of personal information to help determine certain personal aspects like health, personal preferences, and interests. | No |
Internet or other Electronic Network Activities | including browser history, clickstream data, clickthrough data, conversion tracking, crash data, interactions with our advertisements, emails, and services, Internet Protocol (IP) addresses, pages visited, referring/exit URLs, search history, and server logs. | Yes |
Non-Public Education Information | including degrees awarded, grades, and transcripts --used only for employment purposes. | No |
Online Identifiers | including advertiser ids, analytic ids, cookie ids, pixel tags, tracking scripts, and Internet Protocol (IP) addresses. | Yes |
Personal Information Categories listed in California Customer Records statute, Cal. Civ. 1798.80(e) | including any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including name, bank account number, health insurance information, physical characteristics or descriptions, mobile SMS address, postal address, telephone number, insurance policy number, education records, employment history, employment records, payment card number or other Financial Information, medical information, signature, and Government Identifiers. | Yes |
Professional or Employment-related Information | including employee number, beneficiary information, certifications & licenses, compensation data, disciplinary records, family plan data, performance reviews, resume, right to work documentation, training records, and work experience --used only for employment purposes. | No |
Sensitive Personal Information | including Biometric Data, Characteristics of Protected Classifications, Child Data, Clinical Trial Data, Consumer Health Data, Credentials, Genetic Data, Government Identifiers, Health Data, passwords, and payment card number. | No |
Sensory Information | including audio, visual, thermal or similar sensory information (such as photographs, video and voicemail recordings). | No |
Serious Adverse Event Data | including Contact Information, Commercial Information, Consumer Health Data, Health Data, and other information about the adverse event. | No |
User Feedback | including health quizzes, commenting to our social media posts and pages, product ratings and reviews, and surveys. | Yes |
Vehicle Data | including vehicle license plate number and parking decal number --for onsite employees. | No |
Wholesaler Account Information | including business name, contact preferences, email address, fax number, postal address, taxpayer identification number, telephone number, user id and password. | Yes |
Our purpose for collecting and using personal information includes:
- to administer benefits to our employees, former employees, and covered family members.
- to affect a product recall.
- to communicate with you.
- to comply with laws, rules, and regulations and enforce our legal interests.
- to conduct scientific and clinical research.
- to create and maintain your account and manage our relationship with you.
- to develop, sell and deliver products, services, and content.
- to effectively use advertising campaigns and strategies.
- to fulfil our contractual obligations.
- to improve offerings and customers' experiences.
- to manage and support our business operations, external relationships, and legitimate interests.
- to manage and support our employees, including onboarding, enablement, retention, and offboarding.
- to perform breach management and remediation.
- to perform employment verification and background checks.
- to personalize content and offers.
- to prevent, detect, protect against, respond to and recover from fraud, theft, and security events.
- to process and deliver contest or sweepstakes entries and rewards.
- to process and fulfill orders and transactions.
- to process Wholesaler applications.
- to provide customer service and support.
- to provide financing to your business.
- to recruit, select, and hire job candidates.
- to send you transactional messages about your account, orders and transactions, including appointment reminders, password changes, orders, deliveries, payments, refunds, renewals, and returns.
- to verify your age.
- to verify your identity.
3. Information about Children
Our online services are not directed to persons under eighteen (18) years of age, and any person using our online services represents that they are at least eighteen (18) years of age before doing so.
We do not use our online services to knowingly collect personal information from children, which we consider to be persons under thirteen (13) years of age, or the equivalent age as otherwise specified by applicable law. If we learn that a child has provided their personal information on or through our online services without appropriate parent or legal guardian consent, we will promptly delete this information.
Where a parent or legal guardian would like their child to undergo Laboratory Testing or participate in Clinical Trials to the extent permitted by applicable law, the following procedures apply:
- Collection, Processing, and Retention: we will provide notice to the parent or legal guardian and obtain their written authorization for the service and verifiable parental consent before collecting and processing personal information about their child. We will only collect personal information that is relevant, adequate and necessary to accomplish the purpose for which it is collected and retain it only for as long as is necessary to fulfil the purpose for which this information was authorized, and to comply with applicable laws, rules, and regulations. After the purpose and all requirements have been satisfied, we will promptly delete this information unless otherwise instructed by the parent or legal guardian.
- Disclosure: we will provide a separate notice to the parent or legal guardian and obtain their written authorization before disclosing personal information about their child to our service providers and third parties. Before disclosing this personal information, we will obtain written assurances from those service providers and third parties, by contract or otherwise, that they have implemented reasonable measures to maintain the confidentiality, security, and integrity of this information, including data retention and deletion procedures.
- Sale: under no circumstances do we knowingly sell personal information about children.
4. Sharing and Disclosure of Information
We engage different natural and legal persons to operate our business, manage and support our services, and perform other activities described in this Global Notice.
We share or disclose personal information with the following categories of data recipients:
- Within our Corporate Group of affiliate companies and subsidiaries to provide our services to you and support our business operations (including strategic management, legal & regulatory, finance, customer service, human resources, information technology, manufacturing, product research & development, sales & marketing, scientific & clinical research, sourcing & procurement).
- With our Contractors, Service Providers, and other Data Processors who perform services on our behalf and support our business operations, including advertisers, cloud service providers, content delivery networks, contingent labor & recruitment services, data center hosting providers, diagnostics laboratory testing services, delivery and courier services, email hosting providers, internet service providers, legal & regulatory services, measurement & analytic services, network and infrastructure management services, order fulfillment, payment processing services, rating & review services, scientific & clinical research, sales & marketing services, search engine services, telecommunication service providers, user engagement, and website hosting. We rely on appropriate contractual terms to adequately protect your personal information, including data processing addendums containing standard contractual clauses and other model clauses.
- With our Third-Party Providers who provide cross-context behavioral advertising services. These categories of third-party providers include advertisers & advertising networks, and certain measurement and analytic services (where Internet Protocol (IP) addresses are not anonymized).
- Corporate Transactions: we may assign or transfer this Global Notice, as well as share or disclose personal information covered by this Global Notice, to other parties in connection with, or during negotiations of, any sale of a company asset, merger, acquisition, consolidation, or other corporate reorganization.
- Legal, Regulatory, and Law Enforcement Bodies: we do not voluntarily disclose your personal information to government bodies or otherwise provide them access to our business systems except as required: (i) to comply with applicable laws, rules, and regulations; (ii) to respond to and comply with court orders, subpoenas, and warrants, and criminal, civil, or regulatory investigations; (iii) to cooperate with government bodies and law enforcement requests; and (iv) to enforce our legal interests, exercise, prepare for, or defend our legal claims.
5. Retention of Information
We store your personal information for as long as is necessary to provide our services to you, to operate our business (where we have legitimate interests in retaining certain information), and for as long as required to comply with applicable laws, rules, and regulations.
We minimize the amount of personal information we retain by using privacy-enabling technologies (including key coding, pseudonymous, de-identified, anonymous, and aggregated anonymous data management practices) when it would be reasonable to do so.
Where we retain personal information, we evaluate the length of time we should keep information on a case-by-case basis, taking into consideration the purpose, use, relevance, sensitivity, and any ongoing obligations requiring us to preserve this information longer, such as those reasons described above.
- For customers, we typically retain your personal information for up to six (6) years after your contractual relationship with us ends or your last account transaction occurred.
- For employees and successful applicants, we typically retain your personal information for up to six (6) years after your employment relationship with us ends.
- For unsuccessful applicants, we typically retain your personal information for up to four (4) years after we have communicated our hiring decision to you.
6. Protection of Information
We take commercially reasonable, adequate and appropriate administrative, technical, and physical security measures that are designed to protect the confidentiality, integrity, and availability of our services, and safeguard your personal information from accidental or unlawful destruction, loss, or alteration, and from unauthorized access, use, or disclosure (“security incident”).
Our security measures are implemented and maintained by a dedicated information security organization. These measures include information security policies and security incident response plans, encrypting data in-transit and data at-rest, restricting access to personal information to authorized persons, employee security training, and maintaining full and incremental backups to our services and procedures to test and restore these backup copies.
7. Manage your Account Information, Orders, and Settings
- Account Information: manage your user account settings, including updating your name, business name, mailing address, email address, and account password at mycart.lifeextension.com/account/accountsettings.
- AutoShip & Save Subscriptions: add, modify, pause or cancel your reoccurring order subscriptions at mycart.lifeextension.com/account/autoship.
- Laboratory Testing: add or modify your laboratory testing orders at mycart.lifeextension.com/account/bloodlab.
- Orders & Tracking: view order history, track orders, and buy again at mycart.lifeextension.com/account/orderhistory.
- Payment Cards: add, modify or remove your payment card information at mycart.lifeextension.com/account/paymentmanagement.
- Shipping Addresses: add, modify or remove your shipping addresses at mycart.lifeextension.com/account/shippingaddresses.
- Wish Lists: add, modify or remove your shopping cart wish lists at mycart.lifeextension.com/account/favorites.
8. Manage your Contact Preferences & Marketing Communications
Sometimes we have product announcements and promotional offers that may interest you. When we send these communications to you, we do so with your consent and through our business relationship with you. You can choose what types of communications we send to you, how you want these delivered, and opt-out (or unsubscribe) at any time at mycart.lifeextension.com/account/contactpreferences.
If you require help managing your contact preferences, contact our customer service at 1-800-678-8989.
9. Opt-out from Automated Decision-Making
Automated decision-making takes place when systems, software, or processes use your personal information to make or execute legal or similar significant decisions about you without human intervention.
We may use automated decision-making to personalize our offerings and customers' experiences (including to make product recommendations and tailoring our advertising based on your preferences and interests). Where we use automated decision-making, you can opt-out by submitting a request as further described in the Data Rights & Your Privacy Choices section to this Global Statement.
We do not use automated decision-making technologies (and its equivalent term “automated employment decision tools” as defined by applicable data protection laws) in our recruitment, selection, and hiring process.
10. Opt-out from Cookies & Interest-based Advertising
Our online services use cookies, pixel tags, tracking scripts, and similar technologies, including to authenticate users, enable secure online purchasing, deliver our products, services, and content, effectively use advertising campaigns and strategies, personalize content and offers, and improve offerings and customers' experiences. Our Cookies Notice available at www.lifeextension.com/legal/cookies-notice provides instructions on how to opt-out from or remove our cookies from your device or browser.
You may also opt-out from interest-based ads (sometimes called “online behavioral advertising”) through the following trade industry tools, which we provide links for your convenience:
- Digital Advertising Alliance is a consortium of national advertising and marketing trade groups and provides tools to opt-out from interest-based ads set by participating DAA companies and organizations:
- WebChoices available at optout.aboutads.info to opt-out using your browser.
- YourAdChoices available at youradchoices.com/token to opt-out using your email address or telephone number.
- Network Advertising Initiative is a coalition of third-party digital advertising companies and provides a tool to opt-out from interest-based ads set by participating NAI members.
- NAI Consumer opt-out available at optout.networkadvertising.org.
11. Opt-out from Marketing Communications
We use consent management platforms to manage our promotional or marketing communications and take additional steps to prevent unsolicited messages. But sometimes our messages are received by unintended recipients, which can happen when our customers changes their telephone numbers and do not update their Account Information or inform us about their new number.
If you receive an unsolicited message from us or want to opt-out (or unsubscribe) from receiving certain promotional or marketing communications from us, you can take the following steps. We will honor your request within ten (10) business days.
- Direct Mail: opt-out by contacting our customer service at 1-800-678-8989.
- Email Messages: opt-out by clicking on the “Unsubscribe” link in the email message we sent.
- Text Messages: opt-out by replying STOP to the mobile text message we sent.
For account holders, we provide additional instructions on how you can manage these marketing communications in the Manage your Contact Preferences & Marketing Communications section to this Global Statement.
If you require help performing any of these steps, contact our customer service at 1-800-678-8989.12. Opt-out from the Sale or Sharing of Information
Life Extension does not sell your personal information in the conventional sense, for money. However, we use cross-context behavior advertising services to deliver interest-based ads to you about our products and services, which may be considered a “sale” or “selling” of personal information. The Data Rights & Your Privacy Choices section to this Global Statement provides instruction on how to opt-out from this sale or sharing of your personal information.
For employees and job applicants, Life Extension does not sell or share your personal information with third parties for cross-context behavior advertising purposes.
13. Opt-out using Universal Opt-Out Mechanisms
Where your device or browser has been properly configured to transmit your privacy choices to our online services using “universal opt-out mechanisms” (including Global Privacy Control signals) our online services will honor your request and display the confirmation message “Opt-Out Request Honored” on our Cookie Consent Banner(s) and Privacy Preference Center.
If you connect to our services using different devices and browsers, you will need to be sure that each device and browser has been properly configured to transmit your privacy choices.
14. Data Rights & Your Privacy Choices
Data protection laws may provide you with certain data rights to personal information that we have collected about you. Which data rights are available to you and how often you can submit these requests depends upon your country of residence, and the nature, scope, context, and purpose of your request.
Where a parent or legal guardian has given their consent for us to collect personal information about their child, we will provide certain data rights to the parent or legal guardian to their child's information.
These rights may include:- Right to Access your personal information and be informed about what processing, sharing, or disclosure we have done with your personal information.
- Right to Correct inaccuracies to your personal information.
- Right to Delete your personal information from our business systems.
- Right to Data Portability to your personal information in a machine-readable format.
- Right to Restrict Processing to your personal information, including where you have contested the accuracy of your personal information or have objected to our purpose, legal basis or legitimate grounds to processing or retaining your personal information.
- Right to designate an Authorized Agent to act on your behalf regarding your personal information.
- Right to Opt-out from targeted advertising, the sale or sharing of your personal information (including for cross-contextual behavioral advertising purposes), or automated decision-making technologies.
- Right to Withdraw Consent to our collection, use, and disclosure to your personal information.
- Right to Appeal Decisions we have made about your personal information and data rights.
- Right to File Complaint with your applicable data protection authority.
We take steps to authenticate each request to ensure we only disclose your personal information to you and persons you have designated as your “authorized agent” (including a conservatorship, executor, or commercial data removal service) to act on your behalf regarding your personal information.
- Before we disclose your personal information to you, we take steps to verify your identity by asking you to confirm certain account details that only you, generally, would know.
- We take similar precautions before responding to requests from persons claiming to be your authorized agent, by requiring them to provide us with written documentation (such as a power of attorney) to verify they are authorized to act on your behalf.
- Any personal Information collected in connection with verifying these requests will only be used for the purposes of verification and will not be further disclosed or retained longer than necessary for purposes of verification.
Our Data Rights Portal available at www.lifeextension.com/yourprivacychoices provides you with a convenient way to exercise these rights. You can also email privacy@lifeextension.com or call 1-855-874-9085.
15. Non-Discrimination for exercising your Data Rights
Life Extension will not discriminate or retaliate against you for exercising any of the data rights afforded to you in this Global Notice and by applicable data protection laws. This means we will not deny you goods or services, charge different prices or rates for goods or services, or provide a different level of quality of goods or services when exercising your data rights.
16. Privacy & Data Protection Impact and Risk Assessments
Our business systems and processes undergo impact and risk assessments on an as needed as required basis taking into consideration the nature, scope, context, and purposes of our data processing activities and as defined by applicable data protection laws.
17. Breach of Personal Information
Life Extension does not guarantee its security measures will be effective under all conditions. If our services experience a potential security incident, we will promptly investigate. If our investigation determines that your personal information was involved in a breach or potential breach as defined by applicable data protection laws, we or our designated representatives will notify you by emailing a copy of this breach notification to the email address on file for your account or as otherwise specified by applicable law.
18. International Data Transfers
Life Extension is based in the United States and does not maintain any establishment in any other country.
When you use our services, we process, access, and store your personal information on servers and equipment located in the United States, and in other countries, depending on the location of our service providers and third parties. This means your personal information will be transferred to the United States and to other countries that may not provide the same equivalent level of protection to your personal information as your country of residence.
Where we transfer personal information, we rely on appropriate mechanisms for data transfers as adopted by applicable data protection authorities, including with your consent to transfer your personal information:
- Adequacy Decisions: we may transfer your personal information on the basis of an adequacy decision adopted by applicable data protection authorities, including:
- By Contract: we may transfer your personal information on an as needed as required basis in the performance of a contract between you and Life Extension, or the implementation of pre-contractual measures taken at your request. We perform restricted transfers of your personal information using EU standard contractual clauses (“EU SCCs”), the UK International Data Transfer Addendum to the EU SCCs (“UK Addendum”), or equivalent model clauses adopted by applicable data protection authorities.
- With Your Consent: we may transfer your personal information where you have provided us with your consent to the proposed transfer, after having been informed of the possible risks of such transfers due to the absence of an adequacy decision and other appropriate safeguards.
- Other Transfer Mechanisms: from time to time, we may rely on other data transfer mechanisms adopted by applicable data protection authorities.
19. Country and Regional-specific Supplemental Privacy Notices
The following supplemental privacy notices address any additional country or regional-specific privacy terms, data rights and disclosures not covered in this Global Notice:
20. Additional Terms Incorporated or Excluded by Reference:
- For buyers, customers, shoppers, users, and web visitors, you must read this Global Notice together with our General Terms & Conditions.
- For distributors, resellers, and wholesalers, you must read this Global Notice together with your Wholesaler Terms & Conditions.
- For employees and former employees, you must read this Global Notice together with our Employee Handbook and related company policies.
- This Global Notice does not apply to B2B contractual agreements where Life Extension is a data processor to personal information for another data controller.
- This Global Notice does not apply to third-party links from our services to websites or online resources not controlled by Life Extension, which we provide for your convenience. You should read the privacy notices to those websites or online resources before using them.
21. Privacy Questions, Issues, and Complaints
We are committed to resolving your questions, issues, and complaints about this Global Notice and related privacy management practices by emailing privacy@lifeextension.com or calling 1-855-874-9085.
If you are not satisfied with how we have resolved your complaint, you can escalate your complaint to our management team. If you are still not satisfied with our resolution, you can lodge a complaint with your applicable data protection authority.
22. Controller Contacts
The Data Controller for personal information collected under this Global Notice is:
Life Extension Foundation Buyers Club, Inc.
3600 West Commercial Blvd.
Fort Lauderdale, FL. 33309. USA
23. Privacy & Data Protection Officer Contacts
Contact our Privacy & Data Protection Officer by emailing privacy@lifeextension.com or calling 1-855-874-9085.
24. Changes to this Global Privacy Notice
We may modify, amend, or otherwise change this Global Notice from time to time. The “Effective Date” shown on the first page to this Global Notice indicates when these changes will go into effect.
Any material change to this Global Notice will be effective upon posting the revised Global Notice to our services available at www.lifeextension.com/legal/global-privacy-notice or by emailing a copy of these changes to the email address on file for your account or by any other means consistent with applicable law. It is your responsibility to check this Global Notice for changes prior to each use of our services.