Effective Date: March 10, 2025

Welcome to Zen Vitality 

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

By visiting our Site and/or using our Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Zen Vitality LLC
Data protection officer contact information	hello@zenvitalitynow.com
Personal information	Any information relating to an identified or identifiable individual.
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information	Personal information revealing a consumer’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer’s health, sex life, or sexual orientation, contents of a consumer’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status.

2. Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household: 

• Name
• Postal Address
• Email address
• Phone number
• Credit or Debit Card Information
• Age
• Gender or other demographic information

 If you do not provide personal information required to provide service and/or product to you, it may delay or prevent us from providing services and/or product to you.

3. How Your Personal Information is Collected. We collect personal information from the following categories of sources:

• You, directly in person, by telephone, text, or email and/or via our website
• Third party with your consent (e.g., your bank)
• Advertising networks
• Internet service providers
• Data analytics providers
• Operating systems and platforms
• Cookies on our website
• Our IT and security systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.

4. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

• To comply with our legal and regulatory obligations
• For the performance of our contract with you or to take steps at your request before entering into a contract
• For our legitimate interests or those of a third party –or–
• Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. 

We collect the categories of Personal Data listed above for the following business purposes:

• To take steps at your request before entering into a contract for services and/or products
• To provide the services and/or products to you for their intended purposes.
• For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you.
• To send communications to you, including marketing communications (unless you opt-out).
• To accomplish the purposes outlined in our Terms of Service.
• To process your payments if you make a purchase through the Services, including sharing your payment information with third party payment processors. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their own Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
• To comply with our legal and regulatory obligations.

5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions or new services. We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
6. Who We Share Your Personal Information With. We routinely share personal information with:

• Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies
• Other third parties we use to help us run our business, such as marketing agencies or website hosts
• Third parties approved by you, including third-party payment providers
• Our Banks

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO or Investors in People accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

7. Personal Information We Sold or Shared. We will not sell your Personal Information to any third parties. Notwithstanding the preceding statement, We share the following categories of personal information with third parties:

•  Name
• Postal Address
• Email address
• Phone number
• Credit or Debit Card Information
• Age
• Gender or other demographic information

8. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have not disclosed for a business purpose any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. 
9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf
• To show that we treated you fairly –or–
• To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

10. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you may email us at hello@zenvitalitynow.com 

• Please note that you may only make data portability disclosure request twice within a 12-month period.
• If you choose to contact us directly by email/ in writing, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address and customer or matter reference number)
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill) –and–
• A description of what right you want to exercise and the information to which your request relates

• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, a parent on behalf of their minor child, or is someone authorized to act on such person’s behalf.
• Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

11. Accessing and Modifying Account Information. You may update the information that is stored in your user account by e-mailing us at hello@zenvitalitynow.com 

We strive to help parents ensure that their kids have a safe experience using our Services. Parents or legal guardians can review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.

12. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
13. Changes to This Privacy Notice. This privacy notice was published on March 10, 2025 and last updated on March 10, 2025.

We may change this privacy notice from time to time– when we do, your continued use of the Services after the amended Privacy Policy is posted on the Services will constitute your acknowledgment and agreement to the amended Privacy Policy. However, to the extent the amended Privacy Policy materially alters your rights or obligations in this Privacy Policy, the amended Privacy Policy will become effective upon the earlier of (a) your continued use of the Services with actual knowledge of the amended Privacy Policy, or (b) 30 days after the amended Privacy Policy is posted on the Services. 

14. How to Contact Us. If you have any questions comments, or complaints about this Privacy Policy, how we collect and use your information, or your choices and rights regarding the same, then you may contact us at the contact information below. If you are contacting us as an authorized agent for another person or business, please also provide sufficient information in your request so that we can verify that you are authorized to communicate with us as that person’s or business’ authorized agent.

Our contact details are shown below:

Zen Vitalis LLC 10636 N 71st Way, Ste 13, Scottsdale AZ 85254
hello@zenvitalitynow.com
602-345-1239

15. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

CONSENT

By using our Service, you hereby consent to our Privacy Policy. If you are using the Service on behalf of an organization, you are agreeing to these Terms for that organization and promising that you have the authority to bind that organization to these terms. In that case, “you” and “your” will refer to that organization.

ELECTRONIC AGREEMENT

By using our Service, you agree to be bound by this electronic Privacy Policy, which sets forth the legally binding terms of your use. Your continued use of the Service, including registering, clicking “I Agree” or “Accept” (or a similar button or checkbox), or otherwise accessing the Service, constitutes your acceptance of these Terms, as they may be updated or amended at the sole discretion of Zen Vitality LLC. You acknowledge that you can electronically receive, download, and print this Agreement.

ACKNOWLEDGEMENT

By using the Service, you acknowledge that you have read these Privacy Policy and agree to be bound by them.