Koye Wellness GmbH (“Koye”, ”we”, and “us”) has created this Privacy Policy (“Privacy Policy”) to demonstrate our commitment to protecting the personal information of (a) users who access and use our online services (the “Services”), which are made available through our website located at myfyfiber.com (the “Website”); (b) Customers who purchase dietary supplements and vitamins (collectively, “Products”) from us via the Website and Services; and (c) any other individuals from whom we collect personal information during the course of our business activities. The Privacy Policy is effective as of January 25, 2020.

By using or accessing the Website or the Services or otherwise providing personal information to us you signify your acknowledgment and assent to the Privacy Policy set forth below, as well as our “Terms of Use” and our “Terms of Sale” located at myfyfiber.com. If you do not agree to this Privacy Policy or such terms, please do not use the Website or the Services. We can revise this Privacy Policy at any time by updating this posting or otherwise providing notice as set forth in this Privacy Policy, and your use provision of personal information after such change signifies your acceptance of the changed terms. Please check this Privacy Policy periodically for changes.

This Privacy Policy describes the personal information Koye collects, how we use your personal information, with whom we may share such data, and how you can contact us, access your personal information and exercise your rights regarding use of your personal information. As used in this Privacy Policy, “personal information” means data that identifies, relates to, describes, or is linked to a particular identified or identifiable natural person or is otherwise considered personal data under applicable privacy and/or data protection laws or regulations.

Collection of Personal Information

We may collect personal information from you directly such as from forms on the Website or Services; in connection with Product orders, from surveys; when you submit a query to us; or from other communications with us. In order to use certain parts of the Website or Services, you may be required to set up an account with us (an “Account”). During this process, we may ask you for certain personal information to establish and use your Account. We may also collect information about you in connection with your transactions with us, any of our affiliates or Service Providers. Where permissible by applicable law, we may also collect personal information from publicly available sources. Personal information we collect includes, among other things:

• Personal identifiers: (e.g., name, age, gender)
• Contact data (e.g., shipping address, email address, phone number)
• Wellness information (e.g., your short-term and long-term health goals, your diet, your lifestyle, your views about health/wellness, and medical conditions that you have experienced or that exist in your family)
• Financial data (e.g., payment card information, billing address)
• Transaction data (e.g., preferred products and products ordered)

You may at any time refuse to provide any personal information that we request; however, this may limit your ability to access certain services or content.

Collection of Usage Information

Our systems and servers may collect general data pertaining to your use of the Website and Services, including data about the mobile devices and programs you use to access such offerings (“Usage Information"). Usage Information can include: the name of the domain and host from which you access the Internet; the Internet Protocol (IP) address of the device you are using; the browser software and operating system you are using; mobile device type, device operating system, device settings, the date and time of access (including the length of time spent, the pages accessed while visiting, links clicked, and number of visits, and country of origin); and the address of the Internet site from which you have arrived at our Website or Services. This Usage Information is collected to help us manage and administer our Website, Services and systems, improve the content of our products and services, and customize and improve user experience. Usage Information is gathered using the following methods: (1) cookies, (2) tags/beacons, (3) Third-Party Analytics Services, (4) Third-Party Advertising Networks, and (5) general detection and use of your internet protocol (IP) address, device identifiers, or domain name.

 

• Cookies. We may collect Usage Information through the use of “cookies,” which are small text files that are saved by your browser or device that serve a number of purposes, such as remembering your preferences and generally improving your user experience. We may use both session cookies and persistent cookies to gather analytics about our Website and Services, including Usage Information and demographic information in a non-identifiable form, in order to monitor usage and traffic, improve performance and customize users’ experience. Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of our Website or Services.
• Tags/Beacons. We may also employ software technology called tags or web beacons (a.k.a. pixel tags or clear gifs), that help us better manage Website and Services content and communications by informing us what content is effective and how it is used. These beacons (or other tracking technology) may also be included in or associated with e-mails or other communications that you receive from us (or our Service Providers) in order to help us track your response and interests and to deliver you relevant content and services. For account holders we may link information gathered by web beacons or other tracking technology to personal information.
• Location Data. When you use certain features of our Website or Services, we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code), and more specific GPS location information that is provided to us by your mobile device.

Use and Processing of Personal Information

We use and process your personal information for reasonable and legitimate business purposes, to perform and fulfill our contractual obligations to you, and to comply with legal obligations, including for the following purposes:

• contacting you regarding business transactions and information related to the Products or Subscriptions you have purchased,
• providing our Products and services to you (for example, if you provide us with personal information in order to place an order with us, we will use that information to
process your payment, complete the sale and ship Product to you),
• maintaining our business relationship and/or providing ongoing support to you,
• informing you about our Products and services and other promotional activities and responding to your comments or requests for information,
• showing customized ads to you,
• enforcing any contracts that we enter into with you, or defending claims arising from such contracts,
• optimizing our Website, Services or mobile applications and customer experience,
• enhancing the security of our network and information systems,
• developing, enhancing, and improving our products and services,
• administering and managing our relationship with you,
• understanding and monitoring how people interact with our Website and Services,
• where necessary to protect the rights, property or safety of us or other users or customers,
• Complying with our obligations under applicable law, industry guidelines and internal policies,
• where we are obligated, or permitted, to do so by applicable law, regulation or legal process, including disclosure to customs or other governmental authorities, or
• as described to you when collecting your personal information.

We do not use your personal information without a lawful basis, or for purposes contrary to this Privacy Policy, without your consent.

Informational Messages

When you sign up to receive information from us or otherwise provide us with personal information, we may automatically place you on our list to receive communications and updates and offers regarding Koye and our affiliates and certain non-affiliated third party companies that we have specially selected to offer you promotions, products or services. If you do not wish to receive these messages, you can simply utilize the opt-out method detailed in the message or contact us at the contact points specified below. You may not opt-out of receiving essential updates regarding your relationship or transactions with us.

Third-Party Platforms and Functionality

Like many companies we may use services provided by Google, Facebook or others that collect Usage Information or generate performance metrics concerning our Website or Services, deliver advertising to you, or provide social media functionality.

 

• Third-Party Analytics. Our Websites or Services may rely on one or more Third-Party Analytics Services to evaluate, analyze and provide information and performance metrics regarding your use of the Website or Services. These third parties use cookies, tags and other technologies to collect and analyze Usage Information. The Third-Party Analytics Services we currently work with are the following: Google® Analytics, Facebook Pixel, Alchemy Pixel (GALE’s property), Shopify Analytics Pixel and Google Tag Manager. These third parties may change from time to time, please check this Privacy Policy periodically for the latest information.
• Third-Party Advertising Networks. We may interact with third party online advertising networks, social media companies and other third party services, to evaluate and analyze information about your use of our Website or Services over time so that they may display ads on our Website, on other devices you may use, and on other websites, apps or services, including on social media platforms. These networks may track your online activities over time and across our Website and other websites by collecting Usage Information through automated means, including through the use of cookies, web server logs, beacons/tags and other methods. The ad networks use this information to show you advertisements for us and other clients that are tailored to your individual interests. The information ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you have viewed, and the actions you take. The Third-Party Advertising Networks we currently work with are the following: Google® Analytics, Facebook Pixel, Alchemy Pixel (GALE’s property), Shopify Analytics Pixel and Google Tag Manager. These ad networks may change from time to time, please check this Privacy Policy periodically for the latest information.
• Conversion Tracking. We may use conversion tracking or other search engine features that permit us to measure the effectiveness of search engine results.
• Third-Party Offerings and Social Media Functionality. Our Website and Services may enable you to connect to other external services and social media features such as the Facebook “like” button, widgets such as the “share this” button, and other social media functionality. These third party sites and features may collect your personal information and track your use of our Website or Services and other websites by collecting Usage Information through automated means, including through the use of cookies, web server logs, beacons/tags and other methods.

We are not responsible for the data collection or privacy practices of such third party platforms and social media features. You should review those platforms’ privacy policies to find out more about what data they hold about you, what they do with it, and how to opt-out from certain data collection. You can obtain information about the information collection practices and opt-out of receiving interest-based advertising from participating members of the Network Advertising Initiative (NAI) at http://optout.networkadvertising.org/?c=1  and the Digital Advertising Alliance (DAA) at optout.aboutads.info. You can learn more about how Google uses data at https://policies.google.com/technologies/partner-sites and about how Facebook uses data at https://www.facebook.com/privacy/explanation.

The following platforms also offer opt-out features that let you opt out of their use of your information for interest-based advertising purposes:

• Google: https://adssettings.google.com
• Facebook: https://www.facebook.com/about/ads
• Twitter: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
• Pinterest: https://policy.pinterest.com/en/privacy-policy#section-choices-you-have-about-your-info

 

Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Note that because most opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.  Your mobile device settings may also provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes.

Sharing of Personal Information

In connection with the purposes above, we may share your personal information with third parties in the following circumstances:

• We may share your personal information with third party companies that perform services on our behalf, such as delivery and logistics companies, marketing companies, Payment Processors, and website hosts and other IT infrastructure providers, (collectively, “Service Providers”). When we disclose personal information to Service Providers, we enter into a contract that describes the purpose and requires the Service Provider to both keep that personal information confidential and not use it for any purpose except performing the contract.
• We may disclose your personal information to our corporate affiliates.
• We may disclose your personal information to third parties whom you have authorized in connection with products and services we provide to you.
• We may disclose your personal information as required (or requested by law enforcement) and permitted by law or regulation, including in response to a subpoena or to respond to an emergency situation.
• We reserve the right to disclose personal information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury or interference with (either intentionally or unintentionally) our rights or property or anyone else that could be harmed by such activities.
• In the event Koye or its affiliates or their assets are sold, merged or otherwise involved in a corporate transaction, your personal information will likely be transferred as part of that transaction – we reserve to right to transfer your personal information without your consent in such a situation; provided that we will make reasonable efforts to see that your privacy preferences are honored by the transferee.

Payment Processing

Payment card information (such as payment card name, card number, CVV and expiration date) is collected at the time of a transaction. This information is required so that payment can be authorized by a third party payment processor (the “Payment Processor”) that we have retained to process payments. All payment card information is provided directly to the Payment Processor and not to us (i.e., we do not receive or store your payment card information in connection with authorized payments). All internet transactions with the Payment Processor are performed on a server that uses industry standard encryption technology to help protect your payment card information from being obtained by unauthorized third parties. Your payment, and use of your payment and transaction information, will be subject to the privacy policies of the Payment Processor and your payment card issuer. We are not responsible for any actions or errors of the Payment Processor or for any security breaches suffered by such entity. In connection with your payments, we may obtain certain payment transaction details from the Payment Processor, which we will use solely in accordance with this Privacy Policy.

Use of Aggregate and Non-Personally Identifying Information

We may anonymize, pseudonymize, aggregate or de-personalize personal information and/or Usage Information to create non-personally identifiable information (“Anonymized Data”). We may freely disclose and use Anonymized Data and other non-personally-identifying information for industry analysis, statistical purposes, demographic profiling, marketing and advertising, and other business purposes.

Transfer of Personal Information

All personal information that you provide to us in connection with the Websites and Services will be processed and maintained by us on servers in the United States, and it may also be transferred by us to Service Providers within the United States or elsewhere (which may include countries outside of the European Economic Area). By agreeing to this Privacy Policy, you consent to such transfer of your personal information.

Retention of Personal Information

We will retain your personal information for as long as your Account is active or as needed to provide you services, meet legal or retention requirements, defend or bring potential legal claims, and respond to post-termination inquiries. If you wish to cancel your account or request that we no longer use your information to provide you services you can contact us using the contact points specified below.

Changes to Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes to our information practices. If we make any material changes, we will notify you using any contact information you have provided to us, via your Account or the Services, or by means of posting an updated version of this Privacy Policy on the Website. We encourage you to periodically review our posted Privacy Policy for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting or notification of the new terms, and your continued use of the Website, Services or our other products and services or provision of personal information thereafter indicates acceptance of the modified Privacy Policy. If you do not agree to any part of a modified Privacy Policy, then you must terminate your Account and stop accessing the Website and Services. Specific areas or pages of the Website or Services may include additional or different provisions relating to collection and disclosure of personal information. In the event of a conflict between such provisions and this Privacy Policy, such specific terms shall control.

Your California Privacy Rights – CCPA Notice

If you are an individual within the State of California, USA, the California Consumer Privacy Protection Act of 2018 (“CCPA”) may apply to the personal information that you provide us through this website or otherwise through your interaction with us. If so, we are required by the CCPA and other California statutes to provide additional information to you, which you can find in our California Privacy Statement.

Security

We maintain appropriate physical, electronic and procedural safeguards and controls to help protect against the loss, misuse, alteration and unauthorized disclosure of personal information in our possession or under our control. While we use commercially reasonable efforts to safeguard the confidentiality of your personal information, we cannot guarantee that data will always remain secure due to transmission errors, outside events, third party hacking or other causes. We will comply with all privacy laws and make any legally required disclosures regarding breaches of the security, confidentiality, or integrity of personal information consistent with our ability to determine the scope of a breach and our obligations to law enforcement.

External Websites

The Website and the Services may contain links to third-party websites (“External Sites”). We have no control over the privacy practices or the content of these External Sites, and we are not responsible for (and under no circumstances shall be liable for) the contents content or the privacy policies of those External Sites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Policies for Children

We do not intentionally collect or use any personal information from users under 18 years of age. No data should be submitted to the Website or Services by users under 18 years of age.

Access to Personal Information

You may review, update, correct or delete certain personal information associated with your Account by logging into your Account. If you wish to update or delete other personal information, you can contact us using the contact points specified below. To the extent authorized by law, we will take steps to modify or delete your personal information as soon as is practical, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Contact Information

If you have any questions or issues regarding this Privacy Policy or use of your personal information, please contact us using the contact information provided below:

Mail: Koye Wellness Gmbh
          Grossmatt 6, 6052 Hergiswil NW,
          Switzerland
          Attn: Robert Landolt

Tel: +41 (0) 79 174 97 34  

Email: contact@koyewellness.com