Privacy Policy

I. INTRODUCTION

SRW Laboratories Ltd. d/b/a SRW through www.scienceresearchwellness.com (the “Site”) is owner of a line of dietary supplements, test kits and other products offered for purchase through the Site. In this Privacy Notice (this “Notice”), we refer to SRW as “SRW”, “we”, or “us”.

This Notice covers how and why we collect, use, and disclose information that identifies or can be used to identify you (sometimes referred to as “Personal Data” or “Personal Information” under applicable privacy and data security laws, and hereinafter, “Personal Data”) when you access or use the SRW owned website(s) or mobile applications (which may have additional Terms of Use), other products, brands or services that link to this Notice (collectively, the “Services”) or when you otherwise interact with us. If you do not agree with the content of this Notice, please do not use our websites or otherwise interact with our company, services, brands or products.

II.WHAT DATA DOES SRW COLLECT AND HOW?

When you use our Services, we may collect or receive Personal Data about you to provide our services and operate our business. Personal Data may include your name, age, gender, photo, general background information, location/hometown, email address, mailing address, phone number, credit card information, biometric data, fitness level and fitness goals, activities, and interests.

We collect Personal Data in the following ways:

A. Information You Provide to Us Directly:

When you visit and interact with our Services including submitting a posting to any of our forums, message boards, review areas, chats, messaging services, profile pages or other areas of the websites;
When you voluntarily provide information to us when registering for our Services directly or through a social networking site;
When you enter purchase information, place orders, make exchanges or returns, or when you request information about products and services offered through the Services;
When you register for our current or future loyalty/subscription program;
When you contact our call center or customer service department;
When you enter a contest or sweepstakes, respond to a survey or questionnaire or subscribe to a newsletter;
When you provide us with comments or suggestions;
When you download a SRW app from our Services or an app store;
When you use social media in connection with or to interact with the Services;
When you attend our events or events we sponsor or participate in our field marketing activations or other activities; or
When you serve as talent (e.g., a model or social media influencer) in our advertising campaigns.

B. Information Collected Automatically:

We also may receive and store certain information about you and your device(s) automatically when you access or use our Services. This information may include:

Transactional Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
Usage and Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
Preferences: We collect information about your preferences to make your use of the Services more productive through the use of cookies.
Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and pixel tags when you access the Services, whether as a registered user (“User”) or a non-registered user, to automatically record information such as your Internet Protocol (IP) address, browser type and language, Internet service provider, referring and exit websites and applications, operating system, date/time stamp, and clickstream data (“Log Data”). For more information on our collection of your personal data using cookies, please review our Cookie Policy.

C. Information Collected from Other Sources

We also may collect or receive Personal Data from third parties such as service providers, vendors, contractors, and partners as described in Section IV of this Notice.

III. WHY DOES SRW COLLECT PERSONAL DATA?

SRW collects Personal Data for the following business or commercial purposes:

Account registration. We create your User account for your use of the Services based upon the Personal Data you provide. If you decide to create a User account on our Services by logging into a social networking site, you are using the Personal Data you have already provided to the social networking site (such as your name, email address, and other information you make publicly available via the social networking site) to create your User account on our Services. The information we collect may depend on the privacy settings you have with the social networking site, so please consult the social networking site’s terms of use and privacy policy.
Communications. We use your Personal Data to contact you with emails, marketing or promotional materials and other information that may be of interest to you with an “opt-in” mechanism.
Order Fulfillment. We use your Personal Data to assist us in fulfilling orders you place with us, such as making shipping arrangements and contacting you about back orders, returns or exchanges. If you use a credit or debit card for any purchase, we will collect and retain the necessary information about such card that you submit (through our third-party processors who keep the credit or debit card information confidential) to complete that purchase, as well as keep a history of your purchases. We use the collected information to process your purchases and to better assist you when you contact us.
Operation, maintenance, and improvement of our websites, products, and services. We use your personal data to aid us in the operation and maintenance of our Services. We also use such information to help us improve our Services and the products and services we offer to you in order to better serve you and our other customers. For example:
- We use Log Data to monitor and analyze use of our Services and our Services’ technical administration, to increase our Services’ functionality and user-friendliness, and to better tailor our Services and marketing or promotional materials to our visitors’ needs. For example, some of this information is collected so that when you visit our Services again, it will recognize you and the information could then be used to provide advertisements and other information appropriate to your interests. We also use this information to verify that visitors to our Services meet the criteria required to process their requests.
- We may combine your Personal Data with certain non-identifying information (e.g., age and individual preferences) that you provide as part of your registration on our Services (“Non-Identifying Information”) and aggregate it with information collected from other users of the Services to attempt to provide you with a better experience, to improve the quality and value of our Services and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
Contests. If we conduct a contest, give-away or similar type promotion, we may use your Personal Data to administer the same and/or enter you.
Loyalty program. If we implement a loyalty/subscription program, we use your Personal Data to administer any such program.
Customer service. We use your Personal Data to:
- personalize your experience and deliver the type of content and product offerings in which you are most interested;
- better service you when responding to your customer service requests and questions;
- send periodic emails regarding your order or other products and services; and
- follow up with you after correspondence (live chat, email or phone inquiries).
Contracts. We use your Personal Data to carry out our obligations and enforce our rights including for billing and collection.
Miscellaneous. We use your Personal Data in other ways as required or permitted by law or with your consent.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without first providing you with notice.

IV. HOW SRW SHARES PERSONAL DATA

We may share or disclose your Personal Data for a business purpose with the following third parties:

Vendors: We engage vendors, third parties, service providers, contractors, and partners to:
- facilitate the operation of our websites including operating our websites on our behalf, performing website-related services (e.g., maintenance services, database management, web analytics, and improvement of our websites’ features), and/or assisting us in analyzing how our websites are used;
- facilitate and deliver the various forms of communication described in Section III of this Notice and/or track, personalize, and deliver marketing or other promotional materials;
- to fulfill purchase orders including making shipping arrangements, contacting consumers about back orders, returns or exchanges, processing payments, and/or assisting with billing and collection;
- administer our sweepstakes, contests, and other promotions;
- administer any loyalty/subscription program; and
- provide customer service support.
Data Analysts and Aggregators: We may share aggregated information that does not include Personal Data, and we may otherwise disclose Non-Identifying Information such as general (non-specific) geographic location, device/browser technology, onsite behavior, population data, user segmentation, survey results, and Log Data, with third parties for data analysis, demographic profiling, and other purposes. Any aggregated information shared in this manner will not contain your Personal Data. Non-Identifying Information is considered a part of your Personal Data only if combined with other identifiers (e.g., combining your zip code with your street address) in a way that enables you to be personally identified or contacted. The same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (e.g., your viewing preferences).
Social Networking Sites : We allow users to link their social media accounts to our Services, and may allow linking to accounts of future social networking sites as they are developed. Users can then post their recent activity on our Services to their social media accounts. You will be prompted to decide whether or not your activity on our Services will be shared and disclosed on your social media account. Unless the social networking site has received your Personal Data independently of our Services, these social networking sites will only have access to your Personal Data (not including credit or debit card information) for the purpose of making the link to your User account.
Other Website Users: When you register through our Services and submit your Personal Data to create a User profile, other users of the Services will see your name. If you choose to provide additional Personal Data in your profile, other users of the Services will see such additional Personal Data which may include your photo, location, website, and biography. Providing additional Personal Data is voluntary and should correlate with the degree of interaction you want to have with other users of the Services. We recommend that you refrain from disclosing any information you consider sensitive and/or confidential.
Government and Law Enforcement: SRW cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We can disclose any information about you to government or law enforcement officials or private parties as we believe necessary or appropriate to respond to claims and legal process including subpoenas and litigation, and to protect the safety, property, and rights of SRW or other parties or to prevent or stop activity we may consider to be illegal, unethical or legally problematic.
Related Businesses: SRW may disclose Personal Data to our subsidiaries and/or affiliates. We may also sell, divest, transfer, assign, share or otherwise engage in a transaction that involves some or all of our assets, including any or all of the information described in this Notice, in the course of a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization or any other similar transaction or proceeding.
Miscellaneous: In addition to the above, SRW may disclose Personal Data to third parties to fulfill the purpose for which you provide it, for any other legitimate business or commercial purpose disclosed by us when you provide the information, or with your consent (where appropriate).

V. PROTECTING YOUR PERSONAL DATA.

Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and SRW will never ask you for your password, credit card information or Personal Data in any unsolicited communication such as phone calls or emails. We urge you to be careful about giving out information in public areas of our Services or using unsecured public WiFi when accessing your User account.

VI. TRANSFERS TO OTHER COUNTRIES

SRW is based in New Zealand and may share your Personal Data as described in Section IV of this Notice, which means that your information may be transferred to, and maintained on, computers or with third parties located outside of your state, province, country or other governmental jurisdiction. Your Personal Data may therefore be subject to privacy laws of other jurisdictions. If you are located outside the United States and choose to provide information to us, SRW may transfer your Personal Data to New Zealand and process it there.

However, we have taken appropriate safeguards to ensure that your Personal Data will remain protected in accordance with this Notice. These safeguards could include implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Data between any future company we may own or start in the European Union in accordance with European Union data protection law.

VII. DATA RETENTION AND DELETION

SRW keeps your Personal Data for varying amounts of time depending on the type of Personal Data collected, and where we have an ongoing legitimate business need to do so, including customer services, processing product orders, making data-driven business decisions, maintaining appropriate business and financial records, complying with our legal and regulatory obligations, and resolving disputes. We keep some of your Personal Data for as long as you are a SRW customer. For example, we keep your order history, payment information, account information (including personal goals and product preferences), email address(es), and shipping and billing addresses. If you request, we may delete or anonymize your Personal Data so that it no longer identifies you, unless we are legally allowed or required to maintain certain Personal Data, including situations such as (i) an unresolved issue related to your User account, (ii) tax, audit, and accounting obligations, (iii) an unresolved claim, dispute, allegation or litigation, and (iv) mandatory data retention laws in the applicable jurisdiction including regulatory obligations to preserve data relevant to an investigation.

VIII. RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are a resident in the European Economic Area, you have the following data protection rights with respect to your Personal Data (as such term is defined in the General Data Protection Regulation 2016/679):

request to be informed of and have access to the Personal Data we process about you;
request that we amend or update your Personal Data when it is inaccurate or incomplete;
request that we delete your Personal Data;
request that we temporarily or permanently stop processing all or some of your Personal Data;
object to us processing your Personal Data on grounds relating to your particular situation;
object to your Personal Data being processed for direct marketing purposes; and
request a copy of your Personal Data in electronic format and to be able to transmit that Personal Data for use in another party’s service.

You can exercise these rights by using our request webform or contacting our Privacy Team at hello@SRW.co.

IX.ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

In accordance with the California Consumer Privacy Act (the “CCPA”), the following table summarizes our Personal Data collection, use, and sharing practices in the preceding twelve (12) months since we last updated this Notice on January 1, 2023. As reflected in this table, we may (but don’t always) collect and we may share your Personal Data with a variety of outside entities including service providers, third parties, our subsidiaries, and law enforcement.

Personal Data	Sources of Personal Data	Why We Collect Personal Data?	To Whom May We Sell or Disclose Personal Data?
1. Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	See Section II above.	See Section III above.	See Section IV above.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).Examples: name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	See Section II above.	See Section III above.	See Section IV above.
3. Characteristics of protected classifications under federal and California law such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).	See Section II above.	See Section III above.	See Section IV above.
4. Commercial information such as records of personal products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	See Section II above.	See Section III above.	See Section IV above.
5. Biometric information such as test results, keystroke patterns or rhythms, gait patterns or rhythms, or other physical patterns, and sleep, health, or exercise data.	See Section II above.	See Section III above.	See Section IV above.
6. Internet or other electronic network activity information, including browsing history, search history and information on a consumer’s interaction with a website, application, or advertisement.	See Section II above.	See Section III above.	See Section IV above.
7. Geolocation data such as physical location or movement.	See Section II above.	See Section III above.	See Section IV above.
8. Sensory data such as audio, electronic, visual, thermal, olfactory or other similar information.	See Section II above.	See Section III above.	See Section IV above.
9. Professional or employment-related information such as current or past job history or performance evaluations.	See Section II above.	See Section III above.	See Section IV above.
10. Education information such as records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	See Section II above.	See Section III above.	See Section IV above.
11. Inferences about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	See Section II above.	See Section III above.	See Section IV above.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Data we collected about you.
The categories of sources for the Personal Data we collected about you.
Our business or commercial purpose for collecting or selling that Personal Data.
The categories of third parties with whom we share that Personal Data.
The specific pieces of Personal Data we collected about you (also called a data portability request).
If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Data categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Data categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies under the CCPA.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty, returns policy or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.)
Engage in scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Completing and submitting our request webform;
Emailing us at hello@SRW.co;
Calling us at 0800 779 5227;

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Data. If you designate an authorized agent (either a natural person or a business entity registered with the California Secretary of State) to make a request under the CCPA on your behalf:

the authorized agent must submit proof of your authorization through our request webform or to our Privacy Team at hello@SRW.co; and
you must verify your identify directly with us.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative, which may include your name and email address; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time to respond (up to a total of ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response to a verifiable consumer request by email or mail.

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of the verifiable consumer request. Our response will explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Data Sales Opt-Out

You have the right to direct us not to sell (as such term is defined in the CCPA) your Personal Data at any time. To exercise the right to opt-out of a sale, you (or your authorized representative) may submit a request to us by either:

Emailing us at hello@SRW.co;
Calling us at0800 779 5227;

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Data sales. We will only use Personal Data provided in an opt-out request to review and comply with the request.

Non-Discrimination and Financial Incentives

We will not discriminate against you for exercising your rights under the CCPA. Unless otherwise permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services including through granting discounts or other benefits, or imposing penalties;
Provide you with a different level or quality of goods or services; or
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer certain financial incentives permitted by the CCPA.

X. HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA

Nevada Residents. Nevada residents may opt out of the sale of certain Personal Data collected by website operators. Although we do not currently sell Personal Data (as “sale” is defined under Nevada law) or have any plans to sell Personal Data, you may email hello@SRW.co to opt out of any future sale of your Personal Data.

Email Communications. If you decide at any time that you no longer wish to receive email communications from us, please follow the unsubscribe instructions provided in any of the communications or update your “preferences” in your User account settings.

Cookies. We do not sell your Personal Data for money but we offer cookies and other tracking technologies, which may in some cases constitute the sale of your Personal Data under the CCPA. To opt-out of the sale of your Personal Data, please email Do Not Sell My Info to hello@SRW.co. This will cause information to cease to be added to any cookies or other tracking technologies that have been set on our Services or block them entirely. Please note that you will need to opt out again if you visit one of our Services from a different device or browser or if you clear your cookies.

Additionally, you can choose to turn off all cookies through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies preferences. Please note that if you turn cookies off, some features of our Services will be disabled and you may not be able to use all portions of our Services or all functionality of our Services.

De-Linking Social Networking Sites. If you decide at any time that you no longer wish to have your social media account(s) (such as Facebook, Instagram or Twitter) linked to your User account, then you may de-link the social media account(s) in the “preferences” section in your User account settings.

Changing or Deleting Personal Data in Your User Account. Any User may access, review, update, correct or delete the Personal Data in their User account (including any imported contacts) by editing their profile via our Services. If you completely delete all of your Personal Data, then your User account may be deactivated. If you delete your User account and any other contributions from our Services, copies of your records may remain viewable in cached and archived pages, or might have been copied or stored by other users of our Services. We may retain an archived copy of your records as required by law or for legitimate business purposes.

XI.OTHER IMPORTANT PRIVACY INFORMATION

Minors. Our websites are not directed to minors (persons under the age of majority in their relevant jurisdiction), and we will not knowingly collect or sell Personal Data from minors without affirmative authorization. If you are a minor, do not use or provide any information on any of our Services, or on or through any of its features, make any purchases through our Services, use any of the interactive or public comment features of our Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or username you may use. If we learn we have collected, received or sold Personal Data from a minor without verification of parental consent, we will delete that information. If you believe we may have any information from or about a minor, please contact email hello@SRW.co.

Do Not Track Signals. Your browser settings may allow you to transmit a “Do Not Track” signal to websites you visit. Our websites, similar to many other websites and online services, do not respond to Do Not Track signals.

XII. LINKS

We may have advertisements or other content that link to third party websites which have their own terms of use and privacy policies. If you decide to visit those websites, understand that you are leaving our websites and those third parties may place their own cookies or other files on your computer and collect, use or share your Personal Data according to their separate policies and practices. Please read those third parties’ privacy policies to determine how they collect and process your Personal Data. While we have no responsibility or liability for the content and activities of these linked websites, we are interested in protecting the integrity of our Services and welcome any feedback about those linked websites.

XIII. CHANGES TO THIS NOTICE

It is our practice to post any changes we make to this Notice on this page. If we make material changes to how we treat your Personal Data, we will notify you through a notice on the Services. The date this Notice was last updated is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable e-mail address for you, and for periodically visiting our Services and reviewing this Notice to check for any changes. By accessing or using our Services, you agree to this Notice. Your continued use of our Services after we make any changes to this Notice is deemed to be acceptance of those changes.

XIV. HOW TO CONTACT US

If you have a privacy concern, complaint, suggestion or question for SRW, or if you wish to exercise your rights related to your Personal Data, please contact us.

XV. Live Chat Monitoring Feature:

As part of our move to Ring Central, we have implemented a feature that allows us to view the content being typed by customers in real time before they click send. This feature is designed to assist with the smooth handling of longer or more complex messages and improve response times. We ensure that this information is used solely to enhance customer support and is not stored or shared for any other purpose.

XVI. Transparency and Privacy:

We are committed to maintaining your privacy and ensuring that your personal data is protected. This real-time typing visibility is part of our efforts to provide better service and is in line with standard practices adopted by many other leading chat providers. Rest assured, no information is processed or used inappropriately, and we take all necessary precautions to ensure your data remains secure. We collect customers' email addresses at the start of live chat to send them transcripts of the conversation.