Privacy Policy

Effective Date: January 19, 2024

  1. What Does This Privacy Policy Cover?

This privacy policy (“Privacy Policy”) applies to https://www.willowlaboratories.com and the mobile applications owned and operated by Willow Laboratories, Inc. and its subsidiaries and affiliates (“Willow,” “We,” “Us,” or “Our”). This Privacy Policy describes how Willow collects, uses, shares and secures the personal information you provide on our website https://www.willowlaboratories.com and our mobile applications. It also describes the choices available to you regarding our use of your personal information and how you can access, correct and update this information. We are the data controller for processing your personal data. For any questions regarding this Privacy Policy, please contact us using the details listed in the “Contact Us” section below.

  1. Does Willow Participate in the EU-U.S. Data Privacy Framework, the UK Extension, and the Swiss-U.S. Data Privacy Framework?

Willow complies with the EU-US Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the US Department of Commerce. Willow has certified to the Department of Commerce that it adheres to the EU-U.S. DPF Principles with regard to the processing of personal data from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Willow has certified to the U.S. Department of Commerce that it adheres to the Swiss- U.S. DPF Principles with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (the “Principles”), the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification page, please visit https://www.dataprivacyframework.gov/

With respect to personal data received or transferred pursuant to the Data Privacy Framework, Willow is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

  1. What Personal Information About Customers Does Willow Gather?

Personal Information You Give Us: When you sign up to receive product updates and other notifications on our website, post on our blogs/forums, purchase products, or contact us, we may collect a variety of personal information, including your name, your IP address, mailing address, phone number, email address, contact preferences, and credit card information.

Mobile: When you download and set up apps created by Willow, we may collect a variety of information such as full name, email address, mailing address, phone number, age, biological sex, or date of birth. In addition, during the use of our apps, we may also collect information about your location and your mobile device, and sensitive personal information relating to your health/wellness, such as food and beverages, activity, sleep, weight, medication and medication delivery, and physiological parameters. We ask for your explicit consent to process this data. We obtain this consent separately when you set up an account with us. However, setting up an account is not required for you to use devices we sell. When you download and use our mobile application, we automatically collect information on the type of device you use, operating system version, and the device identifier (or "UDID").

  1. Does Willow Collect Any Non-Personal Information?

As you navigate through and interact with our website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our website, including traffic data, location data, logs and other communication data and the resources that you access and use on the website.
  • Information about your computer and Internet connection, operating system and browser type.
  • We gather certain non-personal information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
  • We may collect data about how you use your device and applications in order to help app developers improve their apps.
  • The information we collect automatically is statistical data and may not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties, including through purchased marketing data about our customers. This helps us to improve our website and to deliver a better and more personalized service, which enables us to:
    • Estimate our audience size and usage patterns.
    • Store information about your preferences, allowing us to customize our website according to your individual interests.
    • Speed up your searches.
    • Recognize you when you return to our website.
    • Analyze trends in the aggregate and administer the website. To the extent that Internet Protocol (IP) addresses, similar identifiers, or other pieces of information are considered personal information by applicable law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.
  1. How Does Willow Use the Personal Information Collected?

Our purposes for processing your personal information are listed below:

  • The personal information we collect allows us to conduct marketing activities and keep you posted on Willow’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt out anytime by updating your preferences here.
  • We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content, and advertising, and for loss prevention, anti- fraud purposes and complaint handling purposes.
  • We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Willow account holders.
  • From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this administrative and service-related information is important to your interaction with Willow, you may not opt out of receiving these communications.
  • We may also use personal information for internal purposes such as accounting, auditing, data analysis, and research to improve Willow’s products, services, and customer communications. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
    1. Legal Basis for Processing Personal Information

Where we need to rely upon a legal basis to process your personal information, we generally rely on the fact that the processing is necessary for our legitimate interests, including for those processing activities described above, and/or is necessary for the performance of a contract between us and you. Our legal basis to process your sensitive personal information (i.e. health/wellness related data, as listed above), geo-location and testimonials includes processing that is based on your express consent. You have the right to withdraw consent for such processing at any time. To withdraw your consent, please use the contact details in the “Contact Us” section below, or refer to the “What Choices Do I Have?” or “What About Information Entered through Other Media Channels?” sections below. Withdrawing your consent will not affect the lawfulness of processing based on consent prior to its withdrawal.

  1. Does Willow’s Website or Mobile App Use Tracking Technologies?

We and our partners, affiliates, or analytics or service providers, may use any of the tracking technologies listed below to analyze trends, administer the website, track users’ movements around the website, learn about user behavior on the website, to improve our product and services, and to gather demographic information about our user base as a whole. Willow may also use this information in our marketing and advertising services: Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Local Storage (HTML5). Local Storage (HTML5) to provide certain features on our website, to display advertising based on your web browsing activities, and/or to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. Web Beacons. Pages of our website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Willow, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics such as recording the popularity of certain website content and verifying system and server integrity. Willow also uses cookies and other technologies (beacons, scripts, and tags) to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Willow more convenient and personal.

  1. Can I opt out of behavioral tracking and how does Willow respond to browser signals and other mechanisms that enable me to exercise choice about behavioral tracking (*Do not track disclosure)?

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies to gather information about your activities on this website and other sites in order to provide you advertising based on your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt out by clicking here. If you are located in the European Union or Switzerland, click here. Please note this does not opt you out of being served ads; you will continue to receive generic ads. *Do Not Track Disclosure: Currently, various browsers offer a “do not track” or “DNT” option which sends a signal to websites visited by the user about the user's browser DNT preference setting. Willow does not currently commit to responding to browsers' DNT signals with respect to the Willow’s websites, in part, because no common industry standard for DNT has been adopted, including no consistent standard of interpreting user intent.

  1. Is data collected from Children? Can data collected inadvertently from children be deleted?

Willow does not knowingly collect personal information from children under the age of 16 If you are a parent or guardian who knows or has discovered that your child under the age of 16 has submitted his or her personal information or other information without your consent, permission, or authorization, upon your request, we will promptly remove your child’s personal information or other information from our database, cease the use of such information, and direct any other party with access to such information to do the same.

  1. How Does Willow Share Information It Collects?

We will share your personal information, such as, your IP address, mailing address, phone number, email address, contact preferences, and credit card information with third parties only in the ways that are described in this Privacy Policy. We do not sell your personal information to third parties. We will also share your information with limited members of our IT, customer support and accounting departments.

Service Providers: We may provide your personal information to companies that provide services on our behalf to help us with our business activities such as fulfilling your orders, delivery of product, processing credit card payments, conducting marketing surveys or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

Legal Disclaimer: We may also disclose your personal information:

  • as required by law, such as to comply with a subpoena or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • if Willow is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information; and
  • to any other third party with your prior consent.

In certain situations, Willow may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. Willow’s accountability for personal data that it receives under the Data Privacy and subsequently transfers to a third party is described in the Data Privacy Principles. In particular, Willow remains responsible and liable under the Data Privacy Principles if third- party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Willow proves that it is not responsible for the event giving rise to the damage.

  1. Your Rights

You are entitled, in accordance with applicable law, to request access to, rectification of, erasure of and portability of your personal data, and to object to or request restriction of the processing of your personal data by logging into your account or contacting us at the details listed in the “Contact Us” section below. If you are aware of any changes to or inaccuracies in your personal data, you can also inform us so that your personal data may be updated or corrected. To protect your privacy and security, we may take reasonable steps to verify your identity before granting access or making corrections. Moreover, if you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, you may delete your personal information by contacting us at the details listed in the “Contact Us” section below. We will respond to your request within a reasonable timeframe. You can also easily access certain information at willowlaboratories.com or via our mobile app including up-to-date information regarding recent orders, personal information (including name, email, health/wellness data, communications, and personalized preferences), payment settings (including credit card information, promotional certificate, and gift card balances), e- mail notification settings (including product availability alerts, deliveries, and newsletters).

  1. What Choices Do I Have?

Opt-out Preferences: If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page, or contacting us at privacy@w-labs.com. You may also choose not to provide the personal information that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have. Geo-Location: With your permission, we collect your location-based information for the purpose of tracking correlations between changes in geo-specific information (such as elevation, humidity, and temperature), and the device's measurement of health/wellness information. Turn off Location services: Mobile devices provide users with the ability to disable location services. These controls are located in the device's settings menu. You may opt-out of location-based services at any time by editing the setting at the device level. Mobile Analytics: We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data and from where the application was downloaded. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application. Push Notifications: We send you push notifications in order to enable link loss, a notification to let you know that your phone may not be in pairing distance with Willow’s device. Mobile devices provide users with the ability to disable push notifications. These controls are located in the device's settings menu. You may opt-out of push notifications at any time by editing the setting at the device level.

  1. How Secure Is Information About Me?

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@w-labs.com.

  1. What About Links to Third Party Sites?

Our website may include links to other websites whose privacy practices may differ from those of Willow. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

  1. What About Information Entered Through Other Media Channels?

Blogs/Forums: Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@w-lab.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. Testimonials: We display personal testimonials and other endorsements of satisfied customers on our website. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@w-labs.com. Social Media Features and Widgets: Our website includes social media features and widgets, such as the Facebook Like button, sharing features from Twitter, LinkedIn or Google+, or interactive mini-programs that run on our website. These features and widgets may collect your IP address, which webpage you are visiting on our website, and may set a cookie to enable the feature and widget to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it.

  1. How Are Changes To The Privacy Policy Communicated?

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. How are Disputes Resolved?

In compliance with the Data Privacy Principles, Willow commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding this privacy policy may first contact Willow using the contact information listed in the below “Contact Us” section. You may also lodge a complaint with a supervisory authority if you consider that our processing of your personal data infringes applicable law. Willow has further committed to refer unresolved privacy complaints under the Data Privacy Principles to an independent dispute resolution mechanism, the BBB EU DATA PRIVACY, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you. Under certain conditions, more fully described on the Data Privacy website, you may be entitled to invoke non-binding arbitration when other dispute resolution procedures have been exhausted.

Contact Us If you have questions about this Privacy or our data practices, please contact us at privacy@w-labs.com, or as follows:

Willow Laboratories, Inc. 15750 Alton Pkwy Irvine, CA 92618 USA Phone: 1 (800) 610-8522