Privacy Policy for Makro Wellness, Inc.

To give you the best support as you experience the services provided by Makro Wellness, we collect personal information from you along the way.

This Privacy Policy (“Policy”) describes how Makro Wellness, Inc. (“Makro Wellness,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes your personal information when you use our Services (use of our Website, Mobile App, and other interactions you may have with us). This includes your choices and rights regarding your personal information. This Policy forms a part of our Terms of Service and terms used but not defined in this Policy are defined in the Terms of Service.

First things first, you have to be at least 18 years old to use Makro Wellness. Do not use these Services if you are under the age of 18. Our Services are not designed nor otherwise intended for children or anyone under 18. We implement technical measures designed to prevent individuals under 18 years of age from creating an account or otherwise using our Services. If we become aware that an individual under 18 may have provided us with personal information, we will investigate and, if applicable, take steps to remove the data and delete that individual's account.

Quick Links to Information About Your Privacy

While our Policy might be comprehensive, we hope you do read it. These quick links might help!

• What information does Makro Wellness collect? Makro Wellness collects information from you directly when you create an account, use our Services, and through third parties. More detail? See the “Personal Information We Collect” section.
• How does Makro Wellness use the information it collects? Makro Wellness uses your information to provide you with our Services, show you relevant ads and content, and improve the quality of our Services. More detail? See the “How We Use Personal Information” section.
• Does Makro Wellness sell my information? While Makro Wellness does not expressly “sell” information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose information may constitute “sales” or “sharing” of personal information or the use of personal information for “targeted advertising” purposes under applicable privacy laws. More detail? See the “Managing Your Marketing and Personalized Advertising Preferences” section.
• How does Makro Wellness share my information? Makro Wellness shares your information with service providers, business partners, and other third parties to provide you with our Services. We also share your information with marketing and advertising partners to show you relevant content and advertising. More detail? See the “How We Disclose Personal Information” section.

Personal Information We Collect

We may collect personal information directly from you, automatically through your use of the Services, and from third parties.

Personal Information We Collect Directly from You

• Account and Profile Information. This includes your name, email address, general location information (country/zip code), profile image or photo (if you choose to provide one), username and password, date of birth, and sex.
• Food Diary Data. Certain features of our Services allow you to voluntarily share information about your dietary habits. This includes your dietary habits; food, drink, and medications you consume (including as submitted via voice logging) and purchase (via our grocery integrations); calorie count; dietary restrictions; body measurements (e.g., height, weight, and BMI); information related to any physiological conditions; progress photos you may choose to provide; and other information you might choose to submit in the notes (e.g., observations and reflections about your progress and mindset). Wellness and Activity Diary Data may include sensitive personal information when the information indicates or allows someone to infer a health condition.
• Communications with Makro Wellness. This includes your email address, name, and any other content provided when you communicate with us, including exchanges with our personnel and any Support Center chatbot.
• Communications Posted on Social Media Pages, Community Forums, and Online Discussion Groups. This includes posted content and related contact information you provide when interacting with our social media pages, online discussion groups, or public-facing community forums sponsored by or affiliated with Makro Wellness.
• Research and Survey Information. This may include information you provide if you participate in research and surveys, such as contact information, feedback, and other information you choose to provide.
• Preferences and Other Requests. This may include information about your preferences, including communication preferences, preferences related to your use of the Services, and any other preferences or requests you provide when interacting with us.
• Payment Information. If you pay for a Premium Subscription through our website, you may be asked to provide payment information. This information is not directly collected or stored by Makro Wellness but instead is collected by a third-party payment platform Makro Wellness uses to facilitate the transaction.

Personal Information We Collect Automatically

Makro Wellness may collect Usage and Device Data. This may include details about your browser, operating system, or device (such as your cookie identifiers, internet protocol (IP) address, mobile advertising identifier, and other unique identifiers), internet service provider, mobile carrier, general location information (including inferred location based off of your IP address), actions that you take while using the Services, information about how you interact with the Services, including the frequency and duration of your activities, information about the links you click, and other information about how you use the Services.

Makro Wellness may collect information, such as usage and device data, from you automatically through cookies and other tracking technologies (collectively, “Cookies”) we use to enhance your experience when you use our Services.

We use Cookies for a variety of purposes, including to make our site work, ensure security, and prevent fraud (Required Cookies); to provide enhanced functionality and analyze usage to improve our website (Functional Cookies); and to provide you with personalized content and advertisements (Targeted Advertising Cookies).

What are Cookies? “Cookies” are small text files that are placed on your device when you visit certain websites. Like many other online service providers, we (and our third-party service providers and partners) use cookies and other similar technologies (e.g., pixels, web beacons, local storage objects, log files, software development kits, etc.) on the Services for various purposes. We collect information through cookies through those we set directly (“First-Party Cookies”) and those set by third parties (“Third-Party Cookies”).

Managing Your Cookie Preferences. Depending on the country where you reside, you have choices with respect to Cookies. For example, by modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some of our Service's features may not work properly. You can adjust your preferences and provide or withdraw your consent as described in the “Managing Your Marketing and Personalized Advertising Preferences” section below.

Personal Information We Receive from Third Parties

We may receive information about you from other sources, such as through third-party connected health devices, service providers, research partners, marketing and advertising partners, and social media platforms.

• Service Providers. Our service providers may provide us with your information to enrich our Services. For example, we may collect information about how you use our Services to improve our user experience and ensure the security of our Services. We also use service providers to help us communicate with you when you have questions or information requests.
• Research Partners. We may collect information for research purposes and surveys we conduct. This may include demographic information, health and fitness goals, and input regarding the use of our Services.
• Marketing and Advertising Companies. This includes third parties who may disclose information about your interests, demographic information, and information about the marketing and advertisements you have seen or clicked on.
• Business Partners. We may partner with other businesses to offer the Services. We may receive your personal information from those business partners as necessary or appropriate for the purposes listed in this Policy.
• Social Media Platforms. You may choose to log in to the Services through certain social media platforms. When you connect to the Services using your social media account, we may collect or receive personal information about you that you have provided to that social media platform, such as your name, email address, profile picture, friends list, and other similar information available on your profile.

Aggregated, De-identified, or Anonymized Information

Please note that we may aggregate, de-identify, or anonymize information so that it will no longer be considered personal information under applicable law. We may use and disclose de-identified information for purposes consistent with those described in this Policy or as otherwise permitted by applicable law.

How We Use Personal Information

• Provide Our Services. We use your personal information in connection with the provision, administration, and management of the Services, including managing your account, providing troubleshooting and technical support, and otherwise running our day-to-day operations.
• Communicate with You. We use your personal information to communicate with you, including responding to your questions and requests. We may also use your personal information to send you communications to request information, seek your feedback, or provide you with administrative information, such as changes to our terms, conditions, and policies.
• Respond to Your Requests to Exercise Your Rights. We use your personal information to respond to your requests to exercise your rights over your personal information.
• Send You Promotional and Marketing Materials. We use your personal information to send you newsletters and other promotional communications, including information about Makro Wellness's new offerings, features, offers, events, webinars, and other information.
• Targeted Advertising. We may engage in targeted advertising. This means that you may see advertisements that are targeted and personalized to you on the Services and/or you may see advertisements for Makro Wellness on third-party services based on information that we have collected from and about you. If you'd like to opt out of such advertising, see how to change your preferences under the “Managing Your Marketing and Personalized Advertising Preferences” section below.
• Cross-Device Tracking. We and our third-party partners may use the information we collect to help us identify other devices that you use (e.g., a mobile phone, tablet, computer, etc.). This means that your online behavior on your current browser or device and your device's location may be combined with information collected from your other browsers or devices.
• Analyze Performance of Ads. We engage third-party analytics providers to help us analyze traffic to evaluate usage of the Services and to understand the performance of our advertisements.
• Research. We use your personal information to administer surveys and questionnaires that help us better understand how Makro Wellness users access and use the Services and for other research and analytics purposes.
• Enhance and Personalize Our Services. We use your personal information to improve and enhance our Services, including through the use of various technologies (e.g., business intelligence tools, machine learning systems, and artificial intelligence), personalize content and features to your interests and goals, and test out new features and updates to our Services.
• Maintain Security and Protect Rights. We use your personal information to help monitor and maintain the security of the Services and our business operations.
• Satisfy Our Legal Obligations. We use your personal information to comply with applicable legal and regulatory obligations and respond to legally valid requests and communications from law enforcement authorities.
• Manage Pre-Litigation or Litigation Matters. We use your personal information to defend our rights and interests in the event of pre-litigation or litigation.
• Carry Out Internal Operations. We use your personal information to conduct financial, tax, and accounting audits and assessments of our operations, including our privacy, security, and financial controls.
• Carry Out Sales and Business Transactions. We may use your personal information in connection with the evaluation, negotiation, and/or completion of a business transaction (e.g., a merger, divestiture, restructuring, acquisition, reorganization, dissolution, or other sale or transfer of some or all of our assets).

How We Disclose Personal Information

We disclose personal information to the categories of recipients described below:

• Our Business Partners. We may partner with other businesses to offer the Services and disclose your personal information to those business partners as necessary or appropriate for the purposes listed in this Policy.
• Our Service Providers. We may disclose your personal information to third parties that provide business, professional, or technical support services to us and/or perform functions on our behalf to provide the Services. The services provided by these parties may include IT and website hosting, payment processing, market research, customer support, data storage, data analytics, auditing, and consulting and legal services.
• Our Marketing and Advertising Partners. We may disclose your personal information, including device and browser information and activity and usage information, to our marketing and advertising partners.
• Our Analytics Providers. We may disclose your personal information, including device and browser information and activity and usage information, to parties that assist us in performing analytics.
• Our Research Partners. We may disclose your personal information to our research partners, including those that perform surveys or research projects in partnership with us or on our behalf.
• Relevant Third Parties in Connection with Business Transactions or Reorganizations. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, we may disclose or transfer your personal information to the other company in accordance with applicable laws.
• Law Enforcement and Regulatory Authorities. We may disclose your personal information to comply with applicable legal and regulatory obligations and respond to legally valid requests and communications from law enforcement authorities to the extent required by applicable law.
• Other Parties. We may disclose your personal information to other parties at your direction or with your consent or as it may be justified under applicable law.

Managing Your Marketing and Personalized Advertising Preferences

You have the ability to manage your Makro Wellness account and your preferences as described below.

Marketing Communications

We may send you periodic marketing and promotional emails or other similar communications, and we will obtain your consent to do so, where required by law. If you no longer wish to receive marketing and promotional communications from us, you may change your email preferences in your account settings or unsubscribe from these communications by following the “unsubscribe” instructions included in those communications.

Cookie Preferences

Depending on the country where you reside, you have choices with respect to cookies. For example, by modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some of the Services' features may not work properly. You can manage your cookie preferences by visiting “Cookie Preferences” in our footer.

Personalized Advertising Preferences

We may engage in targeted advertising. If you'd like to consent, opt-in, or opt out of such advertising, you may do so on your browser by visiting “Cookie Preferences” in our footer and adjusting your cookie preferences, or through our App by visiting the personalization settings within the Privacy Center tab under the “More” menu.

Managing Your Targeted Advertising Preferences through Third Parties

Some web browsers, websites/platforms, and mobile devices allow you to exercise certain choices with respect to targeted advertising. You can learn more about ad-serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative.

International Transfers of Personal Information

Makro Wellness is headquartered in the United States and has service providers in the United States and throughout the world. As a result, your personal information may be transferred to the United States and other countries or regions with data protection and privacy laws that differ from those in your country of residence. By using the Services and/or sharing your personal information with Makro Wellness, you are informed that your personal information may be transferred to countries outside of your country of residence.

User-Generated Content

We may offer public-facing interactive features, community forums, or discussion blogs on the Services that enable you to share information. Any information you post to any public-facing section of the Services may be publicly viewable. By posting to such interactive features you acknowledge and agree that you have no expectation of privacy or confidentiality in the content you submit through such features, whether or not it contains your personal information.

How We Protect Your Information

We maintain reasonable technical, organizational, and administrative safeguards designed to protect the personal information under our control from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no information security measures can guarantee security.

How We Retain Your Information

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Policy (including to satisfy our legal or reporting requirements), unless a longer retention period is required or allowed under law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of the personal information; the purposes for which we use the personal information; whether we can achieve the purposes through other means; and the applicable legal requirements. If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

Your Privacy Rights

Depending on where you live, the laws of your country, state, or province may have certain privacy rights over how your personal information is collected, stored, used, and shared, including:

• Right to Access and Data Portability. The right to confirm whether we are processing your personal information, who we share it with, and to access or obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format.
• Right to Deletion. The right to request that we delete your personal information (subject to certain exceptions prescribed by applicable law).
• Right to Correction. The right to request that we correct inaccuracies in your personal information, taking into account the nature of the information and purpose(s) for which we are processing it.
• Right to Limit or Opt-Out of Certain Types of Processing. This includes the “sale” of your personal information; the processing of your personal information for “profiling” and “targeted advertising” purposes; and certain forms of “profiling” (in each case, as these terms are defined in applicable law).
• Right to Opt-In to Processing of Sensitive Information. Some states offer their residents the right to opt-in to the use of sensitive information. In this scenario, this means we cannot use sensitive information (outside of the provision of our Services) without your consent.
• Right Against Discrimination. We will not discriminate against you if you decide to exercise your legal rights.
• Right to Appeal Decisions. You may have a right to appeal a decision on a privacy rights request. To appeal such a decision, please submit your request to privacy@makrowellness.com with “APPEAL” included in the subject line.

How Do I Exercise My Rights?

Makro Wellness Privacy Request Center. You can exercise your privacy rights by visiting our Makro Wellness Privacy Request Center and selecting the country/region in which you reside along with the privacy rights you wish to exercise.

Authorized Representative. Where legally permitted, you may submit requests through an authorized agent or representative at privacy@makrowellness.com. To process these requests, we will need to verify the identity of the agent and that you have authorized them to act on your behalf.

Questions. You can also contact our Data Protection Officer (privacy@makrowellness.com) if you have any inquiries or complaints regarding our processing of your personal information.

Additional Information for Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable laws, including residents of certain states within the United States (e.g., California and Washington), the European Economic Area (EEA), Switzerland, and United Kingdom (UK); Canada, Brazil, and South Korea.

California

California Shine the Light. Residents of the State of California have the right to request information from Makro Wellness regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies' direct marketing purposes. To make such a request, please contact us at privacy@makrowellness.com.

California Consumer Privacy Act. The California Consumer Privacy Act (“CCPA”) (as amended by the California Privacy Rights Act) provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as the right to know/access, delete, and limit sharing of Personal Information.

Under the CCPA, California residents have the following rights:

• Right to Notice at Collection Regarding the Categories of Personal Information Collected
• Right to Know About Personal Information Collected, Disclosed, Shared, or Sold
• Right to Know/Access Information
• Right to Request Deletion of Information
• Right to Information Regarding Participation in Data Sharing for Financial Incentives
• Right to Opt Out of Sale of Personal Information to Third Parties
• Right to Opt Out of Sharing Personal Information for Cross-Contextual Behavioral Advertising
• Right to Restrict Use of Sensitive Personal Information
• Right to Correct/Rectify Inaccurate Information
• Right to Non-Discrimination

How to Submit a Request. You can exercise rights by emailing our Makro Wellness Privacy Mailbox at privacy@makrowellness.com. Where legally permitted, you may submit requests through an authorized agent or representative.

Washington Consumer Health Data Privacy Policy

This Washington Consumer Health Data Privacy Policy supplements the information in the Makro Wellness Privacy Policy. It applies solely to Washington consumers who interact with us in an individual or household capacity and applies only to personal information defined as “consumer health data” under the Washington My Health My Data Act.

1. Categories of Consumer Health Data We Collect. We may collect or receive the categories of consumer health data listed below: Health and wellness information submitted as part of your account; Survey and questionnaire responses; Fitness and Wellness Data (including dietary habits and dietary restrictions, fitness activity, fitness goals, body measurements, BMI, calorie count, and other measurements related to physiological condition); Health data from third-party applications and wearable devices; and Profile information that includes health data.

2. Categories of Sources from Which We Collect Consumer Health Data. We may obtain consumer health data from different sources, including: provided directly by you; collected from a device associated with you; collected from your interactions with our apps, Services, platforms; and received from third parties.

3. Purposes for Collecting Your Consumer Health Data. We may collect and use consumer health data to: Provide, administer, personalize, manage, develop, improve, repair, and maintain our products and Services; Communicate with you; Administer surveys and questionnaires; Combine information from third-party sources; De-identify, tokenize, or aggregate your information; Personalize, advertise, and market our products and services; Generate inferences about you; and Comply with our legal obligations.

4. Sharing of Consumer Health Data. We may share each of the categories of consumer health data described above with business partners, governmental agencies, and purchasers of or successors to our business or assets.

5. Your Washington Consumer Health Data Rights. Washington residents have the right to (1) request access to their consumer health data; (2) confirm whether we have disclosed or sold their consumer health data; (3) delete their consumer health data; or (4) withdraw their consent or authorization relating to such data.

6. How to Submit an Appeal. To appeal our decision on your Washington Consumer Health Data Rights request, you may contact us at support@makrowellness.com.

Canada

• Processing of Personal Information. You are generally not obliged to provide your personal information, but we may be unable to provide certain services to you if you refuse to disclose certain personal information.
• Consent to Process Your Personal Information. Unless otherwise allowed by the laws applicable in your province or territory of residence, we will only collect, use, or communicate your personal information with your consent (which may be express or implied).
• Right to Access and Correct Your Information. You have the right to access the personal information we hold about you and correct or amend your information as appropriate.
• Quebec Residents—Right of Data Portability. The right to receive your personal information in a structured, commonly-used, and machine-readable format and to request that we transmit your personal information to another organization.
• Quebec Residents—Right to De-Indexation. The right to request, in certain circumstances, that we cease disseminating your personal information or to de-index any hyperlink that allows access to your personal information by technological means.

To exercise your rights, please visit the Makro Wellness Privacy Request Center.

Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at privacy@makrowellness.com, or write us at:

Makro Wellness, Inc.
ATTN: Makro Privacy