This Privacy Statement describes Wellness Living Systems Inc. (“WellnessLiving” or the “Company”) privacy practices in relation to the use of the Company’s Website (http://www.wellnessliving.com) and the related applications and services offered by WellnessLiving (collectively the “Software Services” or the “Software Service” or the “Website”).

The WellnessLiving Privacy policy affects three groups of users: Businesses that subscribe to WellnessLiving’s Software Services (“Subscribers”), the customers of Subscribers (“Clients”) and visitors to our Company Website. Collectively, these groups are referred to as “Users”. We treat our Users' information as if it were our own personal information. We do not sell, share or rent our users' personally identifiable information unless required by law. We do not send e-mail or other communications without user permission. We are committed to maintaining your continued privacy and constantly improving our service.

BY USING THE WEBSITE, SERVICES, AND/OR BY REGISTERING WITH US, YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL TRACK, COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. This Privacy Statement covers the information practices of WellnessLiving. The Website may contain links to other websites. The information practices or the content of such other Websites is governed by the privacy statements of such other websites. The Company encourages you to review the privacy statements of other websites to understand their information practices. WellnessLiving asks new Subscribers to provide their name, business name, address, phone and e-mail address. We call this “Subscriber Information”. As a new subscriber, you will also be asked to provide payment information such as a credit card or bank account number, which is used for monthly billing purposes only. If you attend one of our events (e.g., a trade show), we may ask for your feedback, contact details or other information to follow-up with you, such as send you marketing communications consistent with your choices. As part of WellnessLiving's service deployment process, your customers' personally identifiable information, such as their name, email, phone number, address, and credit card information, as well as any other information your customers’ may provide, (“Client Information”) is uploaded into our secure servers. This process is performed so that WellnessLiving can provide our services to clients on your behalf. The collection of Subscriber Information and Client Information is done solely to provide our services to you in accordance with your Software Licensing Agreement.

In order for you to access certain areas of the Website or certain services where it is important for us to know who you are so that we can best meet your needs, we may require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information: (a) contact data (such as your e-mail address, phone number); (b) demographic data (such as your gender, your date of birth, address and your postal/zip code); (c) and any information you enter on our website or give us in any other way. You can choose not to provide information to us, but in general some information about you is required in order for you to enjoy certain benefits of having an account with WellnessLiving. For example, only registered members are able to view their purchase history, book services, and earn reward points. The more information you provide us (and the more accurate it is) the better we are able to customize your experience on our website. If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information.

We also may periodically obtain both personal and non-personal information about you from affiliated entities, Business Partners, social media pages and platforms and other independent third-party sources and add it to other information about you. For example, if you visit WellnessLiving from a site operated by one of our Business Partners, and you have registered with that partner, then information about you that you have provided to that partner may be shared with us. As well, the information may be shared with other Business Partners if you choose to use their services. We may also collect other Personal Information through the WellnessLiving Software Services under the direction of our Subscribers. We may use small computer files that are transferred to your computer's hard drive that contain information such as user ID, user preferences, lists of pages visited and activities conducted while browsing the Website (“Cookies”) to help us improve our Website by tracking your navigation habits and to store some of your preferences. Generally, we use Cookies to customize your experience on our Website and to store your password so you do not have to re-enter it each time you visit the Website. Cookies do not allow our Website to gain access to other information on your computer. At your option, expense and responsibility, you may block Cookies or delete Cookies from your hard drive. However, by disabling Cookies, you may not have access to the entire set of features of the Website.

In addition, our Business Partners may use Cookies to provide us with anonymous data and information regarding the use of our Services. Specifically, some of our Business Partners use Cookies to show WellnessLiving ads on other sites on the internet as a result of you using the Services. Such Cookies do not contain any Personal Information.

You may opt out of receiving Cookies placed by such third party vendors by visiting the Network Advertising Initiative opt out page.

Other Cookies used by our Business Partners may collect other non-personally identifying information, such as the computer’s IP address, type of operating system, type of internet browsing software, what web pages were viewed at what time, the geographic location of your internet service provider and demographic information, such as gender and age range. This information is used to provide WellnessLiving with more information about our users’ demographics and internet behaviors.

We do not link the information stored in these Cookies directly to any of your Personal Information you submit while on the Website. In limited circumstances we also may use tiny graphic image files imbedded in a web page or email that provide a presence on the web page or email and send back to its home server information from the user’s browser (“Web Beacons”) to collect anonymous, non-personal information about your use of our Services and the sites of selected sponsors and advertisers, and your use of emails, special promotions or newsletters we send to you. The information collected by Web Beacons allows us to statistically monitor how many people are using the Services and selected sponsors' and advertisers' sites, or opening our emails, and for what purposes. We may use your Personal Information to send you information about WellnessLiving or our products or Services, to contact you when necessary, including to remind you of upcoming bookings, to create and administer accounts, and to provide you with related assistance.

We may also use your Personal Information to recommend certain Business Partners or services, and facilitate social media sharing. We may use your demographic data, Traffic Data to customize and tailor your experience through the Services, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences.

We may also use your anonymized Personal Information to run (or authorize third parties to run) statistical research on individual or aggregate trends. Such research would only use your Personal Information in an anonymous manner that cannot be tied directly back to you.

In addition, we may use your Personal Information for internal audits, to insure our processes are compliant with legal, regulatory, or contractual requirements, for fraud and security monitoring purposes, and to fulfill legal obligations. We share certain categories of information we collect from you in the ways described in this Privacy Policy, including as described below. We will engage in this activity with your consent, to manage our contractual relationship with you, or where we have a legitimate interest:

• You may choose to authorize WellnessLiving to share your Personal Information with selected Business Partners. For example, if you fill out Personal Information in advance of a visit to one of our Business Partners, we may share your Personal Information with other Business Partners when you book services through them.
  
  
• If you are a customer of one of our Subscribers and are using WellnessLiving Software Services to interact with that Subscriber, we will share your Personal Information with that Subscriber. For more information on the privacy policies of the Subscriber you interact with, please contact the Subscriber directly.
  
  
• If you connect a social media account to your WellnessLiving account, we may share Personal Information with your friends associated your social media account, other users of the social media platform, and your social media account provider.
  
  
• To provide you with marketing and promotional materials and opportunities, and facilitate social sharing.
  
  
• To send you marketing communications and offer other materials that we believe may be of interest to you, such as newsletters.
  
  
• To share information with other marketers (and their service providers) to permit them to send you marketing communications, consistent with your choices.
  
  
• To allow you to participate in sweepstakes, contests or similar promotions.
  
  
• In order to customize your advertising interactions, we may share Personal Information with marketing affiliates and other third parties only on an aggregate (i.e., anonymized) basis.
  
  
• We may share your anonymized Personal Information with third parties to enable them to run statistical research on individual or aggregate trends.
  
  
• We share Personal Information and Traffic Data with Business Partners who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Services and/or by making certain features available to our users. Those Business Partners shall be bound to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your contact data and other Personal Information to carry out their specific business obligations to WellnessLiving.
  
  
• We may transfer information about you to another company in connection with a merger, sale or acquisition by or of WellnessLiving. In this event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy.
  
  

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless we believe in good faith that disclosure of your Personal Information or any other information we collect about you is necessary to: (a) comply with a court order or other legal process; (b) protect the rights, property or safety of WellnessLiving or another party; (c) enforce our Terms and Conditions; or (d) respond to claims that any posting or other content violates the rights of third-parties. We retain your personal information while your account is active or as needed to provide you with Software Services. Additionally, we may retain personal information even after your account has been closed if retention is reasonably necessary to comply with our legal or regulatory obligations, resolve disputes, prevent fraud and abuse, enforce our Terms and Conditions or any other contract entered into between you and us, or if it is not technically feasible to delete your personal information. Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and you have provided us with your personal information, you may request information about our disclosures of certain categories of your personal information to third parties for direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. If you wish to opt-out of our sharing of your information with third parties for the third parties’ direct marketing purposes offline, please follow the instructions in Section 9 below. Where applicable law allows for such a request, you may request to access, correct, restrict, delete or object to the use of Personal Information that you have previously provided to us, or if you would like you may request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), by contacting WellnessLiving at privacy@wellnessliving.com with the subject line “Data Request.” We will respond to your request consistent with applicable law.

For your protection, we may need to verify your identity before complying with your request, and we may only fulfill requests with respect to the Personal Information associated with the particular email address you use to send us your request. We will try to comply with your request as soon as reasonably practicable. If you are a customer of a Subscriber, WellnessLiving may need to forward your request and refer you to your Subscriber to address your request.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. For example, when you make a purchase you may not be able to change or delete the Personal Information provided until after the completion of such purchase. There may also be residual information that will remain within our databases and other records, which will not be removed.

If you are under 18 years of age and a user of the WellnessLiving Software Services, you may also be entitled to ask us to remove content or information that you have posted to WellnessLiving Software Services by submitting a request to privacy@wellnessliving.com. Please note that your request does not ensure complete or comprehensive removal of the content or information. If you are a customer of one of our Subscribers and would no longer like to be contacted by one of our Subscribers, or would like request the exercise of a right as set out above in relation to Personal Information held by a Subscriber, please contact the Subscriber directly.

If you are a user of WellnessLiving Software Services and no longer want to receive marketing-related emails or SMS messages from us, you may opt-out of receiving these marketing-related emails or SMS messages by sending a request for list removal to privacy@wellnessliving.com or changing your preferences in the WellnessLiving Software Service. If you have provided your information to WellnessLiving, and opt-out, WellnessLiving will put in place processes to honor your request, which may require retaining some information for the purpose of remembering that you have opted-out.

We will try to comply with your request as soon as reasonably practicable. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still send you messages for purposes directly relating to your use of the WellnessLiving Software Services, and you cannot opt-out from receiving those messages.

Our mobile applications may also send push notifications to your mobile device. If you have previously consented to receiving push notifications and no longer wish to receive them, you can turn push notifications off at the device level. The applications may also request access to your device’s calendar application, camera, and microphone. If you have previously granted access to your device’s calendar application, camera, and microphone, and no longer want to allow access, you may edit the application settings at the device level. Children under the age of 13 are not permitted to use our Websites and services. We do not knowingly collect personal information from children under the age of 13 or utilize plug-ins or ad networks that collect personal information through child-directed third-party websites or online services. If we learn that we have collected personal information from a child under 13, we will take steps to promptly delete such information.

Our Websites and services generally require users to be at least 18 years of age. Unless our Websites and services contain the “Privacy Rights for California Minors in the Digital World” supplemental terms, our Websites and services do not collect age from users under 18. Without limiting the generality of the foregoing, our services may allow users above the age of 18 (such as healthcare providers, parents, and guardians) to submit personal information of minors. Such users assume full responsibility over their submission, use, and transmission of such information. Any information that you may reveal in a review posting or other online discussion or forum is intentionally open to the public and is not in any way private. You should think carefully before disclosing any personally identifiable information in any public forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict. You can log in to some of the WellnessLiving Software Services using sign-in services such as Facebook Connect or Google Sign-In. These services will authenticate your identity and provide you the option to share certain Personal Information with us such as your name and email address to pre-populate our sign up form. Some sign-in services like Facebook Connect give you the option to share information about your activities on our webWebsites with others within your network. In addition, when using some of our mobile applications you may have the opportunity to tell friends about our services by accessing the contacts in your Facebook or other social media account. If you submit testimonials, ratings or reviews to the WellnessLiving Software Services, any Personal Information you include may be displayed in the Service. If you want your testimonial removed, please contact us at support@wellnessliving.com. We currently use third party payment processors as a Third Party Offering for internet based payment services. If you wish to make a payment through WellnessLiving Software Services, your Personal Information may be collected by such processors directly and not by us, and will be subject to the third party’s privacy policy. We have no control over, and are not responsible for, third parties’ collection, use and disclosure of your Personal Information. WellnessLiving uses robust security measures to protect Data about WellnessLiving Subscribers, Clients and Visitors. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, when you enter sensitive information on WellnessLiving.com, we encrypt that information using secure socket layer technology (“SSL”). WellnessLiving reserves the right to change this Privacy Statement. WellnessLiving will provide notification of the material changes to this Privacy Statement through the Company’s Websites or by sending you an email at least thirty (30) business days prior to the change taking effect.Your continued use of our Websites and services following any such change constitutes your acceptance of the terms of the revised privacy policy. Questions regarding this Privacy Statement or the information practices of the Company’s Website should be directed to WellnessLiving by contacting us at privacy@wellnessliving.com or by mailing:

Wellness Living Systems Inc.
68B Leek Crescent Unit 201
Richmond Hill, Ontario
L4B-1H1

Tel: 1-888–668–7728