Privacy Policy

Reform Botanicals LLC ("Reform Botanicals", "we", "our", or "us") respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our website (www.reformbotanicals.com), products, and services that link to this policy (our "Services") and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.
• When you interact with our advertising on third-party websites and services, if that advertising includes links to this policy.
• When you provide your information to us in person, such as at pop-up events, sampling events, or trade shows.

It does not apply to information collected by:

• Us on any other website operated by Reform Botanicals or any third party that does not link to this policy; or
• Any third party, including retailers that sell our products to their own customers, or through any application or content (including advertising) that may link to or be accessible from or through the Services.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy below).

Children's and Minors' Data

Our Services are not intended for, and we do not knowingly collect any personal data from, anyone under the age of 21. We require visitors to confirm that they are 21 or older before entering our website and at checkout. If we learn we have collected or received personal data from anyone under 21 years old, we will cancel and refund any related order, and delete that information except as needed to process the refund, prevent fraud, or comply with law.

The Personal Data That We Collect or Process

"Personal data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, credit card number, or any other identifier we may use to contact you online or offline).

The types and categories of personal data we collect or process include:

• Account and contact information, including name, address, email address, phone number, username, and other contact information you provide us, and the name, shipping address, and contact information of the person who will receive your order, if different from you.
• Payment information, including credit card, debit card, or digital wallet (such as Google Pay) information you use in connection with the Services. Payment card details are collected and stored by our payment processors and e-commerce platform, including to process recurring subscription charges; we do not store full card numbers.
• Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
• Demographic information, including your age.
• Age verification information, such as your confirmation that you are 21 or older and delivery records showing that an adult signed for your package. Our shipping carriers may check a government-issued ID at delivery under their own privacy policies.
• Location information, including general geographic location such as country, state or province, or city.
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
• Content and information you elect to provide as part of your profile or in any reviews you make through the Services or emails, chats, or other communications sent to us, including claims under our Shipping & Return Policy and product safety reports.
• Images, voice recordings, and videos collected or stored in connection with the Services.
• Marketing preferences, including records of your consent to receive emails and text messages.
• Subscription and billing authorization records, including records of your consent to recurring charges, the subscription terms shown to you when you subscribed, and your renewal, change, and cancellation history.
• Rewards program information, including your points balance, rewards earned and redeemed, and referral activity.
• Business contact information for staff of retailers that carry our products.

If you give us information about another person, such as a gift recipient, you confirm that you have the right to share it with us and that the recipient is 21 or older. If you refer a friend, we use the information you provide only to send the referral and apply rewards, and you confirm your friend is 21 or older.

Some of the information identified above, including information about the wellness products you purchase or ask about, and information you share in a product safety report or about a reaction to a product, may be considered sensitive data or consumer health data under certain laws. We do not ask for medical history or diagnoses, and we ask that you not include it in claims or product safety reports. If required under applicable law, we will collect and process sensitive personal data only with your consent, and we do not sell sensitive personal data or use it for targeted advertising without your consent where consent is required by law. See our Consumer Health Data Privacy Policy [LINK]. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, place an order, subscribe, or make a purchase, participate in surveys or promotions, sign up for our emails or texts, or post reviews or submit claims through the Services.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, logs, and other communication data, and which resources and Services features that you access and use.

We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking).

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by clicking the "Your Privacy Choices" link in the footer of our website or enabling Global Privacy Control in your browser. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies, such as Google Analytics.
• Your device manufacturer.
• Your internet or mobile service provider.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, payment processors, shipping and fulfillment providers, promotions services, loyalty and rewards program providers, and analytics, security and anti-fraud services.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
• Fulfill and manage purchases, orders, subscriptions, deliveries, payments, and claims, store credit, and replacements under our Shipping & Return Policy.
• Fulfill any other purpose for which you provide it.
• Provide you with notices about your account and subscription, including expiration, price change, and renewal notices.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties' services. We may use your information to model, segment, target, offer, market, and advertise our Services.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
• Verify that you are 21 or older and that we may lawfully ship to your location, and detect and prevent fraud, including fraudulent Shipping & Return Policy claims.
• Send reminders about items left in your cart.
• Administer our rewards and referral program.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our Services.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please click "unsubscribe" in any marketing email or reply STOP to any text message. For more information, see Your Rights and Choices About Your Information below.

Large Language Model Training Disclosure

We do not collect, use, or sell personal data for the purpose of training large language models.

Text Message Marketing

If you choose to join our text message program, the following terms apply:

• Consent. By entering your mobile number and checking the box to opt in, you agree to receive recurring automated marketing text messages from Reform Botanicals at the number you provide. Consent is not a condition of any purchase.
• Frequency and cost. Message frequency varies, and we will not send more messages than permitted by applicable law. Message and data rates may apply.
• Opt out and help. Reply STOP to any message to unsubscribe, or HELP for help. You may also revoke consent by any reasonable means, including by emailing hello@reformbotanicals.com.
• Timing and age. We send marketing texts only during hours permitted by applicable law. You must be at least 21 years old to enroll.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our organization, including our fulfillment provider, shipping carriers, payment processors, and email and text message providers, and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Reform Botanicals' assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Reform Botanicals is among the assets transferred.
• To advertising and analytics partners through cookies and pixels, which may be considered a "sale" or "sharing" of personal data, or targeted advertising, under some state laws. For more information, see Your Rights and Choices About Your Information.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To our bank, insurers, and auditors, as needed to confirm our licensing and compliance.
• To our manufacturer, testing laboratories, and government authorities, as needed to investigate product safety reports or carry out a product recall.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms and Conditions [LINK] Shipping & Return Policy [LINK], and other agreements, including for billing and collection purposes, to review and resolve claims, and to respond to payment disputes and chargebacks.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not sell, rent, or share your mobile phone number or text message opt-in data with third parties for their marketing purposes.

The categories of personal data we may disclose include:

• Account and contact information.
• Payment information. 
• Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
• Demographic information.
• Location information, including general geographic location.
• Device information.
• Content and information you elect to provide to us.
• Images, voice recordings, and videos collected or stored in connection with the Services.
• Identity document information.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Services to collect information through other tracking technologies by using our cookie preferences tool [LINK]. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services may not respond to all browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.
• Promotions by Us. If you do not wish us to use your information to promote our own products or services, you can opt out by clicking "unsubscribe" in any marketing email, emailing hello@reformbotanicals.com, or replying STOP to any text message.
• Targeted Advertising by Us. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target audience preferences, you can opt out by clicking the "Your Privacy Choices" link in the footer of our website or enabling Global Privacy Control in your browser.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt out by clicking the "Your Privacy Choices" link in the footer of our website. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of targeted ads from members of the Network Advertising Initiative ("NAI"), see NAI: How to Opt Out.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
• Opt Out of Using Personal Data for Sales, Targeted Advertising, and Profiling for Certain Legal or Similarly Significant Decisions. You may request that we do not use your personal data for these purposes. Some states may also grant you the ability to learn more about or challenge those automated decisions.
• Sensitive Data. Where required, we will obtain your consent before processing sensitive personal data, or allow you to limit its use.
• List of Third Parties. Residents of some states may request a list of the specific third parties to which we have disclosed personal data.
• Non-Discrimination. We will not deny you goods or services, charge you different prices, or provide a different level of quality because you exercised your rights.

Important: The exact scope of these rights varies by state. There are also several exceptions where we may not have an obligation to fulfill your request. Regardless of where you live, you may ask us to access, correct, or delete your personal data, and you may opt out of targeted advertising.

To exercise any of these rights, please email hello@reformbotanicals.com with the subject line "Privacy Request" [or call us toll-free at [TOLL-FREE NUMBER]]. We will verify your identity by matching information you provide to our records, you may use an authorized agent, and we will respond within 45 days. To appeal a decision regarding a consumer rights request, reply to our decision or email hello@reformbotanicals.com with the subject line "Privacy Appeal"; if your appeal is denied, you may contact your state Attorney General.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data "sales" as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to this designated address: hello@reformbotanicals.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

If you are a California resident, additional information applies to you. In the past 12 months, we have collected the following categories of personal data: identifiers; customer records; characteristics of protected classifications (age); commercial information; internet or network activity; general geolocation data; audio, electronic, or similar information; inferences; and sensitive personal information (account log-in credentials and payment card details). We disclose these categories for business purposes to the recipients described in Who We Disclose Your Information To.

We have "sold" or "shared" identifiers, internet or network activity, and commercial information to advertising and analytics partners through cookies and pixels.  We do not knowingly sell or share the personal data of consumers under 16. We do not use or disclose sensitive personal information for any purpose that would give you a right to limit its use under California law. We do not disclose personal data to third parties for their own direct marketing purposes (California "Shine the Light").

If we offer a discount for signing up for our emails or texts, that offer is a financial incentive. Joining is optional, you may withdraw at any time by unsubscribing, and we estimate the value of your personal data to be roughly equal to the value of the discount. Our Reform Botanicals Rewards program, including points and the $10 referral reward, is also a financial incentive. Joining is optional, you may leave at any time, and we estimate the value of your personal data to be roughly equal to the value of the rewards offered.

If you live in Washington, Nevada, or another state with a consumer health data law, please see our separate Consumer Health Data Privacy Policy [LINK]. We do not use location data to identify, track, or send messages or ads to people near health care facilities.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

In general, we keep order and transaction records for up to seven (7) years, account information while your account is active, marketing consent records for at least five (5) years after you unsubscribe, customer service and claim records for up to three (3) years, analytics data for up to [26] months, and store credit records for as long as any balance remains.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the "last updated" date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

If we make material changes to how we use or share your personal data, we will notify you by a prominent notice on our website or by email before the changes take effect.

Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at:

hello@reformbotanicals.com or Reform Botanicals LLC, Attn: Privacy, 697 Grand St #132, Brooklyn, NY 11211

To register a complaint or concern, please email hello@reformbotanicals.com with the subject line "Privacy Complaint."

If you have a disability and need this policy in an alternative format, please contact us at hello@reformbotanicals.com.