WRIGHT-SIZED WELLNESS, INC. (“Company,” “we,” “us,” or “our”) provides nutrition, health, and wellness coaching & consulting services through WrightSizedWellness.com and related pages, forms, social media groups, and communications (the “Site”). We respect your privacy and take it seriously. This Privacy Policy explains what we collect, how we use it, the choices you have, and the rights you may exercise under U.S. state and federal privacy laws.

By using the Site or our services, you agree to this Privacy Policy. If you do not agree, please do not use the Site.

1) SCOPE & WHO WE ARE

This Policy covers the Site, online intake forms, client portals, our Facebook groups, emails, and texts we send or receive.

Role Under Law: For U.S. state privacy laws, we act as a “Business”/“Controller”

Platform Provider: We deliver many Site features, including our contracted coaching services (the “Services”) through Digital Creator Studio and through the Facebook (Meta) platform.

2) WHO WE COLLECT INFORMATION FROM

Site visitors, prospects, and clients

Clients and Program participants

Email subscribers

Vendors/contractors and business partners

Our Services are not directed to children under 13 years of age, and we do not knowingly collect, use, or disclose personal information from children under 13.

If we learn that we have collected personal data from a child under 13, we will delete that information promptly and take steps to prevent further collection.

Special Considerations for Minors:

We take the privacy of all users seriously, particularly children and minors.  If you are between 13 and 17 years old, you may use our Services only with the consent and active supervision of your parent or legal guardian.

We may request limited information such as:

-          Name or display name

-          Email address

-          General wellness or nutritional goals

-          Parental contact information for consent verification

We use this information solely to provide educational or coaching services and do not use it for marketing or behavioral profiling.

We may require verifiable parental consent before activating certain features (such as account creation, data tracking, or personalized feedback).

Parental Consent and Rights

Parents or legal guardians have the right to:

-          Review their child’s personal information

-          Request deletion of their child’s data

-          Revoke previously granted consent

-          Request a description of what data has been collected and how it’s used

Requests should be directed to [email protected]. We will verify the requestor’s identity and relationship to the child before fulfilling any request, consistent with COPPA and state verification standards.

3) CATEGORIES OF INFORMATION WE COLLECT

We collect the following categories:

Identifiers - We collect your name, email, phone, postal address, account username.

Account & Commercial Data - We collect your name purchases, subscriptions, communications, service history, notes.

Payment Data - Your payments are processed by Stripe and Square; we do not store card numbers.

Wellness/Health (Sensitive) - We may collect weight logs, diet logs, wellness goals, and related inputs you provide for coaching.

Internet/Technical Data - Throughout analytics platform Google Analytics we collect your device type, browser, OS, pages viewed, time on page, referring URLs, cookies, pixels.

Marketing Preferences - We collect your email, your opt-in status, unsubscribes, and related preferences.  Opt-in data and consent for SMS will not be shared with third parties.

User Content - We collect your messages, uploads, feedback, intake responses, and community-style inputs.

4) SOURCES OF INFORMATION

We may obtain information directly from you  via forms, intake, scheduling, emails/texts, purchases.

We may collect data automatically through cookies, Meta pixels, analytics tools like Google Analytics.

We may collect information through third-party providers like the DigitalCreatorStudio.com platform, Stripe for payments, and Jotform for signatures.

5) NOTICE AT COLLECTION:

A)     Identifiers:  examples are name, email.  Purpose of use: accounts, service delivery, support, security, marketing with consent.  Retention:  deleted upon request. Not sold. Potentially “shared” for targeted ads via analytics/ads, opt-out available.

B)      Commercial Data:  examples are orders, subscriptions. Purpose of use: billing, records, support, compliance. Retention: kept for business records, and kept no longer than necessary to fulfill the disclosed purpose unless required by law. Not sold. Not “shared” for targeted ads.

C)      Payment Data: examples are via Stripe, Square. Purpose of use: process payments, prevent fraud. Retention: Stripe and Square retain per their policies; we keep receipts per law. Not sold. Not “shared” for targeted ads.

D)     Internet/Technical: examples are cookies, GA events. Purpose of use: site operation, analytics, improvements. Retention: kept for business records, and kept no longer than necessary to fulfill the disclosed purpose unless required by law. Not sold. Potentially “shared” for targeted ads via analytics/ads, opt-out available.

E)      Wellness/Health (Sensitive): examples are weight, nutrition logs. Purpose of use: coaching and progress tracking only. Retention: deleted upon request, and kept no longer than necessary to fulfill the disclosed purpose unless required by law. Not sold. Not “shared” for targeted ads.

F)      Marketing Prefs: examples are email/SMS opt-ins. Purpose of use: Communications per consent, unsubscribes honored. Retention: Kept for business records, and kept no longer than necessary to fulfill the disclosed purpose unless required by law. Not sold. Not “shared” for targeted ads.

6) HOW WE USE INFORMATION (PURPOSES & LEGAL BASES)

Purposes:

·       We use your information to provide your coaching sessions, deliver our wellness programs, and give you personalized client support.

·       We keep your payment details so you can be billed correctly and securely, and we manage your subscriptions to avoid interruptions in service.

·       We maintain your wellness records, such as progress logs, so you and your coach can track your development over time.

·       We use your information to keep our website and systems secure, and to help prevent fraud, misuse, or other unauthorized activity.

·       We review data and analytics to understand how our services are performing and to make improvements to our programs and online content.

·       We may contact you with updates, service reminders, or special offers, but only by email or text if you have given us permission.

·       We also use your information when necessary to follow the law, meet regulatory requirements, or enforce our service terms.

Legal Bases:

·       We use your information when it is necessary to carry out our Services.

·       We use your information when you give us permission.

·       We use your information for our legitimate business needs, like keeping our systems secure, improving our programs, keeping adequate records, and learning how to better serve clients.

·       We use your information when the law requires it, such as keeping tax records, responding to valid legal requests, or meeting other regulatory obligations.

Email Policies

We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information.We will maintain the information you send via e-mail in accordance with applicable federal law.

In compliance with the CAN-SPAM Act, all e-mails sent from our organization will clearly state who the e-mail is from and provide clear information on how to contact the sender. In addition, all e-mail messages will also contain concise information on how to remove yourself from our mailing list so that you receive no further e-mail communication from us.Our emails provide users the opportunity to opt-out of receiving communications from us and our partners by reading the unsubscribe instructions located at the bottom of any e-mail they receive from us at anytime.Users who no longer wish to receive our newsletter or promotional materials may opt-out of receiving these communications by clicking on the unsubscribe or ‘Remove’ link in the e-mail.

7) COOKIES, ANALYTICS, AND ADS

Use of Cookies And Pixels

Similar to other websites, our website utilizes a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the websites visited just before and just after our own, as well as your IP address.A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.

Third Party Use Of Cookies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) 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.

We use cookies/pixels for essential functions and to understand content performance.

You may manage cookies in your browser by using opt-out tools like DAA (https://digitaladvertisingalliance.org/integrate-webchoices-ccpa) and  Your Online Choices (https://youradchoices.com/appchoices).

Do Not Track we do not respond to DNT browser signals.

Opt-Out Preference Signals (UOOM/GPC) where required by law (e.g., CA, CO, CT, DE, NE, NH, NJ, MN, MD), we treat a valid browser-level Global Privacy Control or comparable signal as a request to opt out of sale/sharing/targeted ads.

8) HOW WE SHARE INFORMATION

We do not sell personal information for money. Some states define “sale”/“share” broadly to include third-party analytics or cross-context behavioral advertising, for this, please see the following:

We may disclose to:

·       Service Providers and Processors: We share your information with trusted third parties who help us run our business. This includes processing your payments, keeping our website secure, performing analytics, improving site functionality, managing email or SMS communications, and providing customer service. For example, we may share your credit card number with Stripe to process a payment, or your mailing address with a delivery service to send you materials you ordered. These providers only receive the information they need to perform their work and are not allowed to use it for any other purpose. Our current providers include Mastermind.com (our platform), Stripe (payments), Jotform (signatures and forms), email/SMS platforms, Google Analytics, and security and support vendors.

·       Business Affiliates and Transactions: If our business is involved in a merger, acquisition, or sale of assets, your information may be shared or transferred as part of that process.

·       Legal and Safety Obligations: We may disclose information if required by law, in response to lawful requests, or when necessary to protect our rights, safety, or the safety of others.

·       Other Vendors: Some vendors work with us under contracts that require them to use your data only for our documented purposes, keep it confidential, notify us promptly of any incidents, and never re-identify, resell, or transfer it without our permission.

·       We never use or share your Sensitive Personal Information (defined below) for advertising.

9) SENSITIVE PERSONAL INFORMATION

Your wellness/health inputs (e.g., weight, diet logs) are treated as “Sensitive Personal Information.” We do not use or disclose your Sensitive Personal Information for purposes that, with limited exceptions, are not necessary to provide our products and services as are reasonably expected by an average Consumer requesting those goods and services. We use them only to deliver coaching and track progress, and we do not sell or share them for advertising.

10) SECURITY

We maintain a written Security Program with administrative, technical, and physical safeguards appropriate to the sensitivity of data, including access controls, secure passwords, and an incident response plan. No system can be 100% secure. We will notify you and/or regulators of certain incidents as required by law.

11) YOUR CHOICES

Email Marketing: unsubscribe any time via the email footer or contact [email protected].

Cookies/Ads: use browser settings and the ad-industry tools above.

12) YOUR PRIVACY RIGHTS

We comply with privacy regulations using a “highest common denominator” approach.  Your rights in relation to our Site are as follows:

Right to Know/Access: You have the right to request that we disclose the following to you as it relates to the 12-month period preceding the Company’s receipt of your request:

-          The categories of Personal Information we have collected about you.

-          The categories of sources from which the Personal Information was collected.

-          The business or commercial purpose for collecting, Selling, or Sharing Personal Information.

-          The categories of Personal Information we disclosed, Sold, or Shared for a business purpose.

-          The categories of third parties to whom we disclosed, Sold or Shared Personal Information, by the category of Personal Information.

-          The specific pieces of Personal Information we collected about you.

Your right to access your Personal Information means that we will provide data in a structured, machine-readable format.

Right to Request Correction of Your Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you.

Right To Request Deletion of Your Personal Information. You have the right to request that we delete Personal Information we collected or maintain about you. Upon receipt of a verifiable request and as required by the CCPA, we will delete and direct any Service Providers, Contractors, and Third Parties to delete your PI from their records.

Non-Discrimination for exercising rights. We will not discriminate against you for exercising any of your rights. For example, we generally will not provide you with a different level or quality of goods or services if you exercise your rights.

How to Exercise Your Rights:

Email: [email protected]

California & Nevada Residents:

Under the California Consumer Privacy Act (“CCPA”), Nevada law, and laws of other states, the sale of your personal information means the sharing of your personal information with certain third parties for monetary or other valuable consideration.  Under these laws, consumers have the right to direct a business that sells personal information about the consumer to third parties not to sell the consumer’s personal information. Currently, we do not share your personal information in a manner that would be considered a sale under CCPA, Nevada law, or other state laws.  We only disclose your personal information to our service providers pursuant to contracts that prohibit the service provider from using your personal information for any purpose other than those services specified in the contract.

13) PAYMENTS, E-SIGNATURES, AND PLATFORM DISCLOSURES

Payments: We use Stripe and Square for payment processing. We do not store card numbers and remain PCI compliant. Your payment data is handled under Stripe’s terms, which are viewable here: https://stripe.com/privacy and https://square.com/privacy.

E-Signatures: we use Jotform (free version) for signatures and forms.  Submissions are subject to Jotform’s privacy policy, located at https://www.jotform.com/privacy/.

Facebook.com. We use Facebook to administer our group programs and provide a community hub.  See Facebook’s (Meta’s) privacy policy here: https://www.facebook.com/privacy/policy/.

DigitalCreatorStudio.com: we use Digital Creator Studio to provide: Funnel/Page Builder, Email Marketing (broadcasts, automations) Sales Pipelines & CRM-like tools, Calendar scheduling Automations, Inbox & Review management Reporting & Analytics, Tech admin/support.

You can find Digital Creator Studio’s privacy policy located here: https://digitalcreatorstudio.com/privacy-policy/.

14) AUTOMATED DECISIONMAKING/ PROFILING

We do not use automated decision making / profiling in our Services.

15) CROSS-BORDER TRANSFERS

We operate in the United States. If you access the Site from outside the U.S., your data will be transferred to and processed in the U.S.

16) APPEALS PROCESS (WHERE REQUIRED)

If we deny your privacy request, you may appeal by emailing [email protected] with “Privacy Appeal” in the subject line and a brief explanation. We will respond within 45 days with our decision and supporting reasons. If denied again, you may contact your state Attorney General.

17) AUTHORIZED AGENTS, HOUSEHOLDS

You may designate an authorized agent to make requests on your behalf. We may require proof of authorization and still require you to verify your identity directly. For certain “household” requests, we may need extra steps to verify all household members.

18) DE-IDENTIFIED & AGGREGATED DATA

We may create, use, and share de-identified or aggregated data for analytics and service improvement. We commit to maintain and use de-identified data without attempting to re-identify it.

19) CHANGES TO THIS POLICY

We may update this Policy from time to time. We will post updates here with a new “Last Updated” date. Material changes will be highlighted or otherwise communicated as required by law.

20) CONTACT US

WRIGHT-SIZED WELLNESS, INC.

Privacy Officer: Jodi Sheakley-Wright, [email protected]
Phone: 704.965.0785
Mailing Address: 8000 Qualla Rd, Chesterfield Virginia 23832