Privacy Policy

Synergy CHC Corp Website and App Privacy Policy

Effective Date: 12^th January 2021

Synergy CHC Corp ("Synergy," "we," "our," or "us") provides this Privacy Policy ("Privacy Policy") to describe how we collect, use, and share the information of individuals who visit our websites at www.focusfactor.com, affiliated websites that link to this Privacy Policy, and our mobile app (the "app") (collectively the "Properties").

Information Collection

When using our Properties, you may voluntarily provide information about yourself, including your name, shipping address, billing address, email address, phone number, credit or debit card account information, and any other information you choose to provide. We collect this information when you place an order with us, send an email to us requesting information, or interact with us for any other purpose.

We also collect information relating to your interactions with us and our Properties, including browser type, IP address, pages visited and other activities on the Site, device type, and time and date of visit, and other information we collect through the use of cookies and similar technology. "See the "Analytics" section of this privacy notice to learn more about the use of this information and the choices available to you.

Children's Privacy

Our Properties are not intended to be used by children, and we do not knowingly collect or maintain personal information from children. If you are a parent or legal guardian of a minor under 13 years old, and you believe your child has provided personal information to our Properties, you may contact us at support@focusfactor.com to request that we delete your child's personal information from our systems.

Cookies and Site Tracking

We collect information from other sources, such as through the use of cookies and similar technologies. We also gather information from both online and offline data providers. This information includes internet browsing behavior, demographic data, or interest-based data.

A cookie is a small text file stored on your computer that contains information that helps the website to identify and track the visitor.

Two types of cookies are used. The first type of cookie is a "Session Cookies." During the time you visit the website, our web server assigns your browser a unique identifier string so as not to confuse you with other visitors. A session cookie is never stored permanently on your computer and disappears when you close your browser.

The second type of cookie are "Permanent Cookies", which save a file permanently on your computer. This type of cookie is used to track how visitors move around on the website. This is only used to offer visitors better services and support.

The following categories of cookies are used on our Properties:

• Strictly necessary cookies. These are cookies that are required for the operation of our Properties. They include, for example, cookies that enable you to log into secure areas of our Properties.
• Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Properties when they are using it. This helps us to improve the way our Properties work, for example, by ensuring that users are finding what they are looking for easily.
• Targeting and advertising cookies. These cookies record your visit to our Properties, the pages you have visited and the links you have followed. We will use this information to make our Properties and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies and similar technologies used on our Properties and the purposes for which they are used in the table below:

To opt out of cookies, you can alter the settings on your internet browser to accept or reject a website from using cookies. This can affect functionality of the website.

When you browse our store, we automatically receive your computer's internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.

We also collect information: regarding device IDs or identifiers, connection information, device software, statistics of page views, ad data, referral URLs and IP data; to determine your general geographic location, so that we can provide location-specific content to you; to assist in responding to complaints and queries; to investigate any possible breach of our terms or conditions including fraud or illegal activities with the use of your information; and with your permission, we will send you emails about our store, new products, and other updates.

Information Use

We may use your information for any lawful purpose, including the following:

• To fulfil your orders for products and services you request;
• To respond to your inquiries;
• To operate and improve our services, including to provide better services, products, and opportunities to our customers and visitors to our Properties;
• To operate, personalize, and improve the Properties, including for analytics purposes;
• To send survey, promotions, and marketing materials that may be of interest to you;
• To comply with the law and to maintain the security of our Properties; or
• With your consent, or as otherwise disclosed at the time information is collected.

Information Sharing

We may share the information we collect with other parties, including the following:

• With third party vendors who process data on our behalf to help our business operations, including fulfilling orders, payment processors, delivering packages, and providing promotional services and marketing;
• Third-party companies, vendors, business partners and other organizations whose products or services we think may interest you.
• With the host of our online store, which provides us with the online e-commerce platform that allows us to sell our products and service to you;
• As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as part of a bankruptcy proceeding;
• Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties;
• With your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information that has been de-identified or aggregated without limitation.

Analytics

We may work with third parties that collect data about your use of the Properties and other sites or apps over time for non-advertising purposes. We use Google Analytics and other third-party services to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Properties, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

Third-Party Links and Tools

The Properties may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this privacy policy. You should review the privacy notices of other websites or apps that you use to learn about their data practices.

The Properties may also include integrated social media tools or "plug-ins," such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Properties, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.

Your Choices

To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. You may also out of receiving marketing emails or newsletters by contacting us through the Contact Us link on the website. If you wish to no longer receive emails from third parties, you should contact the third party or unsubscribe. If you opt out, we may still send you non-promotional emails, such as emails about your purchases, account, or ongoing business relations.

For choices with respect to third-party interest-based advertising activities, please see the "Digital Advertising & Analytics" section above.

We may share personal information about you with third parties for the third party's own marketing purposes, including sending direct marketing materials to you. If you would like to opt out of this kind of sharing, please email us at support@focusfactor.com to inform us of your decision.

International Visitors

This section applies to those that visit our Properties from the European Economic Area ("EEA"), United Kingdom, or Switzerland.

Synergy CHC operates businesses in multiple jurisdictions, some of which are not located in the European Union or European Economic Area (EEA). Please be aware that countries outside the EEA do not always have data protection laws that are as protective as those in your location. If you are located outside of the United States, please be advised that we process and store your information in the United States.

Data Protection Officer. We have appointed a Data Protection Officer ("DPO") to oversee compliance with this policy. You have the right to lodge a complaint at any time to a supervisory authority. The data protection supervisory authority for you depends upon the country or geographical area in which you are located.

Your Data Protection Rights. You have a right to the following:

• Request information about whether we hold information about you, and, if so, what that information is and why we are holding/using it.
• Request access to your information (commonly known as a "data subject access request"). This enables you to receive a copy of the information we hold about you and to check that we are lawfully processing it.
• Request correction of the information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your information. This enables you to ask us to delete or remove information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your information where you have exercised your right to object to processing.
• Object to processing of your information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your information or profiling of you.
• Request the restriction of processing of your information. This enables you to ask us to suspend the processing of information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your information in an electronic and structured form to you or to another party (commonly known as a right to "data portability"). This enables you to take your information from us in an electronically useable format and to be able to transfer your information to another party in an electronically useable format.
• Withdraw consent. In the limited circumstances where you have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes to which you originally agreed, unless we have another proper and legitimate basis for doing so.

To exercise these rights, contact us at support@focusfactor.com. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

Retention

We will process and store your information only for the period necessary to achieve the purpose of the storage, or as permitted by law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the purposes for which we process it, and whether we can achieve those purposes through other means. We also consider the periods for which we might need to retain information in order to meet our legal obligations, or to deal with complaints and queries, and to protect our legal rights in the event of a claim being made.

When we no longer need your information, we delete or destroy it. We will also consider if and how we can minimize over time the information that we use, and if we can anonymize your information so that it can no longer be associated with you or identify you, in which case we will use that information without further notice to you.

Nevada Privacy Rights

Although we do not currently conduct sales of personal information, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future.

To exercise this right, please contact us by email at support@focusfactor.com.

California Privacy Rights

This section contains disclosures required by the California Consumer Privacy Act ("CCPA") and applies only to "personal information" that is subject to the CCPA.

Personal Information We Collect. In the preceding 12 months, we collected the following categories of personal information about California consumers.

Categories of Sources. We collect personal information from the following categories of sources:

• Consumers;
• Advertising networks;
• Data analytics providers;
• Social networks;
• Service providers; and
• Affiliated entities.

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation:

• Our commercial purposes, including marketing, advertising, and enabling commercial transactions.
• Our business purposes as identified in the CCPA, which include:
• Auditing related to our interactions with you;
• Legal compliance;
• Detecting and protecting against security incidents, fraud, and illegal activity;
• Debugging;
• Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
• Internal research for technological improvement;
• Internal operations;
• Activities to maintain and improve our services; and
• Other one-time uses.

Recipients of California Personal Information.

We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:

• Service providers;
• Affiliates not under the Synergy brand;
• Government entities;
• Advertising networks;
• Internet service providers;
• Data analytics providers;
• Operating systems and platforms;
• Social networks; and
• Consumer data resellers.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we have collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• The right to request that we delete the personal information we have collected from you.
• The right to opt-out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales of information, we will be unable to provide you with the services that rely on such sales.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the rights described above, please contact us using the following information and submit the required verifying information, as further described below:

• Email at support@focusfactor.com.
• Do not sell my personal information

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide the name and email address associated with your account.

Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf. You will need to provide your identification, the identification of the agent, and your written consent for them to act on your behalf.

Minors' Right to Opt In. We do not have actual knowledge that we disclose the personal information of minors under 16 years of age.

Changes to Our Privacy Policy

If our information practices change, we will post these changes on this page. We encourage you to visit this page periodically to learn of any updates.

Contact Us

If you have questions, comments, or concerns about this privacy policy, you can contact us using the Contact Us form or write to us at:

The Manager
Focus Factor®
865 Spring Street
Westbrook, ME 04092

support@focusfactor.com