Privacy Policy

Effective Feb 24, 2025

This Privacy Policy (“Privacy Policy”) applies to all websites, portals, or pages ownedor operated by NULASTIN, Inc., a Colorado corporation (“Company,” “we,” “us,” or “our”), including those accessible through the domain NULASTIN (“Site”). This Privacy Policy outlines our practices relating to the collection and use of Personal Information from people who visit the Site or who interact with us using another site, program, platform, app, or service (“Program”).

1. COLLECTION OF PERSONAL INFORMATION

We may gather, collect, record, hold, distribute, share, disclose, or otherwise usePersonal Information about you. “Personal Information” means information thatidentifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal Information” does not include: (i) publicly available information from government record, or (ii) de-identified or aggregate consumer information.

1.1. INFORMATION PROVIDED BY YOU We collect Personal Information that you provide to us, including without limitation anyPersonal Information you provide during your use of the Site or any other Program. Forexample, we may collect Personal Information from you when you:

Provide us with Personal Information through the Site, any other Program, or via telephone;
Create an account;
Purchase any of the Company’s products;
Seek customer support;
Request an exchange or return of any of the Company’s products;
Request any information from or about the Company, such as a newsletter, e-alert, or any other information about our products, events, or business partners;
Communicate with a representative of our Company;
Communicate with us via third-party social media sites;
Participate in any contest, loyalty program, promotion, or sweepstake;
Apply for a job with the Company; or
Otherwise communicate with us.
In these instances, the following types of Personal Information may be collected from
You:

Your name;
Account name;
Unique personal identifier;
Mailing address and/or billing address;
E-mail address;
Phone number;
Your username and password;
Billing account information, such as credit card or debit card number;
Your purchase history;
Photographs; and Voice recordings.

1.2 INFORMATION AUTOMATICALLY COLLECTED. When you access the Site or use a Program, we automatically collect certain PersonalInformation about you, including:

Device Information. We (or our service providers) may collect information about the computer, tablet, phone, or other device you use to access any of the Programs, including the Internet Protocol address, hardware model, operating system and version, mobile network information, and other unique device identifiers (hereinafter collectively referred to as “Device Identifiers”).
Cookies and Other Web-based Tracking Technologies. We (or our service providers) may use different technologies such as cookies, web beacons, or other types of small temporary files or web-based tracking technologies to gather certain information. A cookie is a small data file stored by your web browser or hard drive that helps us improve the way we deliver our Site or other Programs to you, helps us improve your overall experience using our Site or other Programs, and/or helps us analyze the areas and features of our Programs that are most popular, or to detect fraud. Web beacons are electronic images that may be used in our Programs or emails. Web beacons help deliver cookies, calculate count visits, and understand usage. While most websites automatically accept cookies for these purposes, you may be able to instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit, including the Site.
Geo-location Data. Subject to your device permissions, we (or our service providers) may be able to collect information about the precise location of your device or may gather other general location data based on GPS data, mailing address, and/or billing address (hereinafter collectively referred to as “Geo-location Data”).
Social Media Information. If any of our Programs offer social media features, such as the Facebook Like button or similar social media interactive mini-programs, these features may collect your Internet Protocol address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly. Your interactions with these features may be governed by the privacy policies of the company providing it.

1.3. EMPLOYEES We collect personal information in the context of your role as anapplicant to, an employee of, director of, or officer of, our business. The personalinformation we collect may include name, Social Security number, address, date ofbirth, gender, race, ethnicity, bank account and routing number, tax filing status,emergency contact information, telephone number, family member names, educationalbackground, criminal background, employment history, medical provider information,personal information about your dependent(s), medical insurance provider,compensation and benefits data, workplace, and title. We only use this information forpurposes of evaluating your qualifications, evaluating your performance, or for providing compensation, benefits, and services in the context of the employment relationship. The personal information described in this paragraph is “Employee Data”.

1.4. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION. We may collect Personal Information about you from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to your use of our Site. For example, we may collect Personal Information from publicly accessible sources; directly from a third party; or from a third party with your consent. We may merge or co-mingle that Personal Information with the Personal Information we maintain about you and other data collected on or through our Site. We may collect Personal Information from: advertising networks; internet service providers; data analytics providers; government entities; operating systems and platforms; and social networks.

2. HOW WE USE YOUR INFORMATION

2.1. PRIMARY WAYS WE USE YOUR INFORMATION. Your Personal Information maybe gathered, collected, recorded, held, or otherwise used by or on behalf of theCompany and our service providers to provide, maintain, and improve our services,including for the following purposes:

- Process your transactions with the Company, including without limitation fulfilling your orders, process exchanges and/or returns, and send shipping notifications;
Send support and administrative messages, and respond to your comments, questions, and customer service requests;
Communicate with you about products, offers, or any other events offered by us and others, and/or to offer and provide you with news and information that the Company thinks will be of interest to you;
Allowing you to sign up and participate in any other Company communication resources, including without limitation any Company newsletters or blogs;
Monitor and analyze trends, usage, and activities in connection with the Company’s goods/services and industry;
Personalize your experience and the advertisements and content you see when you use any Program based on your preferences, interests, and browsing and purchasing behavior;
For compliance purposes, as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested under any subpoena;
To facilitate your use of various social media sharing features or other integrated tools (including, for example only, certain Facebook features, such as a Facebook “Like” button) which you may use as part of social media pages;
To facilitate any contests, sweepstakes, loyalty programs, or promotions and process and deliver entries and rewards;
To evaluate your application if you apply for a job; or
To carry out any other purpose described to you at the time the Personal Information is collected.

2.2. OTHER WAYS WE MAY USE YOUR INFORMATION. In addition to the above,Your Personal Information may be gathered, collected, recorded, held, or otherwise used for the following additional purposes:

Outside Professionals. To use with, or otherwise distribute, share or disclose to, any of the Company’s professional advisors such as attorneys or accountants (“Outside Professionals”) in order to facilitate the professional advice from those Outside Professionals; or
Government Agencies. To use with, or otherwise distribute, share or disclose to, any government agencies or third parties in order to comply with, or otherwise pursuant to, any subpoena, court order, or other governmental order, law, or regulation (including without limitation tax reporting).
Auditing. Auditing related to a current interaction with you, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
Security. Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes;
Debugging. Debugging to identify and repair errors that impair existing intended functionality;
Transient Use. Short-term, transient use, including, but not limited to, non- personalized advertising shown as part of a consumer’s current interaction with us provided that your Personal Information is not disclosed to a third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;
Services. Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf;
Advertising. Providing advertising and marketing services to you. With your permission, we may send you emails about our store, new products, and other updates.
With your permission, we may send you text messages about our store, new products, and other updates.
Research. Undertaking internal research for technological development and demonstration;
Quality and Safety. Undertaking activities to verify or maintain the quality or safety of our products and services and to improve, upgrade, or enhance our products and services; and
Commercial Interests. Advancing our commercial or economic interests, such as by inducing a person to buy, join, subscribe to, provide, or exchange products, goods, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

2.3.

The Company may also use or share your Personal Information for another reasonthat is compatible with the purposes described above. For example, we consider de-identification, aggregation, and other forms of anonymization of Personal Information to be compatible with the purposes listed herein and in your interest because theanonymization of such information reduces the likelihood of improper disclosure of that information. If we need to use Your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

3. SHARING OF INFORMATION

We may distribute, share or disclose Personal Information about you as describedherein:

Service Providers. We may share or disclose your Personal Information with our service provides or other third party vendors, including without limitation the following types of service providers:

a. Email, internet, or other telecommunication service providers, including website hosting;
b. Cloud, other data storage, or other hosting service providers;
c. Third-party payment service providers, including without limitation third-party credit card processors;
d. Analytics companies who assist us with various types of data analytics, web analytics, and app analytics;
e. Third-party delivery or shipping service providers;
f. Other third-party contractors we engage to assist us in providing our products and services;
g. App design; and
h. Database management.

Third-Party Application Providers. We may share or disclose Your Personal Information to third party application providers, including Shopify, credit card processors, other third party payment service providers, or intermediary services that assist in processing your payments.
Third-Party Analytics Tools or Services. We may use analytics tools or services provided by a third party analytics service provider or by using one of their tools, such as, but not limited to Google Analytics, to collect and process certain analytics data (“Third Party Analytics Tools or Services”). These Third Party Analytics Tools or Services may also collect data about your use of other websites, apps, and online resources.
Aggregated Form. We may make certain automatically-collected, aggregated, or otherwise de-identified Personal Information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Programs.
Advertising/Marketing Partners. We may work with third-party sales reporting companies, or third-party advertising or marketing companies (collectively, “Advertising Partners”) in order to provide you with advertisements, marketing, or other information that we think may interest you. These Advertising Partners may set or access their own cookies, pixel tags, or similar technologies on our Programs or they may otherwise collect or have access to data about you that they may collect over time and across different online services. These Advertising Partners may also provide us with their own independent data about potential customers and such data could include data about you previously collected by the Advertising Partner. These Advertising Partners may utilize artificial intelligence technology to provide information to you. Our Advertising Partners’ collection and use of Personal Information is not governed by this Privacy Policy.
Social Media Features. The Programs may, now or in the future, offer social media features, including certain sharing tools or other integrated tools (such as the Facebook “Like” button), which let you share actions that you take on our social media pages. Your use of such features enables the sharing of Personal Information with the public, depending on the settings you establish with the entity that provides the social sharing feature.
Merger, Sale, or Other Asset Transfers. We may share, disclose, or otherwise transfer your Personal Information to the Company’s Outside Professionals, other advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. If another company or individual acquires our business, or assets, that company or individual will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy. The use of your Personal information following any of these events will be governed by this Privacy Policy.
As Required By Law, Subpoena or Similar Government Order. We may access, preserve, share, or disclose your Personal Information if we believe doing so is required to: (i) comply with applicable laws or regulations, including any tax reporting requirements of the Company; (ii) comply with any other law enforcement requests or legal process, such as a court order or subpoena; (iii) respond to your requests; or (iv) protect your, our, or others’ rights, property, or safety.
Company’s Outside Professionals. We may share or disclose Your Personal Information with any of the Company’s Outside Professionals in order to facilitate the professional advice such Outside Professionals provide to the Company.
Contractors. We disclose Personal Information to entities that help us fulfill a business or commercial purpose including, but not limited to, shipping companies that deliver our products to you (“Contractors”). Contractors are not permitted to sell or share your
Personal Information or to use your Personal Information other than to perform the tasks we assign to them.
Consent. We may also share or disclose your Personal Information with your permission.

4. HOW LONG YOUR INFORMATION WILL BE KEPT.

We will keep your Personal Information for as long as is necessary: (i) to respond toquestions, complaints, or claims made by you or on your behalf; (ii) to keep recordsrequired by law; or (iii) to perform the business functions described in this PrivacyPolicy. Personal Information will not be kept longer than necessary for the purpose itwas collected.

5. YOUR RIGHTS UNDER STATE PRIVACY LAWS.

5.1. RIGHT TO ACCESS INFORMATION

Persons who reside in California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia (“Residents”) have the right to request that the Company disclose certain information about the Company’s collection and use of their Personal Information over the past 12 months. Once the Company receives and verifies your request (see Section 5.4), the Company will disclose to you:

The categories of Personal Information we collected about you over the past 12 months.
The sources for the Personal Information we collected about you.
Our business or commercial purpose for collecting or selling your Personal Information.
The categories of third parties with whom we shared that Personal Information.
The specific pieces of Personal Information we collected about you.
If we sold or disclosed Personal Information for a business purpose; two separate lists disclosing:

Sales (if any), identifying the Personal Information that each recipient purchased; and
Disclosures for a business purpose, identifying the categories of Personal

Information that each recipient obtained.

5.2. RIGHT TO DELETE INFORMATION

If you are a Resident, you have the right to request that the Company delete your Personal Information, subject to certain exceptions. Once the Company receives and verifies your request, and determines no exception applies, the Company will delete (and direct our service providers to delete) your Personal Information from our records. The Company may deny your deletion request if retaining the information is necessary for the Company or its service providers to:

Complete the transaction for which we collected the Personal Information, provide a good that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you;
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
Debug products to identify and repair errors that impair existing intended functionality;
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
Comply with a legal obligation; or
Make other internal or lawful uses of that information that are compatible with the context in which you provided it.

5.3 HOW TO EXERCISE RIGHTS

To exercise your rights under applicable state law, a Resident must submit a verifiable consumer request to the Company by either:

Calling the Company at 888- 847-8007; or
Emailing the Company at: policy@nulastin.com the consumer request must:

Provide sufficient information to allow the Company to verify that the person submitting the request is the person or the authorized representative of the person whose Personal Information is implicated by the request.
Describe the Resident’s request with sufficient detail to allow the Company to properly understand, evaluate, and respond to it. The Company cannot respond to a Resident’s request if the Company cannot verify the Resident’s identity or authority to make the request. Making a consumer request does not require a California Resident to create an account with us. The Company will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Only a Resident, or a person authorized to act on the Resident’s behalf, may make a consumer request to the Company related to the Resident’s Personal Information. A Resident may also make a consumer request on behalf of their minor child. A Resident may only make access their information twice within a 12-month period.

5.4. RESPONSE TIMING AND FORMAT

If a Resident sends a verifiable consumer request as set forth above, the Company will endeavor to respond to such verifiable consumer request within forty-five (45) days of its receipt. If the Company requires more time, the Company will inform the Resident of the reason and extension period in writing. We will deliver our written response by e- mail. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. Alternatively, the response will explain the reasons we cannot comply with a request.

For data portability requests, we will provide the Resident’s Personal Information in aform that is readily useable and should allow the Resident to transmit the informationfrom one entity to another entity without hindrance. We do not charge a fee to process or respond to a Resident’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the Resident why and provide the Resident with a cost estimate before completing the Resident’s request.

5.5. NON-DISCRIMINATION NOTICE

The Company will not discriminate against any Resident for exercising any of their rights under applicable state privacy law. Unless permitted by state law, if a Resident exercises any of their rights under applicable state privacy law, we will not:

Deny the Resident goods or services;
Charge the Resident different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide the Resident a different level or quality of goods or services; or
Suggest that the Resident may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. CANADIAN RESIDENTS.

If you are a resident of Canada, please see Appendix A for information regarding yourrights under Canadian law.

7. ADDITIONAL CHOICES ABOUT YOUR INFORMATION.

7.1. OPT-OUT FROM RECEIVING INFORMATION FROM THE COMPANY.

7.1.1 Opt-Out from Email Communications. If you provide the Company with PersonalInformation and, thereafter, do not want to continue to receive further notices orinformation from the Company, such as emails about the Company’s products orservices, you may unsubscribe using the link at the bottom of our emails or by sendingan email to policy@nulastin.comstating that you no longer want to receivecommunications directly from the Company (“Opt Out”). Once the Company hasreceived your request to Opt Out, the Company will use commercially reasonableefforts, in a commercially reasonable time period, to carry out your request; provided,however, the Company will not have any obligation to retrieve your PersonalInformation that has been shared with other parties as permitted by this Privacy Policy.

7.1.2. Effect of Email Opt-Out. If you elect to Opt Out, you will no longer receive emailsdirectly from the Company after a commercially reasonable time from the date you sent your Opt Out notice to the Company. However, the Company does not have anyobligations under, or liability arising out of, this Privacy Policy with regard to yourdecision to share your Personal Information with any other websites, forums, orprograms that may be linked to the Site. Accordingly, after sending your Opt Out to theCompany, you may need to contact these other entities directly regarding their use ofyour Personal Information.

7.1.3. Opt-Out of SMS Messages: If you do not wish to continue receiving SMSmessages from us, reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to anymobile message from us in order to opt out of the Program. You may receive anadditional mobile message confirming your decision to opt out. You understand andagree that the foregoing options are the only reasonable methods of opting out. Youacknowledge that our text message platform may not recognize and respond tounsubscribe requests that alter, change, or modify the STOP, END, CANCEL,UNSUBSCRIBE or QUIT keyword commands, such as the use of different spellings orthe addition of other words or phrases to the command, and agree that we will have noliability for not honoring such requests. You also understand and agree that any othermethod of opting out, including, but not limited to, texting words other than those setforth above or verbally requesting one of our employees to remove you from our list, isnot a reasonable means of opting out.

7.2. GEO-LOCATION DATA. You may be able to prevent your device from sharing precise location information, including without limitation some or all of your Geo-Location Data, at any time through your device’s operating system settings.

7.3. DO NOT TRACK. Some browsers have a “DO NOT TRACK” feature that lets website users inform websites or other applications that they do not want to have their online activities tracked. These “do not track” features may also give website users other choices regarding the collection of their personal identifiable information. However, these “do not track” features and “do not track’ signals are not yet uniform. ACCORDINGLY, EACH USER OF THE SITE OR ANY OTHER PROGRAM IS HEREBY NOTIFIED THAT THE SITE AND THE OTHER PROGRAMS ARE NOT CURRENTLY SET UP TO RESPOND TO ANY OF THE USER’S “DO NOT TRACK” FEATURES OR “DO NOT TRACK” SIGNALS.

7.4. CHILDREN; COPPA NOTICE. This Site and other Programs are not directed to children under the age of 13. We adhere to the Children's Online Privacy Protection Act ("COPPA") and will not knowingly register or otherwise collect any Personal Information from any child under the age of 13. We ask that minors under the age of 13 not submit any Personal Information to the Company. If you have reason to believe a child under the age of 13 has provided the Company with any Personal Information, please contact the Company at customercare@nulastin.com and request that such information be deleted from our records.

7.5. COOKIES POLICY; HOW YOU CAN DISABLE COOKIES.

7.5.1. What Are Cookies. The Site uses cookies, which are tiny files downloaded to yourcomputer, to improve your experience. This section describes what information theygather, how we use it and why we sometimes need to store these cookies. We will alsoshare how you can prevent these cookies from being stored, however, this maydowngrade or ‘break’ certain elements of a website’s functionality.

7.5.2. How We Use Cookies. We use cookies for a variety of reasons, as described inthis Privacy Policy. Unfortunately, in most cases there are no industry standard optionsfor disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not.

7.5.3. Disabling Cookies. You can prevent certain cookies from being downloaded byadjusting the settings on your browser or by electing your preferences in the windowthat appears when you visit the Site. Be aware that disabling cookies will affect thefunctionality of this and many other websites that you visit. Disabling cookies may alsodisable certain functions and features of the Site.

8. SWEEPSTAKES, CONTESTS & PROMOTIONS.

We may offer sweepstakes, contests, and other ?promotions (any, a “Promotion”)through the Site that may require registration. By ?participating in a Promotion, you areagreeing to the official rules that govern that Promotion which are separate from thisPrivacy Policy, and which ?may contain specific requirements of you, including, allowingthe sponsor of the Promotion to use ?your name, voice, and/or likeness in advertising or marketing associated with the Promotion. If ?you choose to enter a Promotion, certain Personal Information may be disclosed to third parties or the ?public in connection with the administration of such Promotion, including, in connection with ?winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official ?rules, such as on a winners list.

9. LINKS TO, AND USE OF, THIRD-PARTY SITES OR PROGRAMS.

The Site and Programs may now or in the future link to other websites, forums, orprograms that are not under the Company’s control and not owned by the Company(collectively referred to as “Third-Party Sites”). If you click on a link to, or otherwisegains access to, any such Third-Party Site, you will be transported to one of theseThird-Party Sites.

THIS PRIVACY POLICY ONLY APPLIES TO THE SITE AND THE PROGRAMSDIRECTLY OWNED BY THE COMPANY. THIS PRIVACY POLICY: (A) DOES NOTDESCRIBE THE PRIVACY POLICIES OF ANY OF THESE THIRD-PARTY SITES;AND (B) DOES NOT GOVERN THE COLLECTION OR USE OF YOUR PERSONALINFORMATION BY THE THIRD-PARTY SITES. THE COMPANY IS NOTRESPONSIBLE FOR THE PRIVACY PRACTICES OF ANY OF THESE THIRD-PARTY SITES. IF YOU CLICK ON A LINK TO, OR OTHERWISE GAIN ACCESS TO,A THIRD-PARTY SITE, YOU SHOULD REVIEW THE PRIVACY POLICIES OF SUCHTHIRD-PARTY SITES (IF ANY) TO DETERMINE THAT PARTICULAR THIRD-PARTYSITE’S PRACTICES WITH REGARD TO THE COLLECTION AND USE OFPERSONAL INFORMATION. WITHOUT LIMITING THE GENERALITY OF THE FOREGOING, YOU AGREE THAT IF YOU USE ANY THIRD-PARTY SITES IN ANY WAY, YOU ARE AWARE THAT PERSONAL INFORMATION THAT YOU PROVIDE TO THAT THIRD-PARTY SITE MIGHT BE READ, COLLECTED, SHARED, DISTRIBUTED, OR OTHERWISE USED BY OTHER USERS OF THAT THIRD-PARTY SITE OR BY ANY OTHER THIRD PARTIES, AND COULD BE USED TO SEND YOU UNSOLICITED MESSAGES. THECOMPANY IS NOT RESPONSIBLE FOR ANY PERSONAL INFORMATION THATYOU ELECT TO SUBMIT TO, OR OTHERWISE MAKE AVAILABLE TO, THESETHIRD-PARTY SITES. Any link to any Third-Party Site from the Site or Programs does not imply any endorsement of the privacy practices of such Third-Party Site by the Company, and no such Third-Party Site is authorized to make any representation or warranty on our behalf.

10. FINANCIAL INCENTIVE NOTICE.

These additional disclosures apply only to individuals who reside in California as required by the California Consumer Privacy Act (“CCPA”) and Colorado as required by the Colorado Privacy Act (“CPA”). We offer incentives to customers that opt in to our Loyalty Program. The Personal Information collected and retained by Nulastin, Inc. (“Nulastin”) in operating these programs is described in this Privacy Policy and includes your name and contact details, your date of birth information, your payment information, your contact history with us, your purchase and product feedback history, additional details about you, information about your device type and how you use our website, your public reviews and blog comments and inferences from data and other personal information we may collect in connection with your interaction with our service and/or participation in any of our promotional programs. We may share this information with our affiliates and subsidiaries, service providers, professional consultants, vendors necessary to complete transactions that you request, and as otherwise described herein. We do not sell or share your personal information with Data Brokers, as defined by the CPA.

Benefits provided through our promotional programs may be deemed a “financial incentive” (e.g., promotional goods) and/or “differential services” (e.g., discounts, coupons, other promotions) under the CCPA and CPA. We currently offer the following promotional programs in connection with the collection and retention of Personal Information:

Loyalty Program: We offer rewards to customers participating in our Loyalty Program, consistent with our Loyalty Program Terms and Conditions. Participants in the Loyalty Program receive promotional offers, including discounts, coupons and opportunities to participate in other promotional opportunities. You can subscribe to our Loyalty Program by logging into your existinghttps://nulastin.com/ account or, if you do not already have an account, registering for an account on https://nulastin.com/.

The benefits of the Loyalty Program are described on our NULASTIN Rewards Page. The categories of personal information collected through your participation in the Loyalty Program that may be shared for the purposes of targeted advertising include Personal Identifiers, Commercial Information, and Internet or Other Electronic Network Activity. If you choose to exercise your data privacy rights and request deletion of your personal information, your Nulastin account and any Loyalty Program benefits are deleted. We are only able to provide Loyalty Program benefits to Nulastin account holders.

Limited-Time Promotions: From time to time, we may offer incentives limited to a specific time period, or time limited sweepstakes, contests and other promotions. Limited-Time Promotions are limited to members of the Loyalty Program. Participation in a limited-time offer or promotion is governed by the applicable terms and conditions for the program, which will also describe any financial incentives associated with the promotion.

Discounts: We also from time to time offer discounts connected to customer’s submission of their email address, phone number or other personal information. You can always opt out of our marketing emails or SMS messaging at any time.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the financial incentive based on our costs.

11. ADDITIONAL NOTICE TO NEVADA RESIDENTS.

Under Nevada Revised Statutes Chapter 603A (the “Nevada Privacy Act”), Nevadaresidents who have purchased goods or services from us may notify us not to sell theircovered personal information. Covered personal information includes first and lastname, address, email address, phone numbers, and identifies that allow a specificperson to be contacted. If you are a Nevada resident, you may submit a request to usno to sell your covered information by emailing customercare@nulastin.com

12. DATA SECURITY.

To protect your Personal Information, we take reasonable precautions and followindustry best practices to make sure it is not lost, misused, accessed, disclosed, altered or destroyed. Your Personal Information is stored securely by Shopify, Recharge, Ordergroove, Yotpo, Klaviyo, and Postscript. If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored using AES-256 encryption. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express, and Discover. Although no method of transmission over the internet is 100% secure, we follow all PCI- DSS requirements and implement additional generally accepted industry standards.

13. CHANGES TO THIS PRIVACY POLICY.

We reserve the right to modify this Privacy Policy at any time, so please review itfrequently. Changes and clarifications will take effect immediately upon their posting on the Site.

14. CONTACT US.

If you have any questions relating to this Privacy Policy, please contact us atpolicy@nulastin.com or NULASTIN, customer care mailing address at 1200 PearlStreet, Suite 314, Boulder, CO 80302 U.S.A.

APPENDIX A

CANADA PRIVACY RIGHTS NOTICE.The person who is accountable for your organization’s privacy policies and practices isour Legal Advisor, who may be contacted by sending an e-mail to policy@nulastin.com;

You may access your personal information as provided under Canadian law or make acomplaint by sending an e-mail to policy@nulastin.com;

Our Privacy Policy explains our policies, standards or codes covering our collection and processing of personal information.

Our Privacy Policy describes what personal information we disclose to otherorganizations, including our affiliates and any third parties, and the purposes for suchdisclosures.

We do not sell personal information to third parties for monetary or other consideration.

Without your express consent, we will not (i) collect, use or disclose your sensitivepersonal information such as medical records, income records and information aboutsexual orientation, (ii) collect, use or disclose your personal information outside of yourreasonable expectations or (iii) collect, use or disclose your personal information in amanner that would create a meaningful residual risk of significant harm.