If you have any questions about our Privacy Policy, you can contact us at [email protected] and include ‘Privacy Policy’ in the subject line. 

1. Privacy Policy Overview

HotPause Health, Inc., with its affiliates (collectively, “HotPause Health”, “us”, “our” or “we”), owns, operates, and provides access to an interactive health & wellness website (hotpausehealth.com), mobile and connected application, and other online interactive features and services, including, but not limited to, emails, newsletters, chat areas, forums, communities, sweepstakes and contests for consumers (collectively, the “Services”). This Privacy Policy applies to all information collected about you when you interact with the Services, regardless of how it is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Contact details are provided in Section 16 below. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of your information, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make.

This Privacy Policy covers information collected through the website HotPauseHealth.com and its related application, which are operated by HotPause Health. If you do not agree with our policies and practices, your choice is not to use our website or Services. 

Children. The Services are not intended for use by children under 18 years of age(or applicable age in your country) (“Minor(s)”). Minors should not provide any Personal Information or use our public discussion areas, forums or chats. Minors under the age of 18 are not permitted to make purchases through the Services or obtain coupons or codes from the Services to purchase goods or services on third party websites. If, notwithstanding these prohibitions, your children disclose information about themselves in our public discussion areas, consequences may occur that are not intended for children (for example, they may receive unsolicited messages from other parties). If it is discovered that we have collected Personal Information from a Minor, we will delete that information immediately.

2. What Categories of Information We May Process

“Personal Information” means information that is about any individual, or from which any individual is directly or indirectly identifiable. “Process”, “Processing” or “Processed” means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We may Process the following categories of Personal Information about you:

• Personal details: your name; username or login details; password; areas or topics of interest; information provided in response to quizzes or surveys or to use certain health-related programs, such as supporting a healthy perimenopause stage; and photograph (if you or another user posts a photo on the Service).
• Demographic information: gender; age/date of birth; nationality; salutation; job title, company information, education, work experience and other professional information; and language preferences.
• Contact details: postal address; telephone and/or mobile number; email address; and your public social media handles or profile(s).
• Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Purchase and payment details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or account holder name; payment amount; and payment date.
• Views and opinions: any views and opinions that you or other users choose to send to us, or publicly post about us on social media platforms or in the Services, including on forums.

We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:

• Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
• Searches for and interactions with e-commerce opportunities, such as merchants and offers contained in the Services.
• Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
• Device identification (“ID”), which is a distinctive number associated with a smartphone or similar handheld device, but is different than a hardware serial number.
• Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
• Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies about (i) your visits to, and interaction and engagement with, the Services, and (ii) your interaction with marketing emails from us including the content and ads therein (collectively, “Online Data”).
• Device type, settings and software used.
• Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
• Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
• Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
• Local Shared Objects and Local Storage, such as HTML5.
• Mobile analytics to understand the functionality of our mobile applications and software on your phone.

Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.

To the extent that information we collect is health data or another special category of sensitive personal information subject to GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you sign up for a newsletter on our site or agree to our Privacy Policy. You can withdraw your consent at any time by unsubscribing from our newsletters as set out in Section 5 or contacting us as provided in Section 16.

3. How We Collect or Create Information

We may collect User Information about you from the following sources:

• Data you provide: We may obtain your Personal Information when you provide it to us across our Services (e.g., where you sign up for emails, newsletters or SMS messages; register for site membership or create a profile or account on any part of the Services; enter a sweepstakes, contest, competition or prize draw; participate in surveys and quizzes; perform search queries through the Services; contact us via email, telephone or by any other means; make a purchase; etc.).
• Relationship data: We may collect or obtain your Personal Information in the ordinary course of our relationship with you (e.g., if you purchase a service from us).
• Data you make public: We may collect or obtain your Personal Information that you clearly choose to make public, including via social media (e.g., we may collect information from your social media profile(s) if you make a public post about us) or through our chats, forums or communities on the Services.
• Service data: We may collect or obtain your Personal Information when you visit, download, use or register to use any part of our Service.
• Content and advertising information: If you choose to interact with any third party content or advertising on the Services, we may receive User Information about you from the relevant third party.
• Third party information: We may collect or obtain your Personal Information from third parties who provide it to us. This may include offline channels such as through telephone or direct mail efforts; from customers, vendors, suppliers, third parties, commercially available or publicly-available sources (e.g., data brokers, data aggregators, public databases, etc.); third party affiliate network operators; referral sources; and social network sites or services (e.g., Facebook, X/Twitter, LinkedIn, etc.). If you use a third party connection or log-in (e.g., Facebook or X/Twitter) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to another person, platform or service, we may also receive your username or email address for those third party services or other information available about you or collected from you on those services.

Please note that HotPause Health is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services, such as forums, blogs, wikis, chat rooms, private messages, message boards or other publicly accessible interaction, or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us at [email protected]. 

This Privacy Policy does not cover the practices of third parties, including those that may disclose information to HotPause Health.

We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also use User Information you have provided to us with data obtained from third parties to enhance our records or enhance our ability to provide products and services, such as appending additional information to your profile.

4. Purposes for Which We May Process Your Information

The purposes for which we may Process User Information, subject to applicable law, include:

• Provision of the Services to You: providing the Services to you from HotPause Health or its partners including (i) offering chat areas, forums and communities, (ii) management of your account, and (iii) customer support and relationship management.
• Offering and Improving the Services: operating and managing the Services for you; providing personalized content to you; communicating and interacting with you via the Services; identifying issues with the Services and planning improvements to or creating new Services; and notifying you of changes to any of our Services.
• Identification: using information from third parties to verify information about you in order to provide the Services (e.g. verify your mailing address to send you requested products or services.)
• Surveys and Quizzes: engaging with you for the purposes of obtaining your views on our Services, as well as learning more about your interests, including your interest in third parties and their offerings.
• Research: analyzing, benchmarking, and conducting research based on User Information and your interactions with the Services. 
• Communications: communicating with you via any means (including via email, telephone, text message, social media, post or in person) regarding content and other information in which you may be interested, subject to ensuring that such communications are provided to you with your consent and in compliance with applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required. We may provide direct marketing to you as set out in Section 5 below.
• Advertising: providing advertising based on your interests and interactions with the Services, including using User Information to serve you advertisements on the Services. 
• Audience Engagement: identification and development of audience engagement, advertising and promotional strategies.
• User Engagement and Purchases: tracking purchase traffic and activity across the Service.
• Marketing to Customers: We may market to current and prospective customers who have indicated an interest in doing business with, or have previously conducted business with, HotPause Health in order to further generate and promote our business. Such efforts include sending marketing emails to drive the purchase of advertising, marketing our lead generation, job boards, and other business services offered by HotPause Health.
• IT Administration: administration of HotPause Health’s information technology systems; network and device administration; network and device security; implementing data security and information systems policies; compliance audits in relation to internal policies; identification and mitigation of fraudulent activity; and compliance with legal requirements.
• Security: electronic security measures (including monitoring of login records and access details) to help mitigate the risk of and provide the ability to identify and rectify a security incident.
• Financial Management: general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate audit; and compliance with legal requirements
• Investigations and Legal Compliance: detecting, investigating and preventing breaches of our Terms of Use or other policies or guidelines and applicable law. For further information regarding our disclosure of User Information to respond to legal requests and to prevent or address emergencies, harm, threatened harm, violence, or abuse, see Section 8 below.
• Legal Proceedings: establishing, exercising and defending legal rights.

5. Direct Marketing

We may Process your User Information to contact you via email, direct mail, or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.

6. Cookies and Similar Technologies

Tracking technologies on the Services may be deployed by HotPause Health and/or by our service providers. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for analytics purposes and administering and improving the Services.

HotPause Health and/or our service providers and partners (including but not limited to e-commerce partners, affiliates, and analytics providers) may use cookies and technologies such as pixel tags, e-tags, IP addresses, Local Shared Objects, Local Storage, and HTML5 to analyze trends; administer the Services; collect and store information such as user settings, anonymous browser identifiers; supplement our server logs and other methods of traffic and response measurement; track users’ location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services, visitor behavior, and responses to promotional campaigns. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on the Services. Various browsers may offer their own management tools for removing Local Storage. 

When you receive email messages or newsletters from us, we may use web beacons, customized links, clear GIFs or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information, and/or to aggregate that information with other data we collect to use for some or all of the purposes outlined in this Privacy Policy.

We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.

Online Data is aggregated with the Other Information and data we collect as described in this Privacy Policy to create groups of users and certain general-interest categories or segments that we have inferred based on (a) demographic or interest data and GeoIP Data, and (b) the pages you view and links you click when using the Services. We use this information to get a more accurate picture of audience interests in order to provide and improve the Services.

7. What is the Lawful Basis for Processing Personal Information

In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:

• Consent: We may Process your User Information where we have obtained your prior, express consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
• Contractual necessity: We may Process your User Information where the Processing is necessary in connection with any contract that you may enter into with us;
• Compliance with applicable law: We may Process your User Information where the Processing is required by applicable law;
• Vital interests: We may Process your User Information where the Processing is necessary to protect the vital interests of any individual; or
• Legitimate interests: We may Process your User Information where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

8. What Information We Disclose to Third Parties

We do not sell Personal Information nor share Personal Information for the purposes of behavioral advertising purposes, and have not sold or shared Personal Information for this purpose in the preceding twelve months.

We may disclose your User Information to legal and regulatory authorities (including law enforcement agencies and courts) to respond to legal requests or orders, comply with applicable law, or exercise or defend our legal rights. We are mindful of your legal rights and may act to protect them. We may object to legal requests or orders that are overbroad, infringe your or our protected rights, or otherwise exceed legal authority. We may also disclose your User Information to prevent or address emergencies, harm, threatened harm, violence, or abuse. For example, we may disclose user information to report apparent ongoing or imminent child abuse or an imminent threat of suicide or self-harm.

In addition, we may disclose your User Information to:

• outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
• third party Processors (such as analytic providers; data centers; etc.), located anywhere in the world, subject to the requirements noted below in this Section 8;
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
• any sponsors of contests, competitions, sweepstakes and prize draws, or content offerings, the registration data for such events is to be used by us as part of User Information, and may be shared with the sponsor and others, subject to this Policy and the sponsor’s privacy policy. We may also share your information with third party vendors involved in the administration of such events. For contests, competitions, sweepstakes and prize draws, please read the official rules or terms and conditions carefully before you submit your information; and
• to third parties whose practices are not covered by this Privacy Policy (e.g., third party providers of goods and services, marketing and advertising companies and agencies, content publishers and retailers). 

With respect to surveys and quizzes, in the event that responses are publicly disclosed, users will be notified at the time they take the survey or quiz. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys or quizzes to other participants in the survey. Where surveys or quizzes allow users to submit written comments, and where HotPause Health advises users of the possibility of such disclosure at the time they take the survey or quiz, HotPause Health reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.

HotPause Health and some of our advertisers may use third party advertising service companies to serve advertisements and perform related services when you interact with the Services. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.

We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, including but not limited to monitoring fraud around the web.

If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.

The Services contain links to other sites or partners whose information practices may be different from ours. You should consult the privacy policy of these third parties to learn how your privacy is protected.

9. Data Security

We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.

10. Data Accuracy

We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.

11. Data Minimization

We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.

12. Data Retention

We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.

13. Your Rights With Respect to Your Personal Information

Many privacy regulations afford consumers with additional rights regarding the use of Personal Information. Under the laws of several U.S. States, including California (CCPA), Colorado (CPA), Connecticut (CTDPA), Oregon (OCPA), Utah (UCPA), and Virginia (VCDPA), or another jurisdiction with similar privacy requirements (now or in the future), you have certain rights which may include those listed below. 

Your rights: 

• Right to Withdraw Consent: Where you are requested to consent to the processing of your personal information, you have the right to withdraw your consent at any time.
• Right to Know: You have a right to know what personal information we collect, process, and share. This policy is meant to provide transparency with regard to your data. If you have additional questions, you can email us at [email protected].  
• Right of Access: You can request a copy of the personal information we have collected about you from us. 
• Right to Delete/Erase: You can request us to delete all the information we have collected about you. It is important to note that by exercising your right to deletion you may lose access to your account and any purchases or features associated with it. If you wish to cancel your account or request that we no longer use some or all of your information to provide you services, you can email us at [email protected]. 
• Right to Request Correction: If you find that any of your information that we are processing is inaccurate, you can contact us to have your information corrected. In response, we will cancel or remove your information but may retain and use copies of your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For certain requests, we may require additional information.
• Right to Object to the Processing: You can object to our processing of your personal information by emailing us at [email protected]. By objecting to processing, you may not be able to access some or all of our services. This right is limited to personal data processed for commercial purposes. 
• Right to Object to the Use of Sensitive Personal Information: You have the right to object to our use of your sensitive personal information. Sensitive personal information is information about your health, race, religion, sexual orientation, gender identity, political opinions or philosophical beliefs. You should always be mindful about the personal information you share online, especially when it is sensitive in nature. 
• Right to Object to Automated Processing: You have a right to object to the processing of your data for the purposes of automated decision making about you. 
• Right to not be Discriminated Against: You have a right to not be discriminated against for exercising your rights.
• Right to Complain (EU, UK): Should you wish to raise a complaint about the collection or use of your information, you have the right to do so without prejudice to any other rights you may have. You may lodge a complaint with your local data protection authority.
• Right to an Authorized Agent (CA): If you would like to make a request on behalf of a California consumer who is a current or former customer, please provide an email from the email address we have on file for the customer authorizing the request. You may also make a request under the California Consumer Privacy Act on behalf of a California consumer if you provide (1) a signed, written permission from the consumer to act on your behalf, and the consumer verifies their own identity directly with us; or (2) proof that the consumer has provided you with power of attorney pursuant to Probate Code sections 4000 to 4465. We may deny a request from an agent that does not submit proof that they have been authorized by the consumer to act on their behalf.

In order to make privacy requests please email us at [email protected]. 

You may be required to verify your identity before we can give effect to these rights. If you are making a request on behalf of a user, we require a signed authorization letter from the consumer.

14. What Can I Do to Control My Information?

You may directly take steps to change your preferences as follows:

Access to Your Personal Information. Upon request HotPause Health will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or emailing us at [email protected], regardless of your citizenship or location. We will respond to your request within a reasonable timeframe.

Your Newsletter and Email Subscriptions. You can opt out or unsubscribe from a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some Services, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.

Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.

California Residents. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers’ “do not track” signals. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out in Section 16 below.

EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us at [email protected]. If you are an EU resident and have any unresolved privacy concern, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.

15. Terms of Use

For more information concerning your use of the HotPause Health website and application, please consult the Terms of Use, which is incorporated by reference into this Privacy Policy. We recommend that you review the Terms of Use regularly, in order to review any changes we might make from time to time.

16. Contact Details

If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact us at [email protected].

17. How this Privacy Policy May Change

We may change this Privacy Policy from time to time, and all changes will be effective at the time we post them. If we believe there is a significant change to this Privacy Policy or our data collection and use practices, we will indicate on our websites that our Privacy Policy has changed prior to the change becoming effective and/or notify you by email to the email address specified in your account. The then-posted version of the Privacy Policy supersedes all prior versions. Your continued access to or use of any of the Services shall be deemed your acceptance of the Privacy Policy.