Privacy Statement

Last updated: May 13, 2020

At SANDOW, the privacy of your Personal Information is important to us. We are committed to providing you with an experience on all of our sites and services that is safe, secure and trustworthy.We work hard to be transparent about what Personal Information we collect and process, while striving to use clear and direct language to describe our privacy practices to help you make informed decisions.

For the purposes of the General Data Protection Regulation 2016/679 (the “GDPR”), SANDOW is the Data Controller, and is registered in New York at 101 Park Avenue, 4th Floor, New York, NY 10178.

If you are visiting us from the State of California or the European Union, we recommend you review Section 17 (Notice to California Residents) and Section 18 (European Data Subjects) for more information on the rights available to individuals located in California and the EU in particular.

Introduction

In order to personalize and improve your experience, SANDOW collects, processes and stores your Personal Information as you use our websites, mobile apps, social media pages and services and those of our brands that link to this Statement (collectively, the “SANDOW Properties”). “Personal Information” is information that can or is capable of identifying you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier, email or street address, or it may be information that could reasonably be linked back to you.

This Privacy Statement describes our practices for collecting, storing, processing and sharing your Personal Information and the controls we provide you to manage it within our Services.

By visiting and/or using any of the SANDOW Properties, you acknowledge the practices described in this Privacy Statement. If you have questions or concerns regarding this statement, you should contact SANDOW by e-mail at privacy@sandow.com.

1. What information does SANDOW collect from you?

The below describes the information we collect from you for our SANDOW Properties. In this Privacy Statement, we refer to this as your “Personal Information”.

 

Information Category Use Description
Account Information -Your name, title, business/company
-Email address and/or mailing address
-Password that you provide when you create an account
-Mobile or other phone number that you provide
-Demographic information
-Shipping or transactional information
Credit Card/Payment Information -Payment information such as your credit card number and your billing and shipping addresses when you purchase something from SANDOW Properties
Profile Information -We collect the information you provide when you voluntarily create a user profile
-Additional personal details that you provide in your profile (for example, image, name, age, location)
User Provided Content -Information you provide about yourself when you voluntarily contribute to SANDOW Properties, or participate in community discussions.
Social Media Information -If you use Facebook to log into the SANDOW Properties, we collect information from your Facebook profile that you choose to provide to us (for example, your Facebook profile information)
Additional User Information -Information that you provide to us when you answer email surveys or online questionnaires offered through SANDOW Properties (for example, user names, e-mail addresses and mailing addresses for select mailings from third parties, as well as opinions and preferences)
Contests and Promotions -Personal Information when you voluntarily participate in contests and special promotions we run through any of our SANDOW Properties
2. What information does SANDOW collect through your use of the Services?
Information Category Use Description
Computer and Mobile Device Information -Information about how you access any of our SANDOW Properties, including the website you visited before and after a SANDOW site
-The Internet Protocol (“IP”) address of your computer, mobile device, or proxy server you use to access the Internet, in addition to other information such as:

>Computer operating system
>Web browser
>Mobile device identifier provided by your mobile device operating system and your mobile operating system
>Name of your internet service provider or mobile carrier
Information from Cookies and similar technologies -Cookies and similar technologies as described in our Cookie Policy. Please refer to our Cookie Policy to learn about our practices and the controls we provide you
Information shared through social media features -If you interact with social media through SANDOW Properties such as our Facebook, Twitter, Pinterest, Instagram and LinkedIn pages, SANDOW will collect these interactions and whatever account information these sites make available to us
-Your interaction with these features are governed by the privacy statement of the applicable third-party company
Information from your use of the Services -Information about your use of any of our SANDOW Properties such as when you search, which pages you view or links you click on, or when you save/share content, etc.
3. Information we collect from other sources
Information Category Use Description
Information from third parties
-We may also receive information about you from third parties, such as supplemental data we collect with demographic information which are licensed from third parties to personalize any of our SANDOW Properties and our offers to you
-If you purchase a gift subscription, we will collect Personal Information to complete the gift and notify the recipient
4. How do we use your Personal Information?
Information Category Use Description
Personal Information (generally) -We use your Personal Information to provide, personalize, improve and expand any of our SANDOW Properties. This includes:

>Authenticate your access to SANDOW Properties
>Processing your payments for subscriptions, services and other products and features
>Building new and improving existing products and services
>Issuing surveys and questionnaires to collect Additional User Information for use in the Services, as well as facilitating product development and research initiatives, and publishing or otherwise disclosing aggregated or otherwise anonymized data
>Conducting scientific and statistical research
>Detecting and protecting against error, fraud or other criminal activity and enforcing our Terms and Conditions
Communications -We use our Personal Information to communicate with you about any of our SANDOW Properties such as when we:

>Respond to inquiries to any of our SANDOW Properties
>Inform you of product changes or new products and services
>Ask you to participate in SANDOW Properties media productions or testimonials
>Provide you with information or request action in response to technical, security, and other operational issues
Market new products and offers from us or our business partners -We may use your Personal Information to market new products and offers from us or, where permitted by applicable laws, our partners. This includes advertising personalized to you based on your interests either on SANDOW Properties sites or through remarketing services so that third-party websites can serve interest-based ads targeting a user after they leave a SANDOW website or emails sent to you about new products and offers from us or our partners.  To opt-out of email communications, follow the “un-subscribe” links included at the bottom of email communications or send an email to optout@sandow.com.
5. When do we share your information and who receives it?
Circumstances when sharing may occur Description
Service Providers -We use other companies to help us provide some products/services to you for any of our SANDOW Properties. As a result, these partners will have some of your information in their systems. Our partners are subject to contractual obligations governing data security and confidentiality as well as applicable laws. However, we will only share such personally identifiable information as we deem necessary for our service providers to carry out their obligations to or on behalf of SANDOW Properties
-These service providers may include:

>Independent contractors
>Payment processors
>Cloud services infrastructure providers
>Vendors for marketing, advertising, data, distribution analytics, scheduling and fraud prevention
Legal or regulatory process -We may share your Personal Information if we believe it is necessary to:

>Comply with valid legal process
>Enforce or apply SANDOW Terms and Conditions
>Protect the security or integrity of our SANDOW Properties
>Protect the rights, property or safety of SANDOW, our employees or users.

Note: If we are compelled to disclose your Personal Information to law enforcement, we will do our best to provide you with advance notice, unless we are prohibited under law from doing so.

If SANDOW is acquired -If SANDOW or any of its businesses or business lines are acquired or transferred, we will share your Personal Information with the acquiring or receiving entity. The promises of this Privacy Statement will continue to apply to your Personal Information that is transferred to the new entity.
Aggregated data -SANDOW Properties may disclose user information in an anonymized and aggregated form as part of the Services or our marketing. We will also share demographic information with independent contractors, service providers, consultants, advertisers and other partners for purposes of research, business initiatives, collaborations, and more. Such disclosures will never include Personal Information.
6. Your choices and access to your Personal Information.

Rights that you may have by law, depending on the country in which you live, include (subject to certain exceptions): a right to request access to your Personal Information and to be provided with a copy of certain information you provided in a portable form, as well as to seek to update or correct this information, or to have us delete this information. Details and options for accessing this information are listed below.

We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. To submit any requests, or if you have questions or concerns, you should contact SANDOW Properties at privacy@sandow.com.

For more information on the rights available to individuals located in California and in the EU in particular, please see Section 17 (Notice to California Residents) and Section 18 (European Data Subjects).

7. What are SANDOW’s retention practices?
Category of Information Retention Period
Account Information -SANDOW Properties will retain the Personal Information you provide while creating your account until such time as you ask us to close it.
Credit Card/Payment Information -SANDOW Properties may retain Personal Information in connection with previous transactions or activity on the SANDOW Properties in a form which permits us to identify you for no longer than is necessary for the purposes for which the Personal Information is processed.
Usage Information -In some cases we choose to retain usage information (for example, visits to sites) in a depersonalized or aggregated form. Once aggregated, this information ceases to be personal and will not be subject to user deletion requests.
 

Following retention, we will use appropriate measures to delete or anonymize your personal data.  To the extent that we hold hard copies of your personal data, such records, print-outs or hard copy documents etc. will be permanently destroyed

8. How can I delete my Personal Information?
Information Category How to Delete
Personal Information If you require assistance deleting Personal Information you provided as part of your profile or subscription, please submit a deletion request (including the exact wording of the information as it appears on the websites, and the URL where the information is found) to our Privacy Statement Team by emailing privacy@sandow.com.

SANDOW Properties may also retain certain information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.

Credit Card/Payment Information SANDOW Properties may retain Personal Information in connection with previous transactions or activity on the SANDOW Properties unless applicable laws require deletion.
Usage Information -In some cases we choose to retain usage information (for example, visits to sites) in a depersonalized or aggregated form. Once aggregated, this information ceases to be personal and will not be subject to user deletion requests.
9. Security

SANDOW Properties have implemented technical, administrative and physical security measures that are designed to protect User information from unauthorized access, disclosure, use and modification. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable.

SANDOW Properties regularly review our security and privacy practices and enhance them as necessary to help ensure the integrity of our systems and your Personal Information. We only partner with security companies that meet and commit to our security standards. While we cannot guarantee that loss, misuse or alteration of data will not occur, we use reasonable efforts to prevent this.

It is also important for you to guard against unauthorized access to your Personal Information by maintaining strong passwords and protecting against the unauthorized use of your own computer or device.

10. Data Transfer

SANDOW operates globally so it may be necessary from time to time to transfer your information internationally. In particular, a User’s information will likely be transferred to and processed in the United States where many of our central databases operate. The data protection and related laws of other countries, such as the United States, may not be as comprehensive as those in your country. Please be assured that we take reasonable steps to ensure that your privacy is protected. By using the SANDOW Properties, you acknowledge that your information will be collected, used and transferred as set forth in this Privacy Statement.

Where required by applicable laws, we will take appropriate measures to ensure adequate protection of your Personal Information when transferred internationally and, if necessary, seek your prior consent.  Such measures may include use of data transfer agreements and / or official transfer mechanisms such as data authority approved contractual clauses. For instance, if you are located in the European Economic Area (“EEA”), we may store your Personal Information as described in this policy outside the EEA.  Where we transfer EEA personal data to a third party located in a country not recognized by the European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the EU Commission, to safeguard such Personal Information.  For further information, please contact us at privacy@sandow.com.

Lastly, to the extent SANDOW is permitted to do so in accordance with applicable laws and regulations, we reserve the right to rent, sell or otherwise commercialize our Users’ data and registration information.

11. Changes to this Privacy Statement

SANDOW reserves the right to make changes to the Privacy Statement at any time. If we plan to make material changes to any of our privacy policies or practices with respect to how we use Personal Information, we will provide prominent advance notice of any material changes to this Statement, such as posting a notice through any of our SANDOW Properties, or sending you an email, before they take effect so our Users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Please review our Privacy Statement periodically to see recent changes.

Your continued use of any of our SANDOW Properties after notice of changes means that you acknowledge the updated Privacy Statement.

12. Privacy and Security Concerns

If you have any questions about this Privacy Statement, the practices or your dealings with any SANDOW Properties, or if you wish to receive a printed version of this Privacy Statement, please contact us:

SANDOW
101 Park Avenue, 4th Floor
New York, NY 10178
Attn: Privacy Statement Team
Email: privacy@sandow.com

13. Linking

SANDOW may offer links to other websites. Please be aware that SANDOW is not responsible for the privacy practices of such linked sites, including sites of our partners. We encourage our Users to be aware of this when they leave any of the SANDOW Properties and to read the privacy statements of each and every website that collects personally identifiable information.

14. Children

None of the SANDOW Properties are directed at children, and SANDOW does not sell products or services for purchase by children. We may, however, sell children’s products for purchase by adults. If you are under the age of 18, you may use the SANDOW Properties only with the involvement and authorization of a parent or guardian. Parents, please monitor your children’s use of the Internet.

15. Choice/Opt Out

SANDOW gives Users the ability to opt-out of receiving future communications. To opt-out of email communications, follow the “un-subscribe” links included at the bottom of email communications or send an email to optout@sandow.com.

Please be aware that when you opt-out of receiving certain communications, it may affect the services you have chosen to receive from Sandow where accepting the communications is necessary for Sandow to provide the services to you.

16. Use of “Do Not Track Signals”

In order to provide you with an optimal, personalized experience, SANDOW does not respond to pre-set web browser requests signalling a User’s request not to be tracked on the website. Users may follow the opt-out instructions provided herein if they wish not to be tracked, however, SANDOW may not be able to provide the same services and offerings within the SANDOW Properties without tracking.

17. Notice to California Residents

California Consumer Privacy Act Rights

The California Consumer Privacy Act of 2018 (“CCPA”) provides “consumers” (California residents) with specific rights regarding their Personal Information.  This section describes your CCPA rights and explains how to exercise those rights.

During the past twelve (12) months, we have collected the following categories of Personal Information from the listed sources, used it for the listed business purposes and shared it with the listed categories of third parties.  Not all information is collected about all individuals. 

Category of information collected Source Business purposes* for use Categories of third parties receiving information
Identifiers (Account Information including name, title, business/company, email address, mailing address, password, mobile or other phone number and demographic data; Profile Information; User Provided Content; Social Media Information; and Contest and Promotions information) Individuals submitting information to us.

Information we may receive from third-party marketing
and data partners.

Performing services for you.

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Sensitive information

(Credit Card/Payment Information)

Individuals submitting information to us.

Information we may receive from third-party marketing
and data partners.

Performing services for you.

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Commercial information (Additional User Information; and shipping or transactional information, transaction history, products/services purchased, obtained or considered and product preferences) Individuals submitting information to us.

Information we automatically collect from website visitors.

 

 

Performing services for you.

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Professional or employment-related information Individuals submitting information to us.

Information we may receive from third-party marketing and data partners.

Performing services for you.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

 

 

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Internet or other electronic network activity (Computer and Mobile Device Information; Information from cookies and similar technologies;Information shared through social media features; andInformation from your use of the Services) Information we automatically collect from website visitors.

 

 

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

Geolocation Information we automatically collect from website visitors.

 

 

Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

Inferences from the above (preferences, characteristics, behaviour, attitudes and abilities, etc.) Internal analytics Advertising customization.

Auditing relating to transactions.

Internal research and development.

Security detection, protection and enforcement.

Functionality debugging, error and repair.

Quality control.

Service providers (such as those listed in Section 5).

Affiliated companies.

Government regulators.

Law enforcement.

Strategically aligned businesses.

 

*The business purposes also include those listed throughout this Privacy Statement.

 

Sale of Personal Information

In the preceding twelve (12) months, SANDOW may have sold the following categories of Personal Information:

  • Identifiers;
  • Sensitive information;
  • Commercial information;
  • Professional or employment-related information;
  • Internet or other electronic network activity;
  • Geolocation; and
  • Inferences from the above.

Your rights and choices

As of January 1, 2020, if you are a verified California resident, you have the right to obtain certain information about our collection and use of Personal Information over the past twelve (12) months, including:

  • The categories of Personal Information we collect;
  • The categories of sources of Personal Information we collect;
  • Our business purpose for collecting or sharing that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The specific Personal Information we have collected about you over the past twelve (12) months;
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • the categories of Personal Information sold and the category of third party recipients; and
  • list of the categories of Personal Information that we disclosed for a business purpose.

You have the right to request that we do not sell Personal Information about you, and to request that we delete (and direct our service providers to delete) your Personal Information subject to certain exceptions. 

Personal information sales opt-out and opt-in rights

If you are sixteen (16) years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of individuals we actually know are less than eighteen (18) years of age.  To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by e-mail at privacy@sandow.com

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.

Exercising your rights

You can exercise any of these rights by contacting us using the contact details set out above or you may submit a request to us by e-mail at privacy@sandow.com.  You may make a request up to twice within a twelve (12) month period. 

We will ask you for information that allows us to reasonably verify your identity (that you are the person about whom we collected Personal Information) and we will use that information only for that purpose. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm that the Personal Information relates to you.

Response timing and format

We will endeavour to respond within forty-five days of receipt of your request, but if we require more time (up to an additional forty-five days) we will notify you of the reason and extension period in writing.

Where you request a copy of your Personal Information, we will endeavour to provide the information in a format that is readily useable, including by mailing you a paper copy or providing an electronic copy.  Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of you verified request.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We will not discriminate against you as a result of your exercise of any of these rights. 

18. European Data Subjects

This section shall apply to any personal data collected by SANDOW Properties from EU residents to whom the GDPR applies.

Where you have consented to data processing, your consent provides the legal basis to process your Personal Information. This may include where you have given your consent to receive marketing communications from SANDOW, our affiliates and/or our partners.  You have the right to withdraw consent at any time. Please note that your withdrawal of consent to collect and process your Personal Information will not affect the lawfulness of processing your Personal Information based on your consent before you withdrew your consent.

We may also process your Personal Information on the basis of contractual necessity to perform a contract we have with you. This includes:

  • When we process your credit card details when you provide them in order to use our Services or to buy our Services as a gift for a third party; and
  • Processing your payments for subscriptions, services and other products and features.

We may also process your Personal Information on the basis of our legitimate interests, including in providing and improving the Services. This includes:

  • To authenticate your access to SANDOW Properties;
  • Understanding your login history so we can assess your interaction with our Services;
  • Providing and developing interesting features to provide to our users;
  • Keeping our Services safe and secure by detecting and protecting against error, fraud or other criminal activity and enforcing our Terms and Conditions, and we do so as it necessary to pursue your and our legitimate interests in ensuring that our Services are secure, and to protect against fraud, spam and abuse;
  • Conducting product development and research initiatives;
  • Conducting scientific and statistical research;
  • To communicate with you about any of our SANDOW Properties such as when we respond to inquiries to any of our SANDOW Properties, to inform you of product changes or new products and services, to ask you to participate in SANDOW Properties media productions or testimonials, to provide you with information or request action in response to technical, security, and other operational issues;
  • To allow you to participate in contests and surveys and benefit from personalized promotional offers; and
  • To keep you up-to-date on the latest product announcements, updates, special offers, and other information we think you would like to hear about.

Where we rely on legitimate interests to process your Personal Information, you have the right to object to such processing (meaning that you can ask us to stop). You can use the links referenced above regarding your account at SANDOW Properties, or follow our Cookie Policy, to control certain ways in which we process your data. You can also contact us to object to other forms of processing.

We may also process your Personal Information in order to protect your vital interests or the vital interests of another person.

European Data Subject Rights

Under European data protection law, in certain circumstances, you have the following rights:

  • Request access to your Personal Information. You may have the right to request confirmation from us as to whether we process your Personal Information and to request access to any Personal Information we hold about you as well as related data, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making.
  • Request correction of your Personal Information. You may have the right to obtain without undue delay the correction of any inaccurate Personal Information we hold about you.
  • Request erasure of your Personal Information. You may have the right to request that Personal Information held about you is deleted.
  • Request restriction of processing your Personal Information. You may have the right to prevent or restrict processing of your Personal Information. 
  • Request transfer of your Personal Information. You may have the right to request transfer of your Personal Information directly to a third party where this is technically feasible.
  • Right to object. You may have the right to object to the processing of your Personal Information when you have legitimate reasons to do so.
  • Right to withdraw consent. Where processing is based on consent, you may have the right to withdraw such consent.  In some cases, if you withdraw your consent to use of your Personal Information, we may not be in a position to continue to provide our Services or products to you.

In addition, where you believe that we have not complied with our obligations under this Privacy Statement or European law, you have the right to make a complaint to your local Supervisory Authority such as the Information Commissioner’s Office (“ICO”), the UK Supervisory Authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach a Supervisory Authority so please contact us in the first instance.

You can exercise any of these rights by contacting us at privacy@sandow.com.  We reserve the right to request the provision of additional information necessary to confirm the identity of the enquirer