Privacy Policy

PRIVACY POLICY

Last Updated: September 17, 2021

This privacy policy (“Privacy Policy”) describes how Dr. Ambra Brown (“Company,” “we,” ,"I" “us,” and “our”) collects, uses and shares personal information when using each of the following websites https://www.drambrabrown.com (the “Site”) or our products and services (together, the “Services”). Please also read the Terms of Service which sets out the terms governing the Services along with any other additional agreements, terms, guidelines or policies provided to or entered into by you that are applicable to your use of our Services.

Your privacy is very important to us. Our Privacy Policy explains the information we collect, how we use and share it, how to manage your privacy settings and your rights in connection with the Services.

We are based in the United States and our Services are provided to you by us. If you are a resident of the European Economic Area (“EEA”), the Company is the controller of your personal information for the purposes of EEA data protection law.

We will post any modifications or changes to the Privacy Policy on our Site. We reserve the right to modify the PRIVACY Policy at any time, so we encourage you to review it frequently. The “Last Updated” date indicates when this Policy was last changed. If we make any material changes to the Policy, we will post a notice on our Site.

Questions or comments about this Privacy Policy may be submitted by email to

[email protected]

Children Under the Age of 18.

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18 DO NOT provide any information on this Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18, without verification of parental consent, we will immediately delete that information. If you believe we might have any information from or about a child under 18, please contact us through this website.

What is personal information?

We collect information about you in a range of forms, including any information which, either alone or in combination with other information we hold about you, identifies you as an individual, including, for example, your name, postal address, email address, telephone number, user name, password, demographic information and billing and payment information.

Why we need your personal information?

We need certain personal information in order to provide you with access to our Service. In order to access some of our Services, such as purchase or participation in one of our products or services, you will need to agree to provide us this information. By providing us this information you are consenting to our use of your information and this consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal information pursuant to this Privacy Policy, please do not use our Services.

How we use your personal information

We may use your personal information as follows:

to operate, maintain, and improve our Services and develop future products, and services;

to manage your account, including to communicate with you regarding your account, if you have a Services account;

to operate and administer and allow you to participate in giveaways, freebies, or other promotions;

to respond to your comments and questions and to provide to you support services;

to send information including technical notices, updates, security alerts, support and administrative messages and legal information and disclosure;

to send you marketing e-mails and other communications about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such email at any time by emailing us. Please note, even if you opt out of receiving marketing communications, we may still send you non-marketing communications, including emails about the status of your Service and our business dealings with you;

to provide you with coaching and support to help you achieve your goals relevant to our programs and services;

to process payments you make in connection to our Services and collect payments owed to us;

to link or combine user information with other personal data;

recognize you and analyze how you, and other users, navigate our Services;

analyze comments and feedback you have given us including comments, feedback and reviews you have posted on or through our Services;

fulfill orders for products or services placed through our Services.

verify or obtain payments due to us when you purchase a product or service from a third party after clicking on an “affiliate” link in or through our Services or communications we

provide you, measure the performance of affiliate links, analyze and develop this part of our business

ask you to take part in or conduct a survey or undertake research about our Service or products and services in development;

administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention;

serve content and other materials and analyze their performance and effectiveness;

to improve and develop our data analytics, products and services and inform our marketing strategy;

as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Privacy Policy, Terms of Use and other Company policies and guidelines; and (d) to protect our rights, privacy, safety or property, and that of you or others; and

as described in the “Sharing of your personal information” section below.

Sharing of your personal information

We may share your personal information as follows:

Third Parties Designated by You. We may share your personal information with third parties where you have provided your consent to do so.

Our Third-Party Service Providers. We may share your personal information with our third-party service providers who provide services such as data analysis, payment processing, information technology and related infrastructure provision, customer service, email and other communication delivery, auditing and other similar services.

Third Party Advertisers. We may share personal information with advertisers and advertising networks that require the data to select and serve relevant advertisements to you and others.

Affiliates. We may share some or all of your personal information with our affiliates, in which case we will require our affiliates to comply with this Privacy Policy.

Other Disclosures. We may share personal information as we believe necessary or appropriate: (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet law enforcement requirements; (c) to enforce our Privacy Policy, Terms of Use and other Company policies, terms, agreements and guidelines; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

How we collect your personal information

We collect information about you in the following ways:

Information you give us. This includes:

the personal information you provide when you use, sign up, apply or enroll for our Services, including on our Site or over the phone or, to receive information about our Services;

the personal information that may be contained in any video, comment or other submission you upload or post in connection to your use of the Service;

the personal information you provide us in connection with your use of our Services, including application, registration and enrollment information;

the personal information you provide us in connection with the promotions we offer as part of the Services;

the personal information you provide when you report a problem with our Services or when we provide you with customer support;

the personal information you provide when you make a purchase of our product or services or through our Services, including payment and billing information; and

the personal information you provide when you correspond with us by phone, email or otherwise.

Information We Get from Others. We may also get information about you from other sources, marketers, partners, researchers, and others. We may combine information that we collect from you with information obtained from other third parties and information derived from any other product or service we provide.

Technology We Use For This Automatic Data Collection May Include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Functionality Cookies. These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customize . The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.

Analytics and Performance Cookies. These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered does not identify any individual visitor. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information.

We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.We use Google

Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Services works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Targeted and advertising cookies. These cookies track your browsing habits to enable us to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show advertisements which we think will be relevant to your interests while you are on third party websites. You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

Social Media Cookies. These cookies are used when you share information using a social media sharing button or “like” button on our Site or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

Web Beacons. On some of our Website pages and email, there may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and

single-pixel gifs). These web beacons permit us to count users who have visited certain of our Website pages or opened an email.

Third-Party Use of Cookies and Other Tracking Technologies

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

We do not control third-party tracking technology or how third parties use your information. Any questions you have about how our sponsors or other third parties use your information; you should contact them directly or carefully review the terms of service and privacy statements on their web pages.

EU users: international data transfer

When we or our affiliates and other third parties process your personal information this may involve processing, transferring and storing your information outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world in order to provide the Service and perform the Terms of Services. By using our Services, you agree to this transfer, storing or processing.

Data Security.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We do not store your PII. All of your PII, including payment transactions, go directly to a third-party site, such as Stripe and/or Paperbell.

The safety and security of your information also depends on you.

Sites you may access through our Website, such as Stripe (https://stripe.com/privacy-center/legal) and Paperbell (https://paperbell.com/privacy-policy/)may or may not require that you have a password for access. You are responsible for keeping that password confidential. We ask you not to share those passwords with anyone. We also strongly urge you to be careful about giving out information while in public areas of earshot of others, on public devices, or while using public Wi-Fi. The information you share in public areas may be viewed or overheard by others.

Unfortunately, the transmission of information via the internet is not completely secure. Although

we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

How Long We Retain Your Data

We keep your personal information for as long as we need it for the purposes for which it was collected. We may select to retain certain information for longer periods for certain legal, regulatory, contractual or accounting obligations. When we decide how long we will keep your information we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, why we need it, and any relevant legal requirements. We may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely.

Sensitive Personal Information.

If you send or disclose any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) to us, you consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such information to us.

EEA Members’ Rights

Sensitive personal information.

If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal information that we may carry out beyond the original purpose; or (v) the transfer of your personal information outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.

Amend. You can also contact us to update or correct any inaccuracies in your personal information.

Move. You can contact us for a copy of your personal information and can ask for a copy of personal information you provided in machine readable form.

Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data.

If you wish to exercise any of these rights, please contact us using the details above. In your request, please make clear: (i) what personal information is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within thirty (30) days of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.

Notice to California Residents – Your California Privacy Rights

individuals who are residents of California and have provided their personal information to us may request information regarding our disclosures, if any, of their personal information to third parties for direct marketing purposes. Such requests must be submitted to us at [email protected]. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. Please allow up to thirty (30) days for a response.

Changes To Our Privacy Policy.

It is our procedure to post any changes we make to this Policy on this page, with a notice that the Privacy Policy has been updated. If we make material changes to how we treat our users’ PII, we will notify you through notice on this Website or through the Apps. The last revised date will be noted at the top of the page. You are responsible for periodically visiting our Website, as well as reviewing this Policy for updates.

Questions and Concerns

Should you wish to raise a concern about our use of your information please contact us at [email protected]. We will reply to your inquiry as soon as we can and in any event, within forty (45) days. We hope to resolve any concern brought to our attention, however if you feel that your concern has not been adequately resolved, you reserve the right to contact your local data protection supervisory authority.