PRIVACY NOTICE - Version 1.1
Last updated February 2, 2026
This privacy notice for Zing Performance Ltd (doing business as Hallowell Brain Health)
("
Hallowell Brain Health," "we," "us," or "our"), describes how and why we might collect, store,
use, and/or share ("
process") your information when you use our services ("Services"), such
as when you:
• Visit our website at http://www.hallowellbrainhealth.com, or any website of ours that links to
this privacy notice
• Download and use our mobile application (Hallowell Brain Health), or any other application of
ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns, please contact us at
privacy@hallowellbrainhealth.com
SUMMARY OF KEY POINTS
What personal information do we process? When you visit, use, or navigate our Services,
we may process personal information depending on how you interact with Hallowell Brain
Health and the Services, the choices you make, and the products and features you use. See
section 1. What Information do we collect.
Do we process any sensitive personal information? We may process limited health-related
information if you choose to connect a compatible wearable device or health platform. This
information is processed only with your explicit consent.
Do we receive any information from third parties? Yes. If you choose to connect a
compatible wearable device or health platform, we receive health-related information from those
services.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may
share information in specific situations and with specific third parties. See section 4. When and
with whom do we share your personal information
How do we keep your information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no electronic transmission
over the internet or information storage technology can be guaranteed to be 100% secure, so
we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information.
What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. See section
10. What are your privacy rights
How do you exercise your rights? The easiest way to exercise your rights is by contacting us
(privacy@hallowellbrainhealth.com). We will consider and act upon any request in accordance
with applicable data protection laws.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on
the context of your interactions with us and the Services, the choices you make, and the
products and features you use. The personal information we collect may include the following:
• names
• phone numbers
• email addresses
• billing addresses
• mailing addresses
• usernames
• passwords
• contact preferences
Health and Wellbeing Information (Optional). If you choose to connect a compatible wearable
device or health platform, we may collect health-related information such as resting heart rate,
heart rate variability, sleep data, and resting respiratory rate. We also collect self-reported mood
and happiness ratings where you choose to provide them.
This information is collected only on days when you log into the app and reflects average data
from the previous day. We do not collect live or real-time health data.
Sensitive Information. We may process limited health-related information where you have
explicitly consented to connect a compatible wearable device or health platform. This
information is processed only for the purposes described in this privacy notice.
Payment Data. We may collect data necessary to process your payment if you make
purchases, such as your payment instrument number, and the security code associated with
your payment instrument. All payment data is stored by Stripe, Apple Media Services and
Google Play. You may find their privacy notice link(s) here: https://stripe.com/gb/privacy,
https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy.
Application Data. If you use our application(s), we also may collect the following information if
you choose to provide us with access or permission:
• Geolocation Information. We may request access or permission to track location-based
information from your mobile device, either continuously or while you are using our mobile
application(s), to provide certain location-based services. If you wish to change our access or
permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your
mobile device, including your mobile device's reminders, storage, and other features. If you wish
to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device
ID, model, and manufacturer), operating system, version information and system configuration
information, device and application identification numbers, browser type and version, hardware
model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or
proxy server). If you are using our application(s), we may also collect information about the
phone network associated with your mobile device, your mobile device's operating system or
platform, the type of mobile device you use, your mobile device's unique device ID, and
information about the features of our application(s) you accessed.
• Push Notifications. We may request to send you push notifications regarding your account or
certain features of the application(s). If you wish to opt out from receiving these types of
communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s),
for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and
device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This
information does not reveal your specific identity (like your name or contact information) but may
include device and usage information, such as your IP address, browser and device
characteristics, operating system, language preferences, referring URLs, device name, country,
location, information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our Services
and which we record in log files. Depending on how you interact with us, this log data may
include your IP address, device information, browser type, and settings and information about
your activity in the Services (such as the date/time stamps associated with your usage, pages
and files viewed, searches, and other actions you take such as which features you use), device
event information (such as system activity, error reports (sometimes called "crash dumps"), and
hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet,
or other device you use to access the Services. Depending on the device used, this device data
may include information such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet service provider and/or
mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which
can be either precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by refusing access to
the information or by disabling your Location setting on your device. However, if you choose to
opt out, you may not be able to use certain aspects of the Services.
Where you choose to connect a wearable device or health platform, certain health-related
information may also be accessed via those services, subject to your permission.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
• To facilitate account creation and authentication and otherwise manage user accounts.
We may process your information so you can create and log in to your account, as well as keep
your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information
to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to
respond to your inquiries and solve any potential issues you might have with the requested
service.
• To send administrative information to you. We may process your information to send you
details about our products and services, changes to our terms and policies, and other similar
information.
• To fulfill and manage your orders. We may process your information to fulfill and manage
your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback
and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal
information you send to us for our marketing purposes, if this is in accordance with your
marketing preferences. You can opt out of our marketing emails at any time. (For more
information, see section 10. What are your privacy rights below).
• To deliver targeted advertising to you. We may process your information to develop and
display personalized content and advertising tailored to your interests, location, and more.
• To protect our Services. We may process your information as part of our efforts to keep our
Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to
better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may
process your information to better understand how to provide marketing and promotional
campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when
necessary to save or protect an individual's vital interest, such as to prevent harm.
• To display optional health and wellbeing information within the app where you have chosen to
connect a wearable device or health platform.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we
have a valid legal reason i.e., legal basis) to do so under applicable law, like with your consent,
to comply with laws, to provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid
legal bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:
• Consent. We may process your information if you have given us permission (i.e., consent) to
use your personal information for a specific purpose. You can withdraw your consent at any
time. Where we process health-related personal data, we rely on your explicit consent. You may
withdraw this consent at any time by disconnecting your wearable device or contacting us.
• Performance of a Contract. We may process your personal information when we believe it is
necessary to fulfill our contractual obligations to you, including providing our Services or at your
request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably
necessary to achieve our legitimate business interests and those interests do not outweigh your
interests and fundamental rights and freedoms. For example, we may process your personal
information for some of the purposes described in order to:
● Send users information about special offers and discounts on our
products and services
● Develop and display personalized and relevant advertising content for our
users
● Analyze how our Services are used so we can improve them to engage
and retain users
● Support our marketing activities
● Diagnose problems and/or prevent fraudulent activities
● Understand how our users use our products and services so we can
improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for
compliance with our legal obligations, such as to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal rights, or disclose your information as evidence
in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect
your vital interests or the vital interests of a third party, such as situations involving potential
threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or in situations where your
permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your
information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a
timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or
settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of
financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability
or the accuracy of the information and the collection is reasonable for purposes related to
investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court
relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession
and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with
the following third parties.
We may need to share your personal information in the following situations:
• Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion
of our business to another company.
• Affiliates. We may share your information with our affiliates, in which case we will require
those affiliates to honor this privacy notice. Affiliates include our parent company and any
subsidiaries, joint venture partners, or other companies that we control or that are under
common control with us.
• Third-Party Health Platforms. If you choose to connect a wearable device or health platform
(such as Apple Health, Fitbit, or Garmin Connect), those services act as data sources only. We
do not control these services, and their own terms and privacy policies apply.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access
or store information. Specific information about how we use such technologies and how you can
refuse certain cookies is set out in our Cookie Notice.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your
own.
Our servers are located in. If you are accessing our Services from outside, please be aware that
your information may be transferred to, stored, and processed by us in our facilities and by
those third parties with whom we may share your personal information (see section 4. When
and with whom do we share your personal information), in and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these
countries may not necessarily have data protection laws or other similar laws as comprehensive
as those in your country. However, we will take all necessary measures to protect your personal
information in accordance with this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the
European Commission's Standard Contractual Clauses for transfers of personal information
between our group companies and between us and our third-party providers. These clauses
require all recipients to protect all personal information that they process originating from the
EEA or UK in accordance with European data protection laws and regulations. Our Standard
Contractual Clauses can be provided upon request. We have implemented similar appropriate
safeguards with our third-party service providers and partners and further details can be
provided upon request.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in
this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set
out in this privacy notice, unless a longer retention period is required or permitted by law (such
as tax, accounting, or other legal requirements). No purpose in this notice will require us
keeping your personal information for longer than the period of time in which users have an
account with us.
When we have no ongoing legitimate business need to process your personal information, we
will either delete or anonymize such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and
technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission over
the Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
9. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. Where a
parent or guardian consents to a minor using the Services, any optional health-related data is
processed only with that consent and in accordance with this privacy notice. By using the
Services, you represent that you are at least 18 or that you are the parent or guardian of such a
minor and consent to such minor dependent's use of the Services. If we learn that personal
information from users less than 18 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data from our records. If you
become aware of any data we may have collected from children under age 18, please contact
us at privacy@hallowellbrainhealth.com
10. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK),
and Canada, you have rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a copy of your
personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your
personal information; and (iv) if applicable, to data portability. In certain circumstances, you may
also have the right to object to the processing of your personal information. You can make such
a request by contacting us by using the contact details provided in the section 14. How can you
contact us about this notice.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory
authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are
available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. This includes the right to withdraw consent
for the processing of any health-related data you have chosen to share. You can withdraw your
consent at any time by contacting us by using the contact details provided in the section 14.
How can you contact us about this notice.
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our
marketing and promotional communications at any time by clicking on the unsubscribe link in
the emails that we send, or by contacting us using the details provided in the section14. How
can you contact us about this notice. You will then be removed from the marketing lists.
However, we may still communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of your account, to respond to
service requests, or for other non-marketing purposes.
Account Information
If you would at any time like to review or change the information in your account or terminate
your account, you can:
• Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms
and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If
you prefer, you can usually choose to set your browser to remove cookies and to reject cookies.
If you choose to remove cookies or reject cookies, this could affect certain features or services
of our Services. To opt out of interest-based advertising by advertisers on our Services visit
http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights, you may email us at
privacy@hallowellbrainhealth.com.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage no
uniform technology standard for recognizing and implementing DNT signals has been finalized.
As such, we do not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard for online
tracking is adopted that we must follow in the future, we will inform you about that practice in a
revised version of this privacy notice.
12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding
access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our
users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third
parties for direct marketing purposes and the names and addresses of all third parties with
which we shared personal information in the immediately preceding calendar year. If you are a
California resident and would like to make such a request, please submit your request in writing
to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with
Services, you have the right to request removal of unwanted data that you publicly post on the
Services. To request removal of such data, please contact us using the contact information
provided below and include the email address associated with your account and a statement
that you reside in California. We will make sure the data is not publicly displayed on the
Services, but please be aware that the data may not be completely or comprehensively
removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory
purpose and
(2) every individual who is domiciled in the State of California who is outside the State of
California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations
regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12)
months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias, postal
address, telephone or mobile contact number,
unique personal identifier, online identifier,
Internet Protocol address, email address, and
account name
YES
B. Personal information
categories listed in the
California Customer
Records statute
Name, contact information, education,
employment, employment history, and financial
information
YES
C. Protected classification
characteristics under
California or federal law
Gender and date of birth
YES
D. Commercial information
Transaction information, purchase history,
financial details, and payment information
YES
E. Biometric information
Health data (heart rate, heart rate variability,
sleep data, resting respiratory rate.
LIMITED
(OPTIONAL)
F. Internet or other similar
network activity
Browsing history, search history, online behavior,
interest data, and interactions with our and other
websites, applications,
systems, and advertisements
YES
G. Geolocation data
Device location
YES
H. Audio, electronic,
visual, thermal, olfactory,
or similar information
Images and audio, video or call recordings
created in connection with our business activities
NO
I. Professional or
employment-related
information
Business contact details in order to provide you
our Services at a business level or job title, work
history, and professional qualifications if you
apply for a job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from
other personal information
Inferences drawn from any of the collected
personal information listed above to create a
profile or summary about, for example, an
individual's preferences and characteristics
NO
We may also collect other personal information outside of these categories through instances
where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy
notice.
You may contact us by email at support@hallowellbrainhealth.com, or by referring to the contact
details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if
the authorized agent does not submit proof that they have been validly authorized to act on your
behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Each service provider is a for-profit entity that
processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
"selling" of your personal information.
Zing Performance Ltd has not disclosed or sold any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. Zing Performance Ltd will
not sell personal information in the future belonging to website visitors, users, and other
consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal
information, we will respect your request and delete your personal information, subject to certain
exceptions provided by law, such as (but not limited to) the exercise by another consumer of his
or her right to free speech, our compliance requirements resulting from a legal obligation, or any
processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a
business purpose; and
• the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer
information that is de-identified in response to a consumer request or to re-identify individual
data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. These verification efforts require us
to ask you to provide information so that we can match it with information you have previously
provided us. For instance, depending on the type of request you submit, we may ask you to
provide certain information so that we can match the information you provide with the
information we already have on file, or we may contact you through a communication method
(e.g., phone or email) that you have previously provided to us. We may also use other
verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority
to make the request. To the extent possible, we will avoid requesting additional information from
you for the purposes of verification. However, if we cannot verify your identity from the
information already maintained by us, we may request that you provide additional information
for the purposes of verifying your identity and for security or fraud-prevention purposes. We will
delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask
to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We
may deny a request from an authorized agent that does not submit proof that they have been
validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling of your personal information to third parties.
Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible,
but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at support@hallowellbrainhealth.com, or
by referring to the contact details at the bottom of this document. If you have a complaint about
how we handle your data, we would like to hear from you.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by
an updated "Revised" date and the updated version will be effective as soon as it is accessible.
If we make material changes to this privacy notice, we may notify you either by prominently
posting a notice of such changes or by directly sending you a notification. We encourage you to
review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
privacy@hallowellbrainhealth.com
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the
personal information we collect from you, change that information, or delete it. To request to
review, update, or delete your personal information, please contact us
privacy@hallowellbrainhealth.com.
