Privacy

Effective: July 01, 2024

Last Updated: July 07, 2024

Welcome and thank you for visiting Justbes and reviewing our privacy policy (“Policy”). This Policy describes the information we collect when you interact with Justbes LLC (“Justbes,” “we,” “us” or “our”) and the manner in which we use, share and protect such information. You may interact with us when you access and / or use our products and services including any digital offerings provided via our websites (e.g., justbes.com and any other sites to which this Policy is linked) and mobile applications (e.g., the Justbes Meditation & Well-Being app) as well as our in-person programs and consumer products (collectively, the “Services”) and in other ways as set forth herein. We refer to our websites and mobile applications (each, an App) collectively as our “Digital Properties”. This Policy also describes your privacy rights with respect to the information we collect and how the law protects you. This Policy is subject to and incorporated within Justbes’s Terms of Use (“Terms”), including its provisions on liability and dispute resolution. Capitalized terms not otherwise defined in this Policy shall have the meanings ascribed to them in the Terms.

If you do not want your information collected or used in the manner described in this Policy, please do not use our Services or otherwise interact with us. By using our Services or otherwise interacting with us in any manner, you are deemed to have agreed to the provisions of this Policy, unless you are in the European Economic Area (“EEA”) or Switzerland in which case you are acknowledging that you have been provided this Policy. We may change, modify, add or delete portions of this Policy at any time. We encourage you to visit this Policy frequently to ensure you are aware of how it applies to you.

Justbes is a “data controller” subject to the General Data Protection Regulation (the “GDPR”) only insofar as we are offering goods or services to individuals in the EEA or where our Digital Properties may be used to monitor individuals’ behavior as far as it takes place in the EEA. Nevertheless, this Policy provides a general description of how we process personal data, regardless of where individual users are from. If you have any questions about this Policy or want to exercise your rights pursuant to the Policy, please contact us using the details set forth below.

Justbes LLC

privacy@justbes.com

[Your Address]

[Your Phone Number]

Justbes is committed to working with you to obtain a fair resolution of any complaint or concerns about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint with the competent EU Member State authority.

1. Information We Collect

Overview

The nature of the information we collect from you depends on how you engage with us and generally consists of:

• Personally Identifiable Information (“PII”), which is information that can be used to identify you, including name, postal address, mobile phone number, or email address.

• Anonymous information, which is data about you, your device, or your activities that do not by itself identify you.

When, and to the extent, anonymous information is combined with PII, such information also becomes PII and is treated and protected as such in accordance with the terms of this Policy.

We collect PII and anonymous information that you directly provide to us as well as information you indirectly provide to us as you use our Services. We may also collect information about you from third parties.

Directly provided information

You may directly provide information to us, including PII such as your name, email address, and password when you register for an Account with us, sign up for a newsletter, or otherwise fill out a lead generation form regarding a particular product or service on our or third-party digital properties, including social media. You may provide further information to us, including information such as gender, birth date/location, payment information, postal address, and phone number as well as physical characteristics and personal preferences, goals, experiences, aptitudes, attitudes, and behaviors (i) when you edit your Profile, (ii) when you utilize tools and other services provided by us including calendars, journals, user surveys and online assessments such as the Dosha Quiz or Mind-Body Type Assessment (collectively, “MBTA”), etc., (iii) in the course of using our Apps or online programs or (iv) when you purchase a product or service from us through our online store.

We may also collect similar information from you in the course of your discussions with our sales personnel regarding potential purchases or to fully enroll you in our in-person events or other products and services. Please note that in order for us to accommodate your special needs or to ensure your suitability for certain in-person events or programs you may also provide us with specific health-related information including disabilities or allergies, among other information, and we may keep such information for future reference for your safety.

You may also provide information to us via communications at our in-person events, during telephonic or online group lessons, meditations, workshops, and other sessions, or via forums such as online groups, chat rooms, and message boards, some of which may be a required or optional component of our product and service offerings. We also collect information from you when you place a request for customer service when you respond to any censuses, surveys, or user interviews, provide any testimonials with respect to our products or services or apply for employment with us.

Indirectly provided information

Every time you engage with us we automatically collect certain information about you. This includes:

• Usage data such as which of our websites and Apps you visit and any or all of your activities on such properties, including the content and other Materials you access, the sequence, duration, dates and times, and manner of such activities and the purchases you make.

• Technical information including your internet protocol (IP) address (which may by itself be considered PII in certain jurisdictions and under certain circumstances), device type, model, operating system and identifier, web browser, pages viewed, including any referring page, and information about your mobile network such as the service provider, connection type, and geographic area.

Information collected from third parties

Information we may collect from third parties includes:

• Usage data and technical and non-technical information provided by third-party service providers (“Justbes Vendors”) with whom we contract to provide specific services to support our business.

• Information you provision us with access to including, for example, data provided by social media services when you create or log in to your Account via such social media services (including your name, username(s), e-mail address, and other information depending on your account settings with the relevant social media service).

• Transaction information from third-party app stores you use to install or purchase a subscription to one of our Apps.

• Additional information we may purchase about you and your activities from third-party data providers.

• Contact information provided by any person via our “Refer a Friend” feature.

We may combine any data we collect with other information we may have about you or use information we have to derive or infer other information. For example, we may be able to determine your approximate location using your IP address.

2. How We Use Your Information

We may collect, store, and use your information for any purpose relating to our business, subject to this Policy. This includes, for example:

• Personalizing your experience by offering and delivering content, products, and services relevant to your stated and inferred interests, needs, location, or other preferences.

• Fulfilling your orders including delivering goods or granting access to Services and Materials, as the case may be, as well as managing any related payments and collections and complying with any consequent legal obligations such as the collection and filing of taxes.

• Communicating with you about products and services we believe would be of interest to you.

• Providing you with support and responding to your inquiries, including investigating your concerns and monitoring and improving our processes.

• Soliciting your feedback on new or existing products and services.

• Analyzing our audience behavior and usage patterns to inform product and content development and to improve our marketing initiatives.

• Creating, maintaining, customizing, and securing your Account, preventing transactional fraud, and assessing and maintaining the safety, security, and integrity of the Services and our databases, business, and technology infrastructure more generally.

• Delivering targeted offers and ads through our Digital Properties, third-party properties, and via email, text messages (with your consent, where required by law) and push notifications.

• Enabling your participation in promotions, sweepstakes, or contests offered by us.

• Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• For other purposes as may be disclosed or is otherwise clear at the point of collection or in the event it is otherwise necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

3. Who Else May Have Access to Your Information

Justbes will never sell or rent your PII to any third party under any circumstances and will only share or disclose your PII with third parties as set forth in this Policy and in all cases, for legitimate business reasons. As you interact with us, the following entities may obtain your information:

• Justbes Vendors that process information we provide to them and those that directly collect information about you to perform services with respect to which we contract them. This includes entities that help us deliver our Services to you such as payment processors and third-party logistics providers such as warehouse and postal service providers. We also utilize the services of various software-as-a-service (“SaaS”) and other software and infrastructure companies for usage tracking and behavioral and marketing analytics, CRM and customer service, job application management, email, text or chat services and related marketing campaign management, serving of webinars and other video content, subscription management and other software and infrastructure companies for usage tracking and behavioral and marketing analytics, CRM and customer service, job application management, email, text, or chat services and related marketing campaign management, serving of webinars and other video content, subscription management, and management of our online courses among other services. Justbes Vendors are required to protect your PII and use it solely in connection with the services they provide to us.

• Partners who directly provide specific services to you in connection with a product or service offering from Justbes, including accommodations for in-person programs. Some programs may be provided by Partners such as wellness retreats. We share information relevant for their services, which may include special instructions, disabilities, and allergies.

• Advertising service providers that provide analytics and/or serve advertisements on our behalf, including agencies, social media platforms, and ad servers. They may collect and combine your information over time and across devices to present relevant advertisements to you.

• Providers of third-party functionality to enhance your experience, including social media service providers, who may directly collect and use your information for their purposes.

• Operators of third-party properties where our Materials may be accessed or that support or enhance our Services, such as social media and video service providers.

• Legal compliance: We may disclose your information to third parties to comply with legal requirements, enforce our Terms or Policy, or protect our rights, property, or safety.

• Affiliates of Justbes or others in connection with business transactions, like a sale or merger of Justbes.

• Any other entity as directed by you or with your consent.

We may also use and share anonymous aggregated information for any purpose, including research and demographic profiling.

Cookies, Web Beacons, and Similar Technologies

We and third parties use tracking technology on our Digital Properties and in connection with advertisements and activities on third-party properties. This includes:

• Cookies: Small data strings stored in your browser, including session cookies (temporary) and persistent cookies (reloaded when you open a new session). They help us authenticate you, recognize preferences, analyze site usage, and customize your experience. You may configure your browser to manage cookies.

• Web Beacons: Electronic images in a webpage or email that recognize information on your computer like cookie numbers, date, and time of page view.

• Other Technologies: Local storage objects, such as “flash cookies,” authentication tokens, and HTML5 local storage, which perform similar functions to cookies.

Third parties may use these technologies for interest-based advertising, collecting and combining data to infer consumer interests and present relevant ads across devices. You can opt out of interest-based advertising through various mechanisms, including the Digital Advertising Alliance’s Consumer Choice Page and settings on iOS and Android devices.

How to Access, Change, or Delete Your Information and Messaging Preferences

If you have an Account, you can view and edit certain information in your Profile. Contact us at support@justbes.com for other edits. You can also request the removal of public display information or stop promotional emails by clicking “Unsubscribe” or managing your Account settings. You can manage push notifications through app or device settings.

Children’s Privacy

We do not intentionally collect PII from individuals under 16 years old. If we learn we hold such information, we will take steps to remove it. Parents or legal guardians can notify us if they become aware that a minor has provided us with PII.

How We Protect Your Information

We use industry-standard security measures to protect your PII from unauthorized access, use, alteration, or disclosure. However, no security system is impenetrable, and we cannot guarantee the security of your PII.

Links to Other Websites and Services

Our Digital Properties may contain links to third-party websites. We do not control their privacy policies or practices. Review the terms and policies of any linked sites before providing any PII. We are not responsible for the content or practices of linked websites.

California Residents

California residents have specific privacy rights, including:

• The right to know what personal information is collected, used, shared, or sold.

• The right to delete personal information.

• The right to opt-out of the sale of personal information.

• The right to non-discrimination for exercising privacy rights.

To exercise these rights, contact us via email at privacy@justbes.com or by phone at [Your Phone Number].

Visiting Our Digital Properties from Outside the United States

We store and process all PII within the US. If you are visiting from outside the US, your information will be transferred to, stored, and processed in the US. By using our services, you consent to this transfer.

Visiting Our Digital Properties from the European Economic Area (EEA)

When we collect information from EEA residents, we process your PII based on contract fulfillment, legitimate interests, consent, or legal obligations. PII may be transferred outside the EEA with adequate protection measures in place. EEA residents have additional rights, including access, correction, deletion, and data portability. Contact us to exercise these rights.

Data Retention

We retain your PII only as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, tax, accounting, or reporting requirements. We may retain your PII longer in case of a complaint or potential litigation. Anonymized information may be used indefinitely without further notice to you.

Changes in Our Privacy Policy

We may modify this Policy from time to time. Changes will be posted on our Digital Properties. Continued use of our Services after changes are posted constitutes your acceptance of the changes.

Contact, Questions, or Feedback

For questions or complaints about this Policy, contact us at:

Email: privacy@justbes.com

Phone: [Your Phone Number]

Mail: [Your Address]

We will respond to written complaints and work to resolve any privacy concerns.

Feel free to review the original privacy policy and terms for any specific details that are important to include or adjust to better fit your business needs. Non-Personal Information

Personal information does not include:

• Publicly available information from government records.

• Deidentified or aggregated consumer information.

• Information excluded from the CCPA’s scope, such as health or medical information covered by HIPAA, or personal information covered by certain sector-specific privacy laws.

Use of Personal Information

We may use or disclose the personal information we collect for various purposes as set forth in the “How We Use Your Information” section. We do not collect additional categories of personal information or use the collected personal information for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosures of Personal Information for a Business Purpose

In the last 12 months, we have disclosed the following categories of personal information for a business purpose: identifiers, personal information categories listed in the California Customer Records statute, protected classification characteristics, internet or similar network activity, sensory data, professional or employment-related information, and inferences drawn from other personal information. These disclosures are made to Justbes Vendors, Partners, and other third parties as described in this policy.

Sale of Personal Information

Justbes has not sold personal information in the last 12 months.

Your Rights and Choices

California residents have specific rights regarding their personal information:

• Access to Specific Information and Data Portability Rights: You have the right to request that Justbes disclose certain information about our collection and use of your personal information over the past 12 months.

• Deletion Request Rights: You have the right to request that Justbes delete any of your personal information that we collected and retained, subject to certain exceptions.

Exercising Access, Data Portability, and Deletion Rights

To exercise these rights, please submit a verifiable consumer request to us via email at privacy@justbes.com or call us at [Your Phone Number]. Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. You can designate an authorized agent using our form or a legally binding document signed by you. We may require verification of your designated agent’s identity.

Response Timing and Format

We strive to respond to verifiable consumer CCPA requests within 45 days of receipt. If more time is needed, we will inform you of the reason and extension period in writing. Our response will be delivered through your chosen method, either electronically or by mail. There are no fees for processing or responding to verifiable consumer requests unless excessive, repetitive, or unfounded.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. We will not deny you goods or services, charge different prices or rates, or provide a different level of goods or services based on your choice to exercise these rights.

Other California Privacy Rights

Under California’s “Shine the Light Law,” California residents can request a notice identifying the categories of personal customer information shared with affiliates and third parties for marketing purposes. To request this notice, email privacy@justbes.com or mail us at [Your Address].

Visiting Our Digital Properties from Outside the United States

We process all PII within the United States. If you visit our Digital Properties from outside the US, your information will be transferred, stored, and processed in the United States. By using our services, you consent to this transfer.

Visiting Our Digital Properties from the European Economic Area (EEA)

When collecting information from EEA residents, we process PII based on contract fulfillment, legitimate interests, consent, or legal obligations. PII may be transferred outside the EEA with appropriate protection measures. EEA residents have additional rights, including access, correction, deletion, and data portability. Contact us to exercise these rights.

Data Retention

We retain your PII only as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, tax, accounting, or reporting requirements. Anonymized information may be used indefinitely.

Changes in Our Privacy Policy

We may update this Policy from time to time. Changes will be posted on our Digital Properties. Continued use of our Services after changes are posted constitutes your acceptance of the changes.