Tula Life, Inc. (“Tula”, “we”, “us”) is committed to respecting your privacy. Our website Privacy Policy describes how we handle your personal information generally. This supplemental Consumer Health Data Privacy Policy (“Health Privacy Policy”) explains our practices for “Consumer Health Data” as such term is defined below.

If we make any material updates to this Health Privacy Policy, we will notify you as required by law, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Health Privacy Policy earlier than required. We reserve the right to amend this Health Privacy Policy at our discretion and at any time. This Health Privacy Policy incorporates, and is subject to, our website Terms of Use.

1. Definitions

The term “Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that that identifies past, present or future physical or mental health status, and includes the following: information about medical conditions as well as non-medical information, and information about use of non-prescription medication or use of health-related products.

The term Consumer Health Data does not include information pertaining to individuals with whom we have an employment relationship.

2. Categories of Consumer Health Data that We Collect

Tula only collects, uses and discloses Consumer Health Data as needed to provide you with the products or services that you request or with your consent. We may collect Consumer Health Data related to the following categories of Consumer Health Data:

• Individual Health Conditions, Treatments and Diseases.Information about your health history, symptoms and/or treatment, such as pregnancy status, having allergies, treating a cold or flu with over-the-counter products, skin or hair condition, or the purpose for using a product.
• Bodily Function, Vital Signs and Measurements. Information about the operations of the systems of your body, such as digestion, metabolism, immune support, height, or weight.
• Reproductive and Sexual Health Information. Information about your reproductive system or sexual well-being, such as information about your periods or pregnancy status.
• Research Programs. Information you provide when participating in research studies or responding to our surveys including any of the above categories about physical or mental health, medical history or other health-related information

3. Prohibited Data

You are hereby prohibited from providing us with the following data:

• Biometric Data. Information including facial recognition data, and a mathematical representation of your biometric identifier, such as the template maintained for comparison.
• Genetic Information. Information that concerns your genetic characteristics, such as information revealed by analyzing DNA sequences or familial genetic information.

4. Purposes for Collecting Consumer Health Data and How We Use It

We may, from time to time, use your Consumer Health Data for the following purposes:

• To provide you Products/Services, including performing services for you and sending you certain products or samples you have requested.
• For Consumer Management purposes, such as identifying and authenticating you to our different marketing programs, websites, and mobile apps, administering and maintaining accounts and preferences, as well as financial incentive, rewards, discounts (e.g., price or service coupons) and loyalty programs; helping you manage your website or app preferences; and, allowing you to enter our contests or sweepstakes and leaving ratings and reviews for products.
• To facilitate Consumer Service/Communications, such as responding to your questions or requests for information; sending transactional messages (such as account statements or confirmations); and, sending marketing communications about our products or services (or the products or services of our partners), surveys, and invitations.
• For Payment/Financial purposes, such as processing your payment or a refund for the certain products you buy from us.
• For Quality and Safety Purposes, including administering our adverse reporting program (wherein you describe an adverse reaction you had to a product); quality control, training, and analytics; safety maintenance and verification; and, system administration and technology management, including optimizing our websites and applications.
• For Security purposes, including detecting threats and protecting against malicious or fraudulent activity.
• For Recordkeeping and Auditing, including recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information
• For Legal and Compliance Purposes, including risk management, audit, investigations, reporting and other legal and compliance reasons
• For Research & Development (“R&D”), such as internal research and designing and developing new products, services, and programs.

5. Sources of Consumer Health Data

We collect Consumer Health Data from the following sources:

• From you, such as when you engage with us about an adverse event that occurred from using our products.
• From our business and marketing partners, who provide us with information about consumers.
• From other third-party sources such as data brokers who provide us with information about consumers that may be interested in our products.
• We may also infer or derive Consumer Health Data by analyzing other non-health related data we have about you or other consumers.

6. Disclosures of Consumer Health Data

We do not, to the best of our knowledge “sell” or “share” your Consumer Health Data, as such terms are defined pursuant to law. However, we may disclose the categories of Consumer Health Data described above in the following circumstances:

• We may disclose Consumer Health Data with our data processors, service providers and contractors who assist us in providing goods and services to you. These processors may only use the data as permitted by our contracts with them.
• We may also disclose Consumer Health Data as permitted by law, such as (i) with your consent, and to an acquiring organization if we are involved in a sale or a transfer of our business.

7. Your Privacy Rights

You have specific rights with respect to your Consumer Health Data:

• You have the right to confirm whether we are collecting or sharing your Consumer Health Data and to access such data.
• You have the right to confirm whether we have not sold your Consumer Health Data.
• You have the right to request that we delete your Consumer Health Data.
• If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the services.

To exercise these rights, please contact us in accordance with the “Contact Us” section below. Once you submit such a request, we will authenticate your requests and process it as required by law. Please allow up to 45 days for a response.

8. Appeals and Complaints

If we deny your privacy rights request, you may appeal that denial by undertaking the following, please email us in accordance with the “Contact Us” section listed below, with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review.

You may also file a complaint with the relevant state regulatory agency, including:

Washington State Attorney General at www.atg.wa.gov/file-complaint.

9. Contact Us

For the avoidance of you doubt, you may not, under any condition, upload or otherwise input into our website (whether via a chat-box, interactive form, or other online communication platform) with any Consumer Health Data whatsoever.

If you have any questions or concerns about this Health Privacy Policy, or would like to exercise a right set forth herein, please contact us as follows: (phone) 844-545-1236, (email) privacy@tula.com, or (mail) Tula Life, Inc., ATTN: Data Privacy, 228 Park Avenue South, PMB 23606, New York, New York 10003-1502.