Privacy Policy - Keep Away from GRAS

Healthy Strategies Privacy Policy rev 1.2 021220

This Privacy Policy applies to any websites provided by Healthy Strategies Consulting LLC (hereafter “Healthy Strategies” or “we”), including the websites at marcelamagdapopamd.com and drpopaslist.com, and to any products, services, or information (collectively, the “Services”) offered by Healthy Strategies’ publishing arm, Birch Paper Books, on such websites whether or not publicly accessible (hereafter the “Sites”). ———————————————————————————————————————————

We understand and values privacy – yours and ours. To help maintain your privacy and the security of your personal information, we communicate this privacy policy to our employees and agents, and we strive to internally ensure privacy safeguards. All uses of the Sites are subject to the Terms of Service and this Privacy Policy, which is part thereof.

We’ve developed this Privacy Policy to explain how we currently or may in the future collect, use, disclose, transfer, and store information received from you in connection with the Sites. Before disclosing information to us, please familiarize yourself with our privacy practices so you can understand how your information may be used by Healthy Strategies.

Our Collection and Use of Information:

We may collect information in a number of ways from users who access our Sites or services. We may collect personal and non-personal information in various ways. You may provide your information to us as part of a request to receive a communication from us (such as a free article, pdf, video, whitepaper, or the like) or more information regarding a product or a service; we may request your information to better serve you; or we may require your information in order to be able complete a transaction (e.g. an online sale) or to provide access (e.g. a subscription service, or returning to revisit an online service we may offer in the future, such as a secure ‘customer-only’ access).

A. Collection of Personal Information

Personal information (or “Personally Identifiable Information” or “PII”) is information and data that can be used to specifically identify or contact a single person.

You may be asked to provide your personal information when you contact Healthy Strategies for any reason. We may share your personal information internally. If we do, we will use it in accordance with this Privacy Policy. We may also combine personal information with other information to help us to develop or improve our products, services, content, communications, and/or advertising, or to provide improved user experiences for you.

Personal information we collect

Examples of some types of personal information We may collect in connection with the Sites and how we may use it include the following:

• If you register to receive communications from us regarding any product, or services; if you request support; or you are looking to do business with Healthy Strategies; if you provide electronic feedback on our services or products, or participate in a promotion or online survey, or respond to an advertisement, we may collect a variety of information, including your name,

Healthy Strategies Privacy Policy rev 1.2 021220

mailing address, phone number, email address, contact preferences, and/or social media credentials. We do not directly collect credit card numbers in connection with the Sites, and we do not collect or store credit card numbers from end-users in connection with any the Sites. You should ensure that any purchases made through third-party provider sites such as Amazon are done via a secure browser session. All such purchases will be subject to the privacy policies of the third-party provider.

• We may collect information required to provide the services in connection with your access including PII such as your name, email address, IP address and current location. This information in some cases may only be stored temporarily, or transiently, e.g. during a particular secure session between your computer and a server hosting the Sites.

How we use your personal information

Optional Communications: The personal information we collect allows us to provide you with Healthy Strategies’ latest product announcements, subscriptions, whitepapers, and other information, updates, and upcoming events. These communications, if offered, are optional. If you don’t want to receive these communications, or do not wish to be on our mailing list, you can opt out of receiving them. Each communication of any type from us will provide opt-out directions, and if you are a registered user, client, or customer, you will also be able to generally opt-out after you are logged in (e.g. via your account, dashboard, or the like). The information in connection with these optional communications and your responses help us to improve the Sites, and our information, products, services, content, and advertising.
We also use personal information to help us develop, deliver, improve, and customize our Sites information, products, services, content, and advertising and to provide a better user experience for every user of our products and services.
Important Communications: We may use your personal information to send important communications, e.g., about your products, or services, updates to the Sites, material changes to our terms, conditions, and policies (including this Privacy Policy), critical updates to products or services, or changes that impact your use of our products or services. Because this information is vital to your interaction with us, you may NOT opt out of receiving these communications if you wish to continue to use the Sites, or any products, or services offered in connection with the Sites.
We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Healthy Strategies’ information, products, services, communications, support and/or help functions, and user interfaces.
If you enter into a promotional program, we may use the information you provide to administer those programs.
If we become involved in a legal process as a result of your actions on the Sites, or in connection with any training materials, products, or services offered via the Sites, we may be required to disclose your PII to a government authority, or a third party who e.g., issues a subpoena that require us to provide it. Our response(s) to any such legal process will be handled on a case-by- case basis following the advice of our attorneys.

B. Collection of Non-Personal Information

Information of a type or in a form that does not permit direct identification of or association with any specific individual is ‘non-personal information.’ Combinations of personal and non-personal information are considered personal information if the combined information can be used to identify or contact any specific individual(s). Aggregated data is considered non-personal information for the purposes of this Privacy Policy as long as it cannot be used to identify or contact any specific individual. Internet Protocol (IP) addresses and certain other identifiers may be considered personal information under various local law; we endeavor to comply with the laws and regulations that are applicable to us.

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How we collect and use your non-personal information

We may collect, use, transfer, and disclose non-personal information for any purpose.

The following are some examples of non-personal information that we collect and how we may use it:

We may collect non-personal information (e.g. demographic information) regarding our customers collectively including information such as age, gender, occupation, preferred language, zip code, area code, geographic location, or the time zone from which customers access the Sites, information, products, or services. Such non-personal information is used so that we can better understand who our customers are, and their behavior generally with regards to the Sites, and to improve our information, products, services, communications, support, help, user experiences, and advertising for our customers.
We also may collect non-personal information regarding customer activities on the Sites or uses of Healthy Strategies’ information, products, and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of the Sites, or our products, and services are of most interest or which can be improved. Non-personal support or help request data may be used to improve our information or the Sites, communications, and user interfaces, or to allow us to provide additional product or service offerings to our present or future customers.
We may collect non-personal information regarding the digital footprints of our customers with respect to accessing the Sites, or any related information, products, or services including mobile and non-mobile access, specific types of devices being used, unique device IDs, type of browser(s) being used, networks that our customers use, and other non-personal information. This information may be used to improve the Sites, information, products, or services including but not limited to their performance, functionality, design, or responsiveness.

C. Cookies and Other Technologies

To help us serve you better, we may use technological means to better understand and adapt to user behavior. To accomplish this, the Sites, as well as our online information and services, email messages, and advertisements may use digital ‘cookies’ or related technology such as pixel tags, clear gifs, and web beacons. These technologies help us to know which parts of the Sites people have visited, and provide data to aid us in understanding the effectiveness of the information, services, our advertisements, and web searches. These data are used to improve our information, products, services, communications, and advertisements. We generally consider such information collected through the use of cookies and other technologies as non-personal information, and treat it accordingly.

We also use cookies and other technologies to remember personal information when you use the Sites, information, products, or services. These uses are intended to improve your personal experience. For example, we can provide better and more personal results if we ‘remember’ your preferred settings, your name, and such.

Healthy Strategies does not presently but may in the future use cookies or other technologies in connection with certain advertising services to determine your experience with our content including whether an ad is likely to be of interest to you, whether or not you are served a particular ad, and the number of times you are served a particular ad. These technologies allow us to measure the effectiveness of our advertising campaigns. You may have options for opting out of such targeted ads. You should contact your service provider or your mobile provider to inquire about how to do so. You have control over this and We cannot target an ad to you if you have done so.

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We may also use specific technologies in connection with certain communications such as emails that may be used to track actions by recipients. For example, these communications may include one or more clickable text or graphics that include URLs that link to content on the Sites. However, these URLs may pass through a web server that tracks the click before arriving at the linked content on the Sites. The tracked data can help us determine the effectiveness of our communications to users and customers, or to gage interest in specific topics. If you prefer not to have your responses to such communications tracked in this manner, do not click links in the email messages. Such communications may also include pixel tags that can tell us whether e.g. an email has been opened. We may use this information to throttle the number of messages sent to users or customers, or to remove people who do not read or interact with our communications from one or more lists.

Cookies and other technologies can generally be controlled on your devices. If you want to disable cookies and you should review your privacy or security settings on your device. Please note that certain features of the Sites or related information, products, or services may not be available if you have cookies disabled on your device. We will typically try to warn you that a page or feature you are trying to reach will not function without cookies enabled. If you have your cookies on your device or browser disabled and are having difficulties you may wish to enable them to see if the problem is resolved.

D. Log Files

As part of standard protocols, the servers hosting Healthy Strategies’ Sites may automatically gather certain information and store it in log files. This information may include date/time stamp of access, Internet Protocol (IP) address(es), device type, operating system, browser and version, language, login details, Internet Service Provider (ISP), referring page, exit page, and other data. We do not control this data or its collection.

Such log files are generally useful for a number of purposes including helping to keep the server operating well – e.g., to maintain security, measure relative usage, understand and analyze trends regarding users, server access, load, or server problems, more effectively and efficiently administer the Sites, as well as related training materials, products, services, or communications, and gather non- personal demographic information about our users. Consistent with the provisions of this Privacy Policy, if We receives such data from the host, it may use the data in the Log Files in a variety ways useful to its business or to provide better experiences for its users and customers.

E. Social Media

We may collect certain information from you if you interact with us via social media such as Facebook, Twitter, LinkedIn, Google+, Pinterest, Snapchat, Instagram, and other such services. For example, you may be given the option to register to receive mailings, whitepapers, newsletters or the like, via your social media account. The information we receive or collect from such social media, and our ability to collect it, may depend on the social media Sites, its policies, and its requirements or its technology. We may collect the information you provide from these social media interactions and may use it for various purposes to improve our services or your experience, or to contact you regarding the reason you connected with us or with additional offers in the future. Of course, you have the opportunity to opt-out at any time provided we do not require a means of contacting you to fulfill your request.

F . Children

Protecting children’s privacy is important to Healthy Strategies. It is our policy to comply with the Children’s Online Privacy Protection Act of 1998 and all other applicable laws. Although Healthy

Healthy Strategies Privacy Policy rev 1.2 021220

Strategies’ information may be applicable to children, we restrict our websites use to persons eighteen years or older. Therefore, we do not knowingly collect personal information from children under 18.

[PLEASE NOTE: You must be 18 or older to use the Sites, and to purchase the products, or services offered via the Sites without an adult (parent or guardian). Parents or guardians are solely responsible for the use of the Sites by any child under the age of 18.]

DUE TO THE AGE RESTRICTIONS FOR USE OF THIS WEBSITES, NO INFORMATION OBTAINED VIA THIS WEBSITES FALLS WITHIN THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) AND IT IS NOT MONITORED AS DOING SO.

Notwithstanding the foregoing, if we discover or form a reasonable belief that we have received any information from a child under 18 in violation of this policy, we will delete that information. If you believe We have any information from a child under age 18, please contact us at the following address:

via Mail:
Healthy Strategies c/o Birch Paper Books

PO Box 3144, Fort Lee, NJ

via email:

legal@marcelamagdapopamd.com

Disclosure to Third Parties

At times We may make certain personal information available to strategic partners that work with us to provide information, products and services, or that help us service our customers. Personal information will only be shared by Healthy Strategies to provide or improve the Sites, and our information, products, services, and advertising.

A. Service Providers

To provide its various products or services, Healthy Strategies works or may work with third party providers, who may be located wherever We operate, or in any other location. Such companies provide services to us. Examples may include server hosting, information processing, software platform services, emailing services, video hosting, product/service delivery, communications, managing and enhancing customer data, providing technical support and/or customer service, and conducting customer research or satisfaction surveys. At any given time, We may work with one or more such provider. We will only provide personal information to these companies where required for them to provide their services, or to improve our products or services for our customers. These companies are contractually obligated to protect your information.

B. Others

We will not share PII with third parties for their marketing purposes. In some cases, We may be required by legal process to disclose your personal information. Such disclosure may be compelled by applicable law, regulation, judicial order, and/or lawful requests from local authorities. We may also disclose information about you if we determine, in our sole discretion, that disclosure is necessary or appropriate to ensure the safety of any individual(s), or for purposes of national security, law enforcement, or other issues of public importance.

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If the Sites and/or information, products, or services, or Birch Paper Books become the subject of a reorganization under the bankruptcy laws, or as a result of a sale, or other change in control, any and all personal information in Healthy Strategies’ control will be transferred to the trustee, debtor in possession, successor, acquirer, or such other third party as will control the Sites, and/or the information, products, or services thereafter.

We reserve the right to disclose personal information if we reasonably believe that disclosure is necessary to protect our users, customers, or the public, prevent fraud or financial wrongdoing, or in any action to enforce our Terms of Service, other terms and conditions, or other policies.

Personal Information Protection

We use commercially reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. We restrict access of personal information to our employees, contractors, and/or agents who need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We and our third- party providers use or will use Secure Sockets Layer (SSL) encryption on all web pages where personal information is transmitted, or will advise you otherwise. Your personal browser settings can also be used to help identify any unsecure page.

You are solely responsible for any personal information you choose to submit on non-secure pages or Sites including but not limited to public comment threads, if any on the Sites, or any social media Sites, groups, or threads related to the Sites or the related information, products, or services.

Access to Your Personal Information

Except for the very limited personal data described herein, We does not currently anticipate maintaining significant PII on visitors who do not register (e.g. for mailing or to receive subscriptions, PDF documents, whitepapers, or the like). Registered users of the Sites, if any, should periodically log in to review their name, contact information and other readily available personal information, and to ensure they are accurate, complete, and up to date. Any registered users can make changes to their information.

You can request access to any personal information we have for you. We will make a good faith effort to provide you with access to reasonably accessible information. You can request that we correct the data if it is inaccurate or delete your personal data. We will comply with such requests if they are reasonable and we will delete your data if We are not required to retain it by law, and does not require it for legitimate business purposes. We may reserve the right to refuse deletion requests that we believe require undue time, or technical effort, or where not provided by local law. We also reserve the right to deny or delay requests where the personal information is scheduled to be deleted as part of any upcoming purge of data that is not being retained. Request for access, correction, or deletion can be submitted to legal@marcelamagdapopamd.com.

Links to Third-Party Sites

The Sites, information, products, services, and communications may contain links to third-party websites, products, or services. Information collected by third parties is governed by their privacy practices, not this Privacy Policy. Please be aware when you leave the Sites and understand that you are subject to a third party’s privacy policy except when you are on the Sites, or using Healthy Strategies’ related information, products, or services.

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International Users: US Safe Harbor

Information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. We have not yet fully complied with “Privacy Shield” (the latest “safe harbor” framework(s) set forth by the U.S. Department of Commerce) regarding the collection, use, retention, and transatlantic transmission of personal information collected by organizations in the European Economic Area and Switzerland. We will revise this Privacy Policy as needed to inform international users of its compliance with the safe harbor.

Changes to this Privacy Policy and Privacy Questions

If you have any questions or concerns about this Privacy Policy please email us at via email:

legal@marcelamagdapopamd.com

This Privacy Policy is subject to change from time to time at Healthy Strategies’ sole discretion. Please check this page periodically for changes. Any such changes to the Privacy Policy will be available on this page. If the policy has been changed in a material way, a notice will be posted on our websites along with a link to the updated Privacy Policy. Your continued use of our Sites following the posting of changes to these terms will mean you accept the changes. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

We will also archive prior versions of this Privacy Policy and make those versions available for your review.

LAST UPDATED:
This Policy was created December 2019 and last updated December 5, 2019.

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Notice of Compliance to California Residents – Your California Privacy Rights Under The California Online Privacy Protection Act and the California Business and Professions Code

This privacy policy identifies the categories of personally identifiable information that our company collects through our websites or online services about individual consumers who use or visit Healthy Strategies’ commercial websites or online services (collectively “the Sites”) and the categories of third- party persons or entities with whom our company may share that personally identifiable information.

We do not maintain an online process for an individual consumer who uses or visits our commercial websites or online service to review and request changes to any of his or her personally identifiable information that is collected through our websites or online service.

See the section above titled “Changes To This Privacy Policy” for a description of the process by which our company notifies consumers who use or visit our commercial websites or online service of material changes to our company’s privacy policy for this websites or online service.

The effective date of this Privacy Policy is listed above under the heading, “Last Updated.” For the purposes of this policy and California compliance the following definitions apply:

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Depending on your activity on our websites or online service, the following “personally identifiable information” may be collected, in addition to what is in prior sections of this document.

The term “personally identifiable information” means individually identifiable information about an individual consumer collected online via the Sites from an individual and maintained by us in an accessible form and may include any of the following:

(1) Afirstandlastname;
(2) Ahomeorotherphysicaladdress,includingstreetnameandnameofacityortown;
(3) Ane-mailaddress;
(4) A telephone number;
(5) Anyotheridentifierthatpermitsthephysicaloronlinecontactingofaspecificindividual;and
(6) Information concerning a user that the Sites collects online, from the user, and which is maintained inpersonally identifiable form, in combination with an identifier described within this Privacy Policy.

Under California Law SB 27, California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to legal@marcelamagdapopamd.com and please include the phrase “California Privacy Request” in the subject line, the domain name of the websites you are inquiring about, along with your name, address and e-mail address. We will respond to you within thirty (30) days of receiving such a request.

“Cookies” and How We Use Them

A “cookie” is a small data file that can be placed on your hard drive when you visit certain websites. The Sites may use cookies to collect, store, and sometimes track information for purposes stated earlier as well as for statistical purposes to improve the products and services we provide and to manage our telecommunications networks. We may also use cookies for purposes of personalizing your experience on the Sites, or for providing online behavioral advertising such a retargeting or remarketing. These uses provide you with additional opportunities to take advantage of our services or products, and provide us with additional opportunities to reach you with personalized offers more tailored to your interests.

Advertisers and partners may also use their own cookies (e.g. on their own Sites). We do not control any third party’s use of such cookies and we expressly disclaim responsibility for information collected by or through them.

Public Areas & Social Media: Any information you disclose in any public areas of our websites (if any) or the Internet, including via social media becomes public information. You should exercise caution when deciding to disclose personal information in these public areas. ————————————————————————————————————————

This Privacy Policy does not create any contractual or other legal rights in or on behalf of We or any other party and is not intended to create any such rights.

Questions about this Privacy Policy may be directed to us in writing at:

legal@marcelamagdapopamd.com

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via Mail:
Healthy Strategies,

PO Box 3144, Fort Lee, NJ, o7o24

Healthy Strategies Privacy Policy rev 1.2 021220