PRIVACY POLICY

Privacy Notice for Thrive With Dr. Esosa LLC

This Privacy Notice for Thrive With Dr. Esosa LLC ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Visit our website at https://www.thrivewithdresosa.com, or any website of ours that links to this Privacy Notice
Use Thrive With Dr. Esosa LLC, a health and wellness coaching service
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. We are responsible for making decisions about how your personal information is processed. If you disagree with our policies and practices, please do not use our Services. If you still have questions or concerns, please contact us at esosa@thrivewithdresosa.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

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 us and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information?
Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example, your racial or ethnic origins, sexual orientation, and religious beliefs.
Do we collect any information from third parties?
We do not collect any information from third parties.
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.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties.
How do we keep your information safe?
We have adequate organizational and technical processes and procedures in place to protect your personal 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.
How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request or by contacting us.

SUMMARY OF KEY POINTS
WHAT INFORMATION DO WE COLLECT?
- Personal Information Provided by You
- Sensitive Information
- Payment Data
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- Vendors, Consultants, and Other Third-Party Service Providers
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE KEEP YOUR INFORMATION SAFE?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- Sources of Personal Information
- How We Use and Share Personal Information
- How to Exercise Your Rights
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

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 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
mailing addresses
contact preferences
billing addresses
debit/credit card numbers
contact or authentication data
job titles

Sensitive Information
When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

health data

Payment Data
We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by Stripe and Get Healthie. You may find their privacy notice link(s) here:
Stripe Privacy Policy
Get Healthie Privacy Policy

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.

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:

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 or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

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 a 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 categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers
We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means:

They cannot do anything with your personal information unless we have instructed them to do so.
They will not share your personal information with any organization apart from us.
They commit to protect the data they hold on to our behalf and retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

Practice management platform and electronic health record

We also 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.

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 gather information when you interact with our Services. Some online tracking technologies help us:

Maintain the security of our Services
Prevent crashes
Fix bugs
Save your preferences
Assist with basic site functions

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including:

Managing and displaying advertisements
Tailoring advertisements to your interests
Sending abandoned shopping cart reminders (depending on your communication preferences)

These third parties and service providers use their technology to provide advertising about products and services tailored to your interests, which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under the section "DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?"

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include:

Remarketing with Google Analytics. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt-out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. 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 to keep your personal information for longer than 3 years.

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.

7. 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.

8. 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 collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. 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 the age of 18, please contact us at esosa@thrivewithdresosa.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or some regions, such as 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, depending on your country, province, or state of residence.

In some regions (like 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; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. 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 using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

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. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

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 section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. 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.

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.

If you have questions or comments about your privacy rights, you may email us at esosa@thrivewithdresosa.com.

10. 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.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring

DNT signals, we do not respond to them currently.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

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.
- Collected: YES
Personal Information (California Customer Records statute):
- Name, contact information, education, employment, employment history, and financial information.
- Collected: YES
Protected Classification Characteristics (state or federal law):
- Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data.
- Collected: YES
Commercial Information:
- Transaction information, purchase history, financial details, and payment information.
- Collected: YES
Biometric Information:
- Fingerprints and voiceprints.
- Collected: NO
Internet or Similar Network Activity:
- Browsing history, search history, online behavior, interest data, and interactions with websites, applications, systems, and advertisements.
- Collected: NO
Geolocation Data:
- Device location.
- Collected: NO
Audio, Electronic, Sensory, or Similar Information:
- Images and audio, video, or call recordings created in connection with business activities.
- Collected: NO
Professional or Employment-Related Information:
- Business contact details, job title, work history, and professional qualifications (e.g., if applying for a job).
- Collected: YES
Education Information:
- Student records and directory information.
- Collected: YES
Inferences Drawn from Personal Information:
- Profiles or summaries about individual preferences and characteristics based on collected data.
- Collected: YES
Sensitive Personal Information:
- Debit or credit card numbers, health data, national origin, racial or ethnic origin, and religious or philosophical beliefs.
- Collected: YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information.

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.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A - As long as the user has an account with us
Category B - As long as the user has an account with us
Category C - As long as the user has an account with us
Category D - As long as the user has an account with us
Category I - As long as the user has an account with us
Category J - As long as the user has an account with us
Category K - As long as the user has an account with us
Category L - As long as the user has an account with us

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

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. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be the "selling" of your personal information.

We have not sold or shared any personal information to third parties for business or commercial purposes in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

Category A. Identifiers
Category B. Personal information as defined in the California Customer Records law
Category C. Characteristics of protected classifications under state or federal law
Category D. Commercial information
Category I. Professional or employment-related information
Category J. Education information
Category K. Inferences drawn from collected personal information
Category L. Sensitive personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

Right to know whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request the deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to non-discrimination for exercising your rights
Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota's privacy law)
Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)
Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota's and Oregon's privacy law).

Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota's privacy law)
Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)
Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law).

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at esosa@thrivewithdresosa.com, or by referring to the contact details at the bottom of this document.

We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Under certain US state data protection laws, you can designate an authorized agent to request on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

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. We will only use personal information provided in your request to verify your identity or authority to make the request. 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.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at esosa@thrivewithdresosa.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

Financial Incentives

"Financial incentive" means a program, benefit, or other offering, including payments to consumers as compensation, for the disclosure, deletion, sale, or sharing of personal information.

The law permits financial incentives or a price or service difference if it is reasonably related to the value of the consumer's data. A business must be able to explain how the financial incentive, price or service difference is reasonably related to the value of the consumer's data. The explanation must include:

• a good faith estimate of the value of the consumer's data that forms the basis for offering the financial incentive or price or service difference; and

• a description of the method the business used to calculate the value of the consumer's data.

We may decide to offer a "bona fide loyalty program" under Colorado law, or a "financial incentive" under California law (e.g., price or service difference) in exchange for the retention, sale, or sharing of a consumer's personal information.

If we decide to offer a financial incentive, we will notify you of such financial incentive and explain the price difference, as well as material terms of the financial incentive or price of service difference, including the categories of personal information that are implicated by the financial incentive or price or service difference.

Under California law, the value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable program, less the expense related to offering those products, services, and benefits to program participants.

If you choose to participate in the financial incentive you can withdraw from the financial incentive at any time by emailing us at esosa@thrivewithdresosa.com, or by referring to the contact details at the bottom of this document.

California "Shine the Light" Law

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 by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12. 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 at the top of this Privacy Notice. 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.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at esosa@thrivewithdresosa.com or contact us by post at:

Thrive With Dr. Esosa LLC

1717 N ST NW.

Ste 1.

Washington, DC 20036

United States

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect about you, understand how it has been processed, correct inaccuracies, or request its deletion. You may also withdraw your consent to our processing of your personal information where applicable. These rights may be subject to certain limitations under applicable law. To exercise these rights, please contact us directly.