Who We Are & How To Contact Us
Fos, Inc. is the Controller (for purposes of the GDPR) of your Personal Data (as such term is defined below). Our address is: [address to be updated]. The Fos group of companies is made up of different legal entities, including one based in the Cayman Islands, called Fos International, Inc. With respect to privacy or data issues you can contact us at email@example.com.
Explanation of Service
We manufacture, distribute and sell health-orientated products and dietary supplements including, without limitation, our Fos brand. Our products may be purchased on a one-time or subscription basis, either directly from us or through one or more of our resellers, distributors or marketing affiliates.
Privacy Shield Commitment
Personal vs. Non-Personal Data
- Personal Data:
We collect Personal Data from you, which data may include data received from within the European Union. “Personal Data” means any information relating to an identified or identifiable natural person. Examples of this kind of information include, as applicable, your name, organization name, email address, phone number, billing address, mailing address, credit card and payment details (which are collected and stored for recurring subscriptions), and other similar kinds of information that may be used for the same purpose. Fos will not rent or sell your Personal Data to others. We may store Personal Data in locations outside the direct control of Fos (for instance, on servers or databases co-located with hosting providers including, without limitation, Limelight, Shopify, Recharge, MCS fulfillment, Five9, Zendesk, Klaviyo, Stripe, Braintree, PayPal, Refersion, FlexPay and Hallmark fulfillment services (“Hosting Providers”). Fos’s Hosting Providers may physically have servers located anywhere in the world (i.e. including outside the European Union). Any Personal Data you elect to make publicly available on our Sites or through the Service, such as posting comments on a blog page, will be available to others. If you remove information that you have made public on our Sites or through the Service, copies may remain viewable in cached and archived pages of our Sites or the Fos Service, or if other users have copied or saved that information. If you wish to post a comment on our blog, registration may be required.
- Non-Personal Data:
We may gather and share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, IP address, browser and platform types, referring/exit pages, operating system number of clicks, etc.) with interested third parties to help them understand the usage patterns of Fos’s Service and those of our partners and affiliates. If you remove information that you have made public through the Fos Service or Sites, copies may remain viewable in cached and archived pages of the Fos Service or Sites, or if other users have copied or saved that information. Non-Personal Data may be stored indefinitely.
Use of Information
We use information that we collect in a variety of ways in providing our Service and operating our business, including, with respect to operations, improvements and communications. Such uses include facilitating the functioning of our business and Sites, complying with applicable law, providing you with products and services, or as otherwise as appropriate in connection with a legitimate business need, including, without limitation:
- enabling, providing and enhancing the efficacy of Fos’s Sites, products, or services (including the Service and for any other purposes as may be further set forth in agreements between Fos and its customers, including acting as a data processor on behalf of its customers to the extent such customers act as data controllers);
- customer service activities (including via email and telephone), including administering your account, processing / fulfilling / confirming orders, billing, providing technical support, responding to your requests, providing updates, and customizing, enhancing, upgrading and improving our Sites, products, services and offerings;
- sales, marketing and promotional activities (including sales tracking, affiliate tracking, and administering contests), and customer relationship management (including newsletters, notices and sending you requested product or service information); and
internal business processes and management, analysis (including usage trends and preferences), crime/fraud detection and prevention, security, protecting Fos’s legal rights, and compliance with governmental, legislative, and regulatory requirements.
California residents may have additional personal information rights and choices. Please see the section entitled “Your California Privacy Rights” below for more information.
Choice / Opt-Out
You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at firstname.lastname@example.org .
We will share your Personal Data with third parties only in the ways that are described in this privacy statement. We may provide your Personal Data to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your Personal Data only as necessary to provide these services to us.
We may also disclose your Personal Data
- as required by law such as to comply with a subpoena, or similar legal process;
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
- if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our site(s) of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your Personal Data;
- to any other third party with your prior consent to do so.
Non-personally identifiable information may be provided to other parties for marketing, advertising, or other uses.
Storage and Processing.
As set forth in more detail above, but subject to appropriate safeguards: (i) your information collected through the Fos Service may be stored and processed anywhere in the world (including, without limitation, in the United States, Europe, or any other country in which Fos or its subsidiaries, affiliates or service providers maintain facilities), and (ii) Fos may transfer information that we collect about you, including Personal Data, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
How We Protect Your Information.
The security of your Personal Data is important to us. But while Fos is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to Fos or guarantee that your information on the Fos Service may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive information (such as log in credentials or credit card numbers) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). No method of transmission over the Internet or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at email@example.com . We may use an outside help platform, and a credit card processing company to bill you if you purchase Services. These companies do not retain, share, store or use Personal Data for any other purposes.
You shouldn’t install any specific software to use Fos’s Services, and our Site pages don’t install any software to your system. If you have any questions about security on our Sites, you can contact us at firstname.lastname@example.org .
Federal Trade Commission.
Subject to approval of the Privacy Shield Application (i) we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). and (ii) we may be required to disclose Personal Data that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Cookies and Other Tracking Technologies
We may use other companies to place cookies on your computer to collect non-Personal Data to compile aggregated statistics for us about visitors to our site.
Our web pages may contain electronic images known as web beacons (sometimes called single-pixel gifs) which may be used along with cookies to compile aggregated statistics to analyze how our site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.
Our web pages may also contain electronic images known as web beacons (sometimes called single-pixel gifs) that are set by our third-party partners. Web beacons may be used along with cookies enabling our partners to compile aggregated statistics to analyze how our site is used.
Cross Border Transfer
Certain Personal Data may be subject to our more specific privacy policies, which are also consistent with the requirements of the EU-U.S. and EU-Switzerland Privacy Shield Frameworks.
Your Choices – Access, Correction & Deletion
We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. If you wish to access or amend any other Personal Data we hold about you, or to request that we delete or transfer any information about you that we have obtained from an Integrated Service, you may contact us as set forth in the “Contact Us” section below. At your request, we will have any reference to you deleted or blocked in our database.
You may also update, correct, or delete your account information and preferences at any time by contacting us as set forth in the “Contact Us” section below. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
You may decline to share certain Personal Data with us, in which case we may not be able to provide to you with our Service, including, without limitation, the products that we sell.
At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Fos’s Data Protection Officer at email@example.com . You also have a right to lodge a complaint with data protection authorities.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit CCPA Privacy Notice for California Residents.
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
Do Not Sell My Personal Information
We will not sell your personal information. California law requires that, to the extent we sell your personal information, we maintain a separate webpage that allows you to opt out of the sale of your personal information, which can be accessed by clicking the link below: https://www.fos.co/DNSMPI
We only retain the Personal Data collected from you for a limited period of time as long as we need it to fulfill the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
- unless you request otherwise, we keep your contact details for our future marketing and customer retargeting campaigns;
- backups are kept for twelve (12) months;
- billing information is retained for a period of seven (7) years as of their provision to Fos in accordance with applicable accounting and taxation laws;
- information on legal transactions between you and Fos is retained for a period of seven (7) years as of their provision to Fos in accordance with the general limitation period set for civil claims in applicable law.
Correcting and Updating Your Personal Data
To review and update your Personal Data to ensure it is accurate, contact us at email@example.com .
Notification of Privacy Statement Changes
We may update this privacy statement to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Under certain conditions, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
You can contact us by writing or email us at the address below:
Attn: Data Protection Officer
[to be updated]
Email for General Support: firstname.lastname@example.org
Email for Privacy Issues: email@example.com