Privacy

Malouf VIP Privacy Notice
CVB, Inc., a Utah Benefit Corporation

Malouf VIP strives to provide quality health/wellness products and services at discounted pricing. This Privacy Notice applies to personal information we collect in connection with the products and services we offer, and the Notice describes how and why we collect, use, and share the personal information relating to our websites, other online platforms, and customer service.

By using our websites, social media, or customer service, you agree to our processing of personal information for the purposes stated in this Notice. If you do not agree with our collection, use, or sharing of personal information, please do not use the site or our applications.

From time to time, Malouf VIP may offer new services. New services will be subject to this notice unless the services change the way we collect, use, or share your personal information. If the new services change our privacy practices, we will update this notice.

For purposes of this Notice, we use the terms “Company,” “we,” “us,” and “our,” or similar terms, when referring to Malouf VIP.

Privacy Notice Contents

Information Collected

Personal information is information that can be used to identify you directly or indirectly. Personal information is collected to provide our users a quality, customized experience. You are not required to provide Malouf VIP with any requested information; however, many products or services may not be available if we do not collect specific personal information elements. With the exception of payment information, we avoid the collection of sensitive personal information.

You may adjust your browser to limit or refuse cookies or to alert you when cookies are being sent. If you disable cookies, however, the full functionality of some our webpages may not be available to you.

Direct Collection

The Company collects the personal information you voluntarily disclose when you interact with our services, e.g., create an account, request information, contact us, download software, participate in promotional communications, or purchase products and services through our platform. The types of personal information requested will relate to the purpose of its collection. Examples of requested information may be grouped into the following categories:

  • Identifiers and Contact Information: first name, last name, title, username, password, mailing and billing addresses, email address, phone numbers, contact preferences
  • Financial and Transactional Information: payment (card or bank) information, products or services purchase information, delivery information, purchase history, feedback, requests, survey responses

Indirect Collection

The Company has a legitimate interest in understanding how consumers use its website and mobile applications. We may collect certain information automatically through the use of Cookies and/or Internet Protocol (“IP”) address tracking. In general, this information is used to deliver and optimize online content, personalize content, enable faster checkout, and/or recognize you across multiple devices.

Examples of requested information may be grouped into the following categories:

  • Technical Information: information relating to your login, browser and browser plugins, operating system, platform, internet service provider, internet protocol (IP) address, time zone, other necessary website accessing technologies
  • Usage Information: Use and journey through websites and applications

As part of the Usage Information, personal information may be collected through third parties. This information may be collected by related business partners, social media sites, marketing platforms, other of our affiliates, companies that provide supplemental information about you (e.g., data aggregators), ad-tech companies, and others (family, friends) who provide us your personal information, as they share a product, service, or promotion with you.

We may utilize Google Analytics, a web analysis service, to better understand your use of and journey through our websites, applications, and services. Google Analytics collects and reports information such as how often users visit a website, what pages they visit, and what other sites they previously visited. Google uses the data collected to track and examine the use of the websites, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the websites to contextualize and personalize the ads of its own advertising network. Google's ability to use and share information collected by Google Analytics about your visits to the Websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. To opt out of the Google Analytics advertising features outlined above, follow the instructions at Google Analytics Opt-Out.Facebook Pixel and HotJar may also be utilized as analysis and feedback tools.

Information Sharing and Use

We may share some or all of your personal information within our organization, including with our affiliates, and with our third-party service providers for the benefit of our organization, including affiliates, and will use the information in a manner consistent with this Privacy Notice. We will not share your information with any third party outside of our organization, other than the service providers who are necessary to comply with a law or fulfill your request, e.g., payment platforms, product delivery, in connection with enhancing user experience, improving product recommendations, or performing analytics data review. We may engage such third-party service providers in connection with these efforts on behalf of our organization and affiliate organizations. We do not allow our service providers to use your personal information other than to process your information for its specific purpose(s).

The Company uses and shares your personal information only for specific and limited business purposes. For example, information may be used by our organization or shared with third-party contractors who perform services for us or our affiliates to

  • Communicate information
  • Personalize and improve services
  • Understand user interests
  • Handle and answer inquiries
  • Authenticate the identity of individuals
  • Process a purchase or transaction
  • Process payments
  • Process returns or warranty claims
  • Perform contractual agreements
  • Comply with legal or regulatory obligations
  • Perform a related business operation
  • Control information
  • Improve the functionality of our websites
  • Understand and assess the interests of consumers
  • Provide product recommendations and targeted advertising
  • Measure advertising effectiveness
  • Secure online processes
  • Data Analytics

Legitimate interest for processing your personal information may be used, for example, to assist in the performance of a service, contract, or to improve a service. It will be limited to the purpose of achieving the legitimate interest. We assure you that if legitimate interest is used as a ground for processing your personal information, we will keep a record of this, and you have the right to ask for this information. This ground does not outweigh your rights as an individual and will be limited to purposes of achieving a legitimate interest.

We also may process or disclose your personal information in the performance of a contract as well as when we have a legal or regulatory obligation, e.g., official investigations, tax obligations, financial reporting. For example, a court order or a subpoena may require us to process personal information for a particular purpose.

Unless you ask us not to, we may contact you via email in the future to tell you about specials, new products or services, or changes to this Privacy Notice.

California residents may review our California Privacy Notice for additional information sharing and use disclosures.

Microsoft may collect or receive Personal Data from you (with your permission based on cookie acceptance) to provide Microsoft Advertising, for a full understanding of how this information is used please visit the Microsoft Privacy Statements:  https://privacy.microsoft.com/en-us/privacystatement.

Profile and Automated Decisions

Your personal information may be analyzed to build online searching and buying behaviors profiles. This helps us better understand your interactions with our brand communications.

In addition, the Company processes some personal data using automated means, where no human decision-making is involved, such as the collection, use, and sharing of your personal information for the following: payment processing, order status updating, promotions, subscriptions, and targeted advertising.

Children Under 13

The Company does not design our websites to appeal to children, nor are they directed at children under 13. We do not knowingly collect personally identifiable information from persons under the age of 13, and we strive to comply with the provisions of COPPA (The Children's Online Privacy Protection Act). If you are a parent of a child under 13, and you believe that your child has provided us with information about themselves, please contact us at legal@maloufcompanies.com.

Storage and Retention

Personal information is retained to provide quality services such as a product guarantees, warranty services, financial obligations, etc. If you live outside the United States (U.S.), you understand and agree that your personal information will be transferred to and stored in the U.S. EU Customers: We must inform you that there are risks associated with data transfers, and we rely on derogations for specific situations, GDPR Article 49.

Personal information is kept one year after Malouf VIP is released of all legal, financial, and reporting retention requirements.

Information Protection

Your personal information is important to us, and we will take reasonable and appropriate measures to protect your information. Although we cannot guarantee the security of your personal information, we implement technical, administrative, and physical controls to protect your information from unauthorized disclosures, misuse, or modification. These controls include restrictive access controls, vulnerability management, incident management, and employee training. Moreover, we expect the same level of data protection from the external third parties with whom we share your personal information.

To further the reduce the risk to your personal information, we encourage you to protect your UserIDs and Passwords and to always use caution with your online interactions.

Information Choices

With very few exceptions, you have choices regarding your personal information. You have the right to

  • View the personal information we have collected
  • Access a copy of your personal information in portable format
  • Edit or correct any personal information
  • Delete any personal information
  • Restrict the collection or processing of certain personal information
  • Restrict the use of your sensitive personal information
  • Restrict the storage of your information longer than necessary

You may also opt-out of our marketing communications. Please understand you will continue to receive non-marketing or transactional messages from us, such as account messages and inquiry responses.

Additionally, you may opt out of any future contact with us or exercise your data rights by contacting us via the following methods at any time:

Email address: hello@maloufvip.com

Toll-Free Phone Number: +1 888.829.9083

The Company will not discriminate consumers exercising one or more of these rights.

Do Not Track

We do not respond to or honor “Do Not Track” signals or similar mechanisms transmitted by web browsers.

California Residents

See our California Privacy Notice

Linked Websites

Lastly, for your convenience, links to external party websites may be provided on our webpages or applications. This Privacy Notice does not apply to, and we are not responsible for, the privacy practices of any external companies or organizations that we do not own or control. Therefore, you are encouraged to read the privacy notices of each linked site.

This Privacy Notice was last updated February 2023. Please check periodically for updates.

For additional information, please see our Website Terms of Use.

VIRGINIA RESIDENTS

This Notice for Virginia residents supplements the information contained in the Privacy Policy to qualifying residents under the Virginia Consumer Data Protection Act (“VCDPA”).

Under the VCDPA, “Personal Data” means any information that is linked or reasonably linked to an identified or identifiable natural person, not including de-identified data or publicly available information.

Virginia

  1. Confirm what Personal Data is being process;

  2. Request access to the Personal Data we collect;

  3. Obtain a portable copy of your Personal Data;

  4. Delete Personal Data we have collected;

  5. Correct inaccuracies and rectify Personal Data we have collected;

  6. Opt-out of the sale of Personal Data;

  7. Opt-out of targeted advertising; and

  8. Appeal Personal Data right decisions.

residents may exercise the following rights with respect to their Personal Data:

Virginia

Malouf VIP California Privacy Notice

CVB, Inc., a Utah Benefit Corporation

This Notice for California residents supplements the information contained in the Privacy Policy to qualifying residents under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, “CCPA”). The Notice explains our privacy practices as they apply to “Consumers” as defined by the CCPA and does not extend to individuals who are not defined under the CCPA.

Under the CCPA, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, not including publicly available information or de-identified or aggregate consumer information.

Consumer Privacy Rights

Under the CCPA, California consumers have the following rights:

If you make a request for access to your personal information, the Company will disclose your records covering the 12-month period preceding the date of your request. Any request submitted is subject to an identification and verification process, which will depend on the nature of the request and the sensitivity of the personal information requested. For the safety and security of consumer information, we will not fulfill your CCPA request unless you provide adequate information to convince us that you are the consumer about whom we collected the personal information. Authorized agents who met the agency requirements of the CCPA may also submit requests on your behalf. See Verification requirements below.

To exercise your rights under the CCPA, we provide both an email address and a toll-free phone number (below) to submit your request. Please respond promptly to any follow up inquires, so we may process your request within the designated period.

Email address: hello@maloufvip.com

Toll-Free Phone Number: +1 888.829.9083

Additional Request Information: The Company will provide you with your personal information for the 12-month period preceding your request. A request receipt will be sent to you within 10 business days, and we will make efforts to respond to verified request within 45 calendar days of our receipt of your request. If we are unable to verify your request or if we require more time (up to 45 additional days) to grant the request, we will inform you in writing or by phone.

California consumers may only make requests to know or access their personal information twice within a 12-month period. The format is available in a transportable copy.

Consumer Verification

Prior to our fulfillment of a right to know or a right to delete request as described, below, Malouf VIP will require consumers to verify their identity. We will require verification of the consumer whether the consumer submits such a right to know or a right to delete request directly or through an authorized agent.

The minimum requirements for consumer verification follow:

  • First, Middle (if available), and Last Name
  • Physical California address
  • Valid email address
  • Valid phone number

For a right to know or a right to delete request submitted through the Company's toll-free phone number, a company representative will call you to administer an identity authentication process.

If we are unable to successfully verify your identity, we will be unable to fulfill your requests to know or for deletion. If this is the case, you will be notified and directed to read the Malouf VIP Privacy Notice concerning our data collection, sale, and disclosure practices.

As mentioned, the CCPA allows California consumers to use “authorized agents” to submit requests on the consumers' behalf to our company. If you choose to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any authorized agent requests.

For the safety and security of consumer information, requests for the right to know or a right to delete submitted by an authorized agent will require a direct method of communication with the consumer, preferably a valid email address, to fulfill the request.

All authorized agents will be required to successfully establish the minimum requirements for qualification as stated in the consumer verification minimum requirements list above. They will be required to establish the requirements prior to being authorized to submit requests on behalf of a consumer.

Agent Authorization Verification

In order to qualify as an authorized agent, businesses or individuals will be required to submit the following documentation:

Businesses. If you are operating as a business, the following documentation is required:

  • Certificate of good standing with your state of incorporation;
  • Written authorization document that includes each consumer's name, address, telephone number and valid email address, signed and dated by each consumer authorizing you, as the authorized agent, to act on behalf of each consumer in making the request. Proof of written consumer consent for opt-out requests are generally not required, unless the Company must confirm authorization; and
  • Valid consumer email address for our direct correspondence with each consumer, including an identity verification process to be conducted by our Company directly with that consumer.

Individuals. If you are an individual and acting as an authorized agent on behalf of a consumer, the following documentation is required:

  • A “power of attorney” signed and dated by the consumer and notarized by a notary public naming you as the consumer's authorized representative, which includes the consumer's full name and physical California address;
  • If you do not have a power of attorney signed by the consumer, then we require a written authorization document that includes the consumer’s name, address, telephone number and valid email address, signed by the consumer authorizing you, as the authorized agent, to act on behalf of the consumer in making the request; and
  • Valid email address for direct correspondence with the consumer, including an identity verification process to be conducted by our Company directly with that consumer.

Parent/Guardian of Minor Child. Our Company does not knowingly collect or sell information about minors. If you are a parent or guardian of a minor child under 16 and would like to make a request for a right to know or right to delete on behalf of the minor child, the following documentation will be required:

The minor's verification documents, which includes the following:

  • Certified school record or transcript or home school notice of intent form that includes minor's permanent address
  • Proof of parental/guardianship identity document that matches the minor's permanent residence

Right to Know

You may request that our company disclose what personal information we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that information. Specifically, you may request

  • The categories of personal information collected
  • Specific pieces of personal information collected
  • The categories of sources from which the business collected personal information
  • The purposes for which the business uses the personal information
  • The categories of third parties with whom the business shares the personal information
  • The categories of information that the business sells or discloses to third parties

We will provide you this information for the 12-month period preceding your request.

Right to request deletion

You may request that our company delete personal information that we and our service providers collected from you. For reasons outlined in Civil Code sections 1798.105(d) and 1798.145, a deletion request may not be granted. Common reasons that we must retain your personal information include:

Your request cannot be verified

To complete your transaction, provide a reasonably anticipated product or service, or for certain warranty and product recall purposes

For certain business security practices

For certain internal uses that are compatible with reasonable consumer expectations or the context in which the information was provided

To comply with legal obligations, exercise legal claims or rights, or defend legal claims

If the personal information is certain medical information, consumer credit reporting information, or other types of information exempt from the CCPA

Right to opt-out of sale of personal information

(DO NOT SELL MY INFORMATION)

The CCPA defines the term “sell” broadly. Under the definition, we may sell your personal information. Over the past 12 months, we may have sold the following categories of personal information:

  • Identifiers/Contact Information - name, billing address, mailing address, email address, username, identification number, phone number(s), device cookies
  • Commercial Information/Account Details - purchasing history, purchase tendencies
  • Internet Usage Information - login information, device operating system, browser type, browser version, browser plug-ins, time zone setting, interactions with our website, computer systems, and devices
  • Inferences from Personal Information - customer profiles, customer preferences

You may request that our Company stops selling your personal information (“opt-out”). With some exceptions, we will not sell your personal information after receiving your opt-out request unless you later provide authorization allowing us to do so again.

Right to Non-Discrimination

The Company will not deny goods or services, charge you a different price, or provide a different level or quality of goods or services to consumers who exercise their rights under the CCPA.

Under CCPA, we may offer you reasonable promotions, discounts, and other incentives in exchange for collecting, keeping, or selling your personal information.

Minors

The Company does not design our websites to appeal to children, nor are the websites directed at children under the age of 13. Therefore, we do not knowingly collect or sell the personally information from persons under the age of 13. If you are a parent of a child under 13, and you believe that your child has provided us with information about themselves, please contact us.

Pursuant to the CCPA, we clearly understand that we can only sell the personal information of a child that they know to be under the age of 16 if they get affirmative authorization (“opt-in”) for the sale of the child's personal information. For children under the age of 13, that opt-in must come from the child's parent or guardian. For children who are at least 13 years old but under the age of 16, the opt-in can come from the child.

Financial Incentives

Financial incentive programs require consumers to opt-in to participate. Infrequently, we may offer financial incentives in the form of VIP Membership, discounted products, contests, promotions, advanced notices of new products or of product sales. The incentives are available to consumers who opt-in to our Company marketing materials, allowing us access to personal information such as first name, last name, postal address, email address, and internet/electronic activity.

The purpose of the incentives is to encourage consumers to fully experience our websites, products, and related services. The information collected as part of the incentives, in turn, help us improve the customer experience, as well as understand consumer buying and spending habits.

When offered, you may opt-in to participate in incentives by clicking “Accept” or by checking the opt-in box. Consent may be revoked at any time by emailing or calling our toll-free phone number:

Email address: hello@maloufvip.com

Toll-Free Phone Number: +1 888.829.9083

SHINE THE LIGHT

This Notice for California residents supplements the information contained in the Privacy Policy to qualifying residents under California’s Shine the Light law (“Shine the Light”).

Under Shine the Light, California residents may request information about our collection and sharing of your personal information, if any, with third parties for their own marketing purposes.

California residents may exercise this right once per calendar year by contacting us at:

This California Privacy Notice was last updated February 2023. Please check periodically for updates