privacy policy

Privacy Policy – Naturalena Brands

Effective Date: October 1, 2020

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• Privacy and Security

• Collecting Personal Information About You

• Using and Disclosing Your Personal Information

• Access to Your Personal Information

• Correcting Your Personal Information

• Securing and Storing Your Personal Information

• How Your Personal Information May be Shared

• Cookies

• Third Party Ad Networks

• Changes To Our Privacy Policy

• Children under age of 13

• Important Notice for California Residents

• Do Not Sell

 

At Naturalena Brands (“we”, “us”, or “our” of “Naturalena”) we recognize that privacy is very important, and we greatly value the privacy of our customers and website users.  In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose personal information that we obtain about our customers and users of our websites (e.g., veedausa.com, Happy Little Campers) (“Site(s)”), and the services available through our Site (together, the Site and the services available therein are the “Services”).  This Policy also outlines your rights and choices with regard to the personal information collected about you. Applicable Terms. Your use of our Services, and any dispute over privacy, is subject to this Policy, the respective terms of use (the “Terms”), between you and Naturalena and any other relevant agreements, which are available.  The applicable Terms are incorporated by reference into this Policy, including their applicable limitations on liability and the resolution of disputes.  By disclosing your personal information to us or using our Services, you understand and agree that We may collect, use, and disclose your personal information in accordance with this Policy and the applicable Terms

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1. Information We Collect
   We generally collect information about you directly from you[, from third parties,], and automatically through your use of our Services as further described below.
   
   Information We Collect Directly From You.  The type of information that we collect from you depends on your interaction with our Services.  While you can browse most parts of our website freely, certain areas and features of our Services require you to register with us.   We may also ask or allow you to submit additional account information, such as your month and day of birth and phone number. You can also sign up to receive email newsletters and promotional offers from us by submitting your email address. 
   
   User Content. If you choose to engage in forums, blogs, or similar features and submit comments, ratings, reviews, or other content we maintain a copy of this content.  We may also collect certain information metadata associated with your content.  User content may also be viewable by other visitors and users of the Services. 
   
   Other Information We Collect Regarding Your Usage of Our Services. We collect information about your use of our Services, such as your order and subscription history and purchases. 
   
   Information We Collect About You from Third Parties. We may also collect information about you from third parties, which we append to the information we have collected.  For example, we may receive information about items in your online shopping cart from the third party who help us fulfil your subscription and purchases.  Or, we may receive your name and email address when someone refers you to us through our referral program. 
   
   Communications and support. If you contact us by email, mail, phone, or otherwise regarding the Services, we collect and maintain a record of your contact details, communications and our responses.  If you call us, we may also record calls and maintain logs and records of those calls. 
   
   Inquiries and requests.  We also collect personal information when you submit information to or request information from us or sign up for marketing and communications from us (such as related to Naturalena products, subscriptions, special offers and upcoming product releases). The information we may collect includes your name, contact information, and other information. 
   
   Other Information We Collect Automatically Through Our Services. We may also collect personal information about how you use the Services (e.g. using cookies and pixel tags), such as IP address, advertising ID, location information, browser type, device type, domain name, the website that led you to our Services, the website to which you go after leaving our Services, the dates and times you access our Services, and the links you click and your other activities within the Services.  We may also use pixels in HTML emails to understand if individuals read the emails, we send to them (“Usage Data”).  We may combine this information with other information that we have collected about you, including, where applicable, your name and other personal information. (For more information, see the Cookies and Other Tracking Information section below.)   
    

2. How We Use Your Information
   
   We process your information and content, including your personal information, for the following purposes:
   
   Providing and Improving Our Services. To provide and maintain our Services; to fulfil your orders, or otherwise to improve our Services; to develop new features, products, or services; to authenticate users; to perform technical operations, such as updating software; and for other customer service and support related purposes. 
   
   Communicating with You. To provide you with the information or services that you have requested; to communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes; and to administer surveys and questionnaires, such as for market research or user satisfaction purposes. 
   
   Personalizing Content and Ads. We may use the information we collect about you to personalize the information and content we display to you, including marketing, promotional and sponsored content, as well as providing you with more relevant ads. 
   
   Marketing and Communications. To communicate with you about your account and use of our Services via email, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Please see the Rights and Choices section further below for more information about how to change your communications preferences.
   
   Research and Analytics. To better understand how users access and use our Services and products, for other research and analytical purposes, such as to evaluate and improve our Services and business operations, develop new features, products, or services, to otherwise improve our Services and user experiences, and for other research, analytical, and statistical purposes.
   
   In Support of Our General Business Operations. Relating to audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions.  These purposes are based on our legitimate interest in operating our business and maintaining adequate internal records and safeguards.
   
   Securing and Protecting Our Assets and Rights. To protect our business operations, secure our network and information technology, assets and services; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend our legal interests and rights. 
   
   Complying with Legal Obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
   
   We may also use your personal information for other purposes, where you have consented. 
   
   Aggregate and De-identified Information.  We may also use aggregate and de-identified information for various research, development, product improvement, analytics and other purposes.
    

3. How We Disclose Personal Information
   
   We may share or disclose the information (including personal information) that we collect as follows:
   
   Subsidiaries and Affiliates.  With our affiliated companies (i.e., our parent company and other companies under common ownership, control or management with us); their use and disclosure of such personal information is subject to this Policy.
   
   Service providers. With our third-party service providers who use this information to perform services on our behalf, such as hosting providers, payment providers, auditors, advisors, consultants, customer service and/or support providers.
   
   Third Parties. With third parties that provide advertising, campaign measurement, online and/or mobile analytics and related services.  These third parties may receive or access browsing history and/or other data about your use of the Sites, in order to help us better reach individuals with relevant ads, measure our ad campaigns and/or to better understand how individuals interact with our Sites over time and across devices.   
   
   Legal Compliance.  In response to a valid court order, subpoena, government investigation, or as otherwise required by law.  We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.  
   
   Business Transfers. As part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law. 
   
   Protection of Rights. Where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, to protect the rights, property or safety of Naturalena, our affiliates, clients, customers and/or others, and/or as evidence in litigation in which we are involved.
   
   Aggregated and De-identified Data.  We may share aggregate or de-identified information with third parties for research, marketing, advertising, analytics and/or other purposes. 
    

4. Cookies and Tracking Information
   
   We and our third-party provider, Mute6, uses cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Sites and other Services.   
   
   Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes.  Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site.  Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future.  The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.  Some of the Services may not work properly if you disable cookies.
   
   Pixel Tags. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies.  In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages.  We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services.  We may also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
   
   Preference.  You can block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our Sites may not be available or function properly if you block or disable cookies. Our Sites currently do not respond to “do not track” signals. 
    

5. Interest Based Advertising
   
   We may work with third-party ad networks, channel partners, measurement services and others (“third party ad companies”) to display advertising on our Services, and to manage our advertising on third-party sites, and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to improve and evaluate such ads and content.  
   
   Ad Choices. You can learn more about the information collection practices and "opt-out" procedures of many third-party ad companies by visitingwww.networkadvertising.org/optout_nonppii.asp.   Opting out of participating ad networks does not opt you out of being served advertising.  You may continue to receive generic or “contextual” ads on our Services.  You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs. 
    

6. Third-Party Sites and Services
   
   Our Services may link to other websites or online services (including those operated by our parent, affiliates, or others) that are not covered by this Policy.  Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites.  We are not responsible for the information practices of such third-party websites. 
    

7. Security
   
   We have implemented safeguards designed to protect the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction.  Please be aware that despite our efforts, no data security measures can guarantee security. 
    

8. Rights and Choices
   
   In this section we describe the choices you have regarding our collection, use and handling of your personal information. 
   
   Access and Update Information. You may access, update, and delete certain of your personal information by accessing and adjusting your account settings.  You may also contact us using the information in the Contact Us section below to make an access, correction or other privacy request.  Please note that we may maintain copies of information that you have updated, modified or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law.  For example, if you request that we delete your information, but we believe that you have violated our Terms, we may retain information about you in order to attempt to resolve the issue before deleting it.  Your access to or correction of your personal information is subject to applicable legal restrictions and the availability of such information.  Further, we may take reasonable steps to verify your identity before granting such access or making corrections.  
   
   Marketing Communications.  You may opt-out of receiving email marketing communications from us by using the unsubscribe link in any such email we send to you.  Or alternatively, by emailing your request to info@naturalenabrands.com.  Please note that we may still send you transactional emails, such as emails related to your account or subscriptions.
   
   Third-Party Ads and Cookies. As noted above, you can control your cookie preferences on our Sites and opt out of most third-party advertising tags and cookies on our Sites.
    

9. Children
   
   Our Services are not targeted and directed at children under thirteen years of age (13) and we do not knowingly collect any personal information from a child under 13.  If you believe we have inadvertently collected personal information about a child, please contact us and we will take steps to delete this information.  
    

10. Shine-The-Light
    
    Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us their personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use; such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year (e.g., requests submitted in 2020 would be applicable to relevant disclosures (if any) in 2019). If you are a California resident and would like to make such a request, please submit your request in writing by emailing us at info@naturalenabrands.com, using the subject line "Request for California Privacy Information." In your request, please attest to the fact that you are a California resident and provide a current California address.  We will reply to valid requests by sending a response to the email address from which you submitted your request.  Please note that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.
     

11. Contact Us
    
    If you have any questions about this Policy or our privacy practices, please contact us at:
    Email us:    info@naturalenabrands.com
    Fax: +1 650 532 9340
    Post: The Privacy Officer, 17951 Sky Park Circle(Bldg.35/Suite K), Irvine, CA 92614
    
    This Policy is current as of the Effective Date set forth above.  We may change this Policy from time to time, so please be sure to check back periodically.  We will post any changes to this Policy on our Services.  If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Services. 

ADDITIONAL IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
 

Under the California Consumer Privacy Act (“CCPA”), we are required to notify California consumers about our collection, use, and disclosure of their personal information.   In accordance with the CCPA, “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

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Categories of Personal Information that We Collect, Disclose, and Sell 

Below please find the categories of personal information about California residents that we collect, sell, and/or disclose to third parties or service providers for a business purpose.  

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Categories of personal information 

Last Updated: [ October 1, 2020]

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NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

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Do we collect? YES

Do we disclose for business purpose? YES

Do we sell? NO

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CUSTOMER RECORDS: Paper and electronic customer records containing personal information, such as name, address, email address, telephone or telephone number. 

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Do we collect? YES

Do we disclose for business purpose? YES

Do we sell? NO

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PURCHASE HISTORY AND TENDENCIES:  Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

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Do we collect? YES

Do we disclose for business purpose? YES

Do we sell? NO

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USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.

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Do we collect? YES

Do we disclose for business purpose? YES

Do we sell? NO

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GEOLOCATION DATA: Precise geographic location information about a particular individual or device

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Do we collect? YES

Do we disclose for business purpose? YES

Do we sell? NO

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EMPLOYMENT HISTORY: Professional or employment-related information.

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Do we collect? NO

Do we disclose for business purpose? NO

Do we sell? NO

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PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

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Do we collect? YES

Do we disclose for business purpose? YES

Do we sell? NO

 

Purposes for Collecting and Using Personal Information

Generally, we may use the above categories of personal information for the following purposes:

 

• To provide our Services to you and to fulfill your orders.

• To communicate with you about your use of our Services, to respond to your inquiries, and for other customer service purposes. 

• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services.

• To send you email marketing about our products and services. 

• To send you news and newsletters.

• To send you email marketing about products and services of our affiliated entities. 

• To assist us in advertising on third-party websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through third-party channels (including our online targeted advertising and offline promotional campaigns).

• To better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Site are more (or least) used by users, and we will use this information. 

• To conduct internal analysis of outreach and marketing efforts, as well as for market research or member satisfaction purposes. 

• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.

• Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

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• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where we need to comply with a legal or regulatory obligation.

• Where it is in our legitimate interests, including our commercial interests in operating the Naturalena  customer facing platform. We make sure that we consider and balance any potential negative impact on you and your rights before we process your personal data.

 

California Residents’ Rights

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.

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Do-Not-Sell. 

California residents have the right to opt-out of our sale of their personal information.  Other than through cookies, we do not sell your personal information to third parties.  Please refer to section 4, for more information about our cookies practices.  

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Verifiable Requests for Copy, Deletion and Right to Know.

Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months. Please see section on Submitting Requests for instructions about how to exercise your rights:

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Deletion: The right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary that we maintain such personal information in order to: 

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• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

• Debug to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.

• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.

• Comply with a legal obligation.

• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

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Copy: The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months.

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Right to Know (Collection): Where we have collected their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling their personal information; and the categories of third parties/with whom we have disclosed or shared their personal information.

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Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.

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Submitting Requests. You may exercise your rights by doing one of the:

• Contacting us at 800-927-8260 (toll free) .

• Emailing us at [info@naturalenabrands.com]

We will respond to your Copy and Right to Know requests within 45 days, unless additional time (up to 45 more days) is needed, in which case we will let you know. 

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When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you have set up an account on our website, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request when we are satisfied that we have verified your identity to a reasonably degree of certainty. 

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Authorized Agents. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA.  

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Incentives and Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.  

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Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.

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Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, residents have the right to be notified of any financial incentives offers and their material terms, the right not be included in such offers without prior informed opt-in consent, and the right to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. 

 

California Privacy Rights under California’s Shine-the-Light Law 

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use.  Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing to info@naturalenabrands.com. The request should attest to the fact that the requester is a California resident, and provide a current California address.   

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This privacy notice was last updated on October 1, 2020.