Last Updated: June 30, 2023
Thank you for visiting the Nava MD™ website located at NavaMD.com (the “Site”). The Site is an Internet property of LifeMD, Inc. (collectively, “Nava MD™” “we,” “our” or “us”). This Nava MD™ Privacy Policy (“Privacy Policy”) covers our treatment of personal information and other information that we collect when end-users (“user,” “you” or “your”): (a) access or use the Site; (b) access and/or download any of the: (i) blog posts, text, audio, video, photographs, graphics, artwork, testimonials and/or other content featured on the Site, including skincare-related content (collectively, “Informational Content”); and/or (ii) links to third party websites, products and/or services (“Third-Party Links,” and together with the Informational Content, the “Content”); (c) access links to NavaMD'sTM™ social media pages/accounts (collectively, “Social Media Pages”) on third-party social media websites, such as Facebook®, Instagram® and Twitter® (“Social Media Websites”); (d) access certain product review sections, message boards, comments sections, customer ratings and other interactive features of the Site (collectively, “Interactive Services”); (e) register to receive the Nava MD™ e-mail newsletter (“Newsletter”); (f) purchase any of non-prescription creams, lotions, foams, sprays, liquids, face treatments, medications, or skincare treatment-related items made available by and through the Site(collectively, the “NavaMD Products”) as provided by Nava MD™; (g) purchase prescription medications via the Site (“Prescription Medications,” and together with the Nava MD™ Nonprescription Products, the “Products”), as same are prescribed by certain third-party licensed medical providers (“Healthcare Providers”) that provide telemedicine-related services in connection with the Site (“Telemedicine Services”); and/or (h) utilize the various contact forms and/or contact information made available on the Site as a means to contact directly, or request to be contacted by, Nava MD™ (collectively, the “Contact Services,” and together with the Site, Content, Social Media Pages, Nava MD™ Nonprescription Products, Newsletter, Prescription Medications and Telemedicine Services, the “Site Offerings”). Please note, if you are a resident of a European Union Member State, you are not permitted to use the Site and/or Site Offerings.
Users with disabilities who wish to access this Privacy Policy in an alternative format can contact us by e-mailing us at: [email protected]; by calling us at: (866)-483-8644; or by sending us U.S. Mail to: LifeMD, Inc. (d/b/a Nava MD™), 800 Third Avenue, Suite 2800, New York, NY 10022.
Capitalized terms not defined herein shall have the meanings set forth in the Nava MD™ Website Terms and Conditions (“Terms and Conditions”). IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE OFFERINGS.
Instagram® and Facebook® are registered trademarks of Facebook, Inc. (“Facebook”). Twitter® is a registered trademark of Twitter, Inc. (“Twitter”). Please be advised that Nava MD™ is not in any way affiliated with Facebook or Twitter, nor are the Site Offerings endorsed, administered or sponsored by any of the aforementioned entities.
Shine the Light. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please e-mail us at: [email protected]; call us at: (866)-483-8644; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Nava MD™), 800 Third Avenue, Suite 2800, New York, NY 10022.
Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please e-mail us at: [email protected]; call us at: (866)-483-8644; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Nava MD™), 800 Third Avenue, Suite 2800, New York, NY 10022. Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.
California Consumer Privacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Privacy Provisions for California Residents” below for a more complete description of your rights under the CCPA as a California State resident.
When you set up an account with Nava MD™, you are creating a direct customer relationship with Nava MD™ that enables you to access and/or utilize the various functions of the Site Offerings as a user. As part of that relationship, you may provide certain personal information to Nava MD™ that we do not consider to be “protected health information” or “medical information,” such as your name, email address, mailing/billing address and telephone number.
However, where you request Prescription Medications or otherwise request certain Nava MD™ Nonprescription Products, you may also provide certain health or medical information that may be protected under applicable laws, rules and regulations, such the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments (collectively, “HIPAA”). Nava MD™ is not considered a “covered entity” under HIPAA; provided, however, that our Healthcare Providers are “covered entities” under HIPAA and, in connection therewith, Nava MD™ may, in some cases, be a “business associate” of the Healthcare Providers. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to all of your transactions or communications with Nava MD™. To the extent Nava MD™ is deemed a “business associate” however, and solely in its role as a business associate, Nava MD™ may be subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that you provide to the Healthcare Providers (“PHI”). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information”), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.
The Healthcare Providers have adopted separate Notices of Privacy Practices that describe how they use and disclose Protected Information. By accessing or using any part of the Site Offerings, you acknowledge and agree that you have read all applicable Notices of Privacy Practices.
Below are links to key sections of our Privacy Policy:
Please see our Privacy Provisions for California
Residents for additional details regarding the categories of personal information collected.
For the purposes of this Privacy Policy, “personal information” shall mean individually
identifiable information from or about an individual. We collect personal information when you
access certain of the Site Offerings and complete the required information request Form(s) and/or
otherwise provide such information to us. The information that you must supply on the Form(s) may
include, without limitation: (a) your full name; (b) your mailing/billing address; (c) your e-mail
address; (d) your telephone number; (e) your gender; (f) your credit card information (where
purchasing Products); (g) answers to questions regarding your health and well-being, as asked via
the medical intake form; and/or (h) any other information requested by us on the applicable
registration Form.
For purposes of this Privacy Policy, items (f) and (g) in the preceding paragraph, as well as any Protected Information, will be considered “Sensitive Information.”
Please see our Privacy Provisions for California Residents for details regarding our use and sharing of personal information.
Unless you affirmatively consent and/or affirmatively opt-in pursuant to an explicit request to do so, Nava MD™ will never share, sell, rent, exchange or barter your personal information to or with any third-party for financial gain or marketing purposes. Please be advised, however, that where you submit a request for Prescription Medication, we may share your personal information (including Sensitive Information and Protected Information) with our Healthcare Providers to enable them to evaluate your suitability for the applicable Prescription Medication.
By making your personal information available to Nava MD™, you also grant Nava MD™ the right, subject to applicable law, to use that personal information to contact you by telephone and email regarding your use of the Site Offerings (including in connection with any purchase of Products). For SMS users and carriers, users' personally identifiable information will not be shared, rented, or sold to any third party--including affiliates. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or see the “Opt-Out/Unsubscribe” section below.
Please be advised further that, by making your personal information available to Nava MD™, you also grant Nava MD™ the right to verify your identification via third party verification service providers (such as Woolly Labs, Inc. d/b/a Vouched). You acknowledge and agree that Nava MD™ may share your personal information with such third party verification service providers for such purposes.
We may also use your personal information to send you promotional messages regarding various Nava MD™ products (as well as products and/or services offered by other LifeMD owned Internet properties such as, Shapiro MD™, REX MD™, LifeMD™, and SoSRx™) and/or services, as well as third-party products and/or services that we think may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or use any of the other options available in the “Opt-Out/Unsubscribe” section below.
Where you submit personal information, we use the personal information that you make available to facilitate the delivery of the applicable Site Offerings to you, including the Products and to respond to any inquiries made by you. You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Site Offerings, and to keep you informed of our other products and services.
We may also employ other companies and individuals to perform certain functions on our behalf. Examples include processing credit card and other payment transactions, sending direct and electronic mail, removing duplicate information from user lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our users’ personal information (including Sensitive Information, where applicable) as needed to perform these functions for us, but we do not permit them to use user personal information for other purposes.
We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Site Offerings and/or to contact you for market research purposes. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Site Offerings. We may also combine the information we have gathered about you with information from other sources.
By submitting your personal information by and through the Site Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.
Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive, from Nava MD™, telephone calls, including artificial voice calls, pre-recorded messages and/or calls (including text alerts via SMS text messages delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Site Offerings, and your consent simply allows Nava MD™ to contact you via these means. Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Nava MD™ of the Phone Number Change via e-mail at: [email protected], or by using one of the methods set forth in the “Contact Us” section below.
We reserve the right to release current or past personal information (including Sensitive Information): (i) in the event that we believe that the Site Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (iii) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Nava MD™ is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via e-mail and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.
You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be required by applicable law, including sharing your e-mail address with third-parties for suppression purposes in compliance with the CAN-SPAM Act of 2003, as amended from time to time, and other e-mail marketing laws. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.
Nava MD™ utilizes third-party service providers to provide credit and debit card payment processing services. If you choose to purchase Nava MD™ Nonprescription Products, the credit or debit card information provided will be shared with our contracted third-party payment processing service provider(s). Nava MD™ requires that its third-party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third-party payment processing service provider(s).
Please see our Privacy Provisions for California Residents below for more details regarding the categories and types of non-personal information collected.
Computer IP Addresses/Browser Type
We may collect certain non-personally identifiable information about you and your desktop computer
when you visit many of the pages of the Site. This non-personally identifiable information includes,
without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your
IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of
your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable
information that we collect to improve the design and content of the Site Offerings and to enable us
to personalize your Internet experience. We also may use this information in the aggregate to
analyze usage of the Site Offerings.
Cookies
When a user visits the Site and/or interacts with one of our commercial e-mail messages, we send one
(1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique
identifier to the applicable user’s computer and/or mobile device, as applicable. A Cookie is a
piece of data stored on your hard drive containing non-personally identifiable information about
you. Cookies have many benefits to enhance your experience on the Site, as applicable. To find out
more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the
Site Offerings, including for storing user preferences and tracking Site usage (such as pages opened
and length of stay at the Site, as applicable).
Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a user rejects a Cookie, he or she may still use the Site Offerings; provided, however, that certain functions of the Site Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.
Behavioral Tracking
Nava MD™ and its third-party partners, such as Google®, use
Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) to
analyze trends, administer the Site, track users’ movements around the Site and to gather
demographic information about our user base as a whole. In addition, we partner with third-parties
such as Google® to use Tracking Technology in connection with the display of advertising on our
Site, and to manage the serving of our advertising to you on other websites when you exit the Site.
Our third-party partners may use Tracking Technology to gather information about your activities on
the Site and other websites in order to provide you with certain Nava MD™ advertising based upon
your browsing activities and interests. To the greatest extent permissible under applicable law, we
are not responsible for the tracking practices of third-parties in connection with the Site.
Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout.
In addition, users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. Further, users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative, Facebook or Digital Advertising Alliance. Please note that opting out of this tracking activity does not opt you out of being served advertising. Even where you opt out of this tracking activity, you will continue to receive generic ads.
Cross Device Tracking
Nava MD™ tracks users’ use of the Site Offerings across
various devices, including your personal computer and mobile device, in order to optimize and
personalize your Site Offerings experience. Nava MD™ may collect certain of your personal
information across various devices. Please be advised that where you opt-out of having your use of
the Site Offerings tracked across devices, you may need to upload certain information multiple times
and/or input your log-in information multiple times.
Aggregate Data
Nava MD™ reserves the right to transfer and/or sell aggregate or
group data about users of the Site Offerings for lawful purposes. Aggregate or group data is data
that describes the demographics, usage and other characteristics of users as a group, without
disclosing personally identifiable information.
If you engage in any interaction with Nava MD™, other users or any third-party via the Interactive Services and/or by and through any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Interactive Services and/or Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where Nava MD™ responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all members/users of Nava MD™’™ social media accounts. We are not responsible for the personal information that you choose to submit via Interactive Services and/or any Social Media Websites.
In addition, the Site contains Social Media Website widgets and buttons (“Widgets”), such as the Facebook® and Twitter® share buttons. These Widgets may collect your IP address, as well as which page you are visiting on our Site, and may set a Cookie on your browser to enable the Widget to function properly. The Widgets are owned and operated by the applicable Social Media Websites. The Social Media Websites operate independently from Nava MD™, and we are not responsible for such Social Media Websites’ interfaces or privacy or security practices.
Your interactions with the Social Media Pages and Widgets are governed by the privacy policies of the applicable Social Media Websites. We encourage you to review the privacy policies and settings of the Social Media Pages with which you interact to help you understand those Social Media Websites’ respective privacy practices. If you have questions about the security and privacy settings of any Social Media Pages and/or Widgets that you use, please refer to the applicable Social Media Website’s privacy notices or policies.
This Site may contain links to third-party owned and/or operated websites including, without limitation, Social Media Websites, as well as the websites of third parties such as Healthcare Providers. Nava MD™ is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Nava MD™ has no responsibility or liability relating to them.
We endeavor to safeguard and protect our users’ personal information. When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts users to enter Sensitive Information (such as Protected Information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information), and when we store and transmit such Sensitive Information, that information is encrypted with industry standard encryption technology.
Access to your personal information is strictly limited, and we take reasonable security measures to ensure that your personal information is not accessible to the public. All of our users’ personal information is restricted in our offices, as well as the offices of our third-party service providers. Only employees or third-party agents who need user personal information to perform a specific job are granted access to user personal information. Our employees are dedicated to ensuring the security and privacy of all user personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store user personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.
Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Site Offerings or otherwise via the Internet or wireless networks, is done at your own risk.
In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.
Use of our text message-based services is subject to the following.
Description of the Service:
We use SMS messaging to let you know or remind you of product offerings and to inform you when we need additional information. The Wireless Carriers are not liable for delayed or undelivered messages.
Please note: Message & Data Rates May Apply.
Help: To obtain help you may:
Text HELP to obtain help on your mobile phone.
Email us at: [email protected]
Call us at: 866-294-3772 M-F 9am-5pm EST
Terminating the Service: You may terminate any of the Services or subscriptions at any time by texting STOP.
Frequency of Messaging: Text alerts are delivered 1 message per day.
We will not share, rent, or sell your Personal Information to other companies or individuals, unless we have your consent.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messages originator opt-in data and consent; this information will not be shared with any third parties.
NavaMD account updates - up to one message per day. Reply STOP to Opt-Out and HELP for help. Message and data rates may apply.
Please see our Privacy Provisions for California Residents below for more details regarding the personal information of minors.
Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Nava MD™ does not knowingly solicit or collect information from visitors under eighteen (18) years of age.
Please see our Privacy Provisions for California Residents below for instructions on how California Residents can opt-out of the sale of their personal information to third parties.
To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: [email protected].
Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Site Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Site Offerings-related and/or inquiry response-related messages from Nava MD™, you must cease requesting and/or utilizing the Site Offerings and/or cease submitting inquiries to Nava MD™, as applicable.
Please see our Privacy Provisions for California Residents below for instructions on how California Residents can access and/or delete personal information that we have collected.
At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have otherwise collected. You may do so by e-mailing us at: [email protected]. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
Please be advised that deleting your personal information may terminate your access to certain of the Site Offerings. If you wish to continue using the full complement of Site Offerings, you may not be able to delete all of the personal information that we have on file for you.
Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.
If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.
Nava MD™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Nava MD™ will notify users by: (a) sending the modified policy to our users via e-mail; and/or (b) by any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.
If you have any questions about this Privacy Policy or our privacy practices in general, you may
e-mail us as at: [email protected]; call us at: (866)-483-8644; or send us U.S. Mail to: LifeMD, Inc. (d/b/a Nava
MD™), 800 Third Avenue, Suite 2800, New York, NY 10022.
These Privacy Provisions for California Residents (“Privacy Provisions”) supplement, and do not limit in any way, the Privacy Policy set forth above. These Privacy Provisions apply solely to residents of the State of California (“CA Users”). We adopt these Privacy Provisions in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in these Privacy Provisions. CA Users with disabilities who wish to access these Privacy Provisions in an alternative format can contact us by emailing us at: [email protected]; calling us at: (866)-483-8644; or sending us U.S. Mail to: LifeMD, Inc. (d/b/a Nava MD™), 800 Third Avenue, Suite 2800, New York, NY 10022.
Categories of Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or
device (“personal information”). In particular, we have collected the following categories of
personal information from CA Users within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | YES |
| F. Internet or other similar network activity. | Browsing history, search history, information on a CA User's interaction with a website, application or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | No |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources (with the specific categories of personal information indicated in parenthesis):
Use of Personal Information
Subject to your right to limit our ability to use the sensitive personal information that we collect
from you, we may use or disclose the personal information that we collect (including: (a) name; (b)
mailing/billing address; (c) e-mail address; (d) telephone number; (e) your gender; (f) credit card
information (where purchasing Products); and (g) answers to health and well-being related questions,
as asked via the medical intake form) for one or more of the following business purposes (with the
specific categories of personal information indicated in parenthesis):
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.
Sharing Personal Information
Subject to your right to opt-out of such sharing/sale, we may share your personal information (including: (a) name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) your gender; (f) credit card information (where purchasing Products); and (g) answers to health and well-being related questions, as asked via the medical intake form) for the business purposes set forth above.
When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.
In the preceding twelve (12) months, we have disclosed the following categories of personal information (including: (a) name; (b) mailing/billing address; (c) e-mail address; (e) telephone number; (f) your gender; (g) credit card information (where purchasing Products); and (h) answers to health and well-being related questions, as asked via the medical intake form) for a business purpose :
We disclose your personal information (including: (a) name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) your gender; (f) credit card information (where purchasing Products); and (g) answers to health and well-being related questions, as asked via the medical intake form) for a business purpose to the following categories of third parties (with the specific categories of personal information indicated in parenthesis):
In the preceding twelve (12) months, we have not sold personal information to third parties.
Retention of Personal Information
Nava MD™ may retain the categories of personal information set forth below for the period that is the greater of: (a) as long as Nava MD™ believes necessary; (b) as long as necessary to comply with Nava MD™'sTM legal obligations, resolve disputes and/or enforce its agreements; and/or (c) as long as needed to provide CA Users with the products and/or services requested by such CA Users on the Site:
Nava MD™ may dispose of or delete any such information at any time, except as required by law, or as otherwise restricted by the terms and conditions set forth in any other agreement or document that is binding upon Nava MD™.
Your Rights and Choices
The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Opt-Out from the Sale of Your Personal Information
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.
Opt-Out from the Sharing of Your Personal Information
You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.
Opt-Out from the Use and/or Sharing of Your Sensitive Personal Information
You have the right to limit our use of your sensitive personal information, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category E (Biometric information), to those uses which: (i) are necessary to perform the services or provide the goods requested by you; (ii) help us to ensure security and integrity of your personal information to the extent the use of your sensitive personal information is reasonably necessary and proportionate for these purposes; (iii) are short-term, transient uses including, but not limited to, non-personalized advertising shown as part of your then-current interaction with the Site, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the then-current interaction with the Site; (iv) involve performing services on behalf of Nava MD™, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of Nava MD™; and (v) include activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by, Nava MD™, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by, Nava MD™.
You also have the right opt-out of our sharing your sensitive personal information with third parties, including any sensitive information from Category B (California Customer Records personal information), Category C (Protected classification characteristics under California or federal law) and/or Category E (Biometric information).
To exercise your right to limit our use of your sensitive personal information and/or opt-out of our sharing your sensitive personal information with third parties, please submit a verifiable CA User request to us by either:
We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to these Privacy Provisions
We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.
Contact Information
If you have any questions or comments about these Privacy Provisions, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either:
This Privacy Notice for California Residents (“Privacy Notice”) supplements the information contained in the Nava MD™ Privacy Policy (the “Privacy Policy”) made available on the website located at www.navamd.com (the “Site”). The Site is owned and operated by LifeMD, Inc. d/b/a Nava MD™ (“Nava MD™,” “we,” “us” or “our”). This Privacy Notice applies solely to residents of the State of California (“CA Users”). We adopt this Privacy Notice in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Privacy Notice. CA Users with disabilities who wish to access this Privacy Notice in an alternative format can contact us by emailing us at: [email protected]; by calling us at: (866)-483-8644; or sending us mail to: LifeMD, Inc. (d/b/a Nava MD™), 800 Third Avenue, Suite 2800, New York, NY 10022.
Categories of Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, postal address, telephone number, passport number, driver's license or State identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | YES |
| F. Internet or other similar network activity. | Browsing history, search history, information on a CA User's interaction with a website, application or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
Subject to your right to limit our ability to use the sensitive personal information that we collect from you, we may use or disclose the personal information that we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.
Sharing Personal Information
Subject to your right to opt-out of such sharing/sale, we may share your personal information for the other business purposes set forth above.
When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have not sold personal information to third parties.
Retention of Personal Information
Nava MD™ may retain the categories of personal information set forth below for the period that is the greater of: (a) as long as Nava MD™ believes necessary; (b) as long as necessary to comply with Nava MD™'sTM legal obligations, resolve disputes and/or enforce its agreements; and/or (c) as long as needed to provide CA Users with the products and/or services requested by such CA Users on the Site:
Nava MD™ may dispose of or delete any such information at any time, except as required by law, or as otherwise restricted by the terms and conditions set forth in any other agreement or document that is binding upon Nava MD™.
Your Rights and Choices
The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Opt-Out from the Sale of Your Personal Information
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.
Opt-Out from the Sharing of Your Personal Information
You have the right to opt-out of our sharing your personal information with third parties. To exercise your right to opt-out of our sharing your personal information with third parties, please submit a verifiable CA User request to us by either:
We endeavor to act on all such requests as soon as practicable, but in all cases within fifteen (15) business days of the receipt of your request.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies; provided, however, that in some cases, strictly for regulatory compliance purposes and to better evidence/honor opt-out/unsubscribe requests (and for no other purposes), we may retain certain items of your personal information on a de-identified and aggregated basis in such a manner that the data no longer identifies you.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require that you create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures that we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response that we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to this Privacy Notice
We reserve the right to amend this Privacy Notice in our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on the Site’s homepage.
Contact Information
If you have any questions or comments about this Privacy Notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either: