Privacy Policy

Schwabe North America, Inc. - Website Privacy Policy
Last Modified: December 29, 2019

This Privacy Policy applies to the websites, social media pages, mobile applications, widgets or online services that are owned or controlled by Schwabe North America, Inc. and its subsidiaries (collectively, “Schwabe North America” or “we” or “us”) and that post a link to this Privacy Policy (collectively, “Sites,” and individually, a “Site”). This Privacy Policy only covers information collected at the Sites and does not cover any information collected at any other web site or offline by Schwabe North America (unless specifically stated). This Privacy Policy describes Schwabe North America ’s information collection practices at the Sites, such as the types of information Schwabe North America collects regarding visitors to the Sites and how we may use that information.
 
This Privacy Policy does not apply to any other website owned or operated by any third party even if such third party links to a Site or if Schwabe North America links to that third-party website. Accordingly, this Privacy Policy does not apply to the practices of any third party or business partner that Schwabe North America does not own or control.
 

1. YOUR CONSENT

Please review this Policy before using the Site. By using this Site, you are consenting to the collection, use and disclosure of your information as set forth in this Privacy Policy. If you do not agree to be bound by this Privacy Policy, you may not access or use the Sites.
 

2. DEFINITIONS

For purposes of this Privacy Policy:
  • “Aggregate Information” means information about groups or categories of data, which does not identify and cannot reasonably be used to identify an individual, such as web traffic analytics.
  • “Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual, such as Cookies.
  • “Cookies” means anonymous, unique identifiers that a website places on the hard drive of your computer or mobile device when you visit the website.  Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its Privacy Policy.
  • “Flash Cookies” means local shared objects that are used to store personalized information based on visits to websites.
  • “Personal Information” means information that identifies (whether directly or indirectly) an individual, such as the individual’s name, postal address, email address or telephone number. When Anonymous Information is directly or indirectly associated with Personal Information, this Anonymous Information also is treated as Personal Information.
  • “Web Beacons” means small pieces of data that are embedded in images on the pages of Sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its Privacy Policy.

3. COLLECTION OF INFORMATION

We collect two basic types of information from you and about you – Personal Information and Anonymous Information. We may use Personal and Anonymous Information to create a third type of information – Aggregate Information. For example, we collect contact information, demographic information, purchasing information, information you submit or post, and payment information. If you use our Sites, we may collect information about the browser you’re using or other traffic information.
 
We collect information in different ways. We collect information that you give to us. For example, if you register with us, contact us for information, or participate in a promotion.
 
We collect information about you automatically. Where permitted by law we use tracking tools such as browser Cookies and Web Beacons to collect information from you. We collect information about users over time when you use the Sites. We collect information about you from third parties, such as social media platforms and advertising analytics providers. We may have third parties collect information as described in this Privacy Policy, for example in Section 6.
 

4. USE OF INFORMATION

We use information that we collect including Personal Information for a variety of purposes. We use information to respond to your requests or questions. We use information to improve our Sites, products, programs and services. We might use your information to customize your experience with us.
 
We use information to administer our Site and for internal operations. For example, we may aggregate or anonymize your information for analytics, research or other business purposes. We combine information. For example, we may combine information that we have collected offline with information we collect online, to the extent permitted by law, for the transactional purpose, or by your consent. We may combine information we get from you with information about you we get from third parties.
 
We use information for security purposes. Where legally permitted, we may use your information to protect our company, our customers, and our websites.
 
We use information for marketing purposes. For example, we might send you information about new products or services or special offers. We might also use your information to serve you ads about our products, services and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. If you register with us, we’ll send you our promotional emails.
 
We use information to communicate with you about your account, purchases or our relationship. We may contact you about your account or for feedback. We might also contact you about this Privacy Policy or our Site Usage Terms and Conditions.
 
We use information to comply with applicable law, and as otherwise permitted by applicable law.
 

5. DISCLOSURE AND SHARING OF INFORMATION.

We may use third party service providers to perform certain services on behalf of the Sites, such as web site hosting, accepting job applications, providing web site usage analytics, sending email or other communications, providing marketing assistance and data analysis, providing consumer affairs services, fulfilling and processing orders, or performing other administrative services. We may provide these service providers with access to your Personal Information so that they can carry out the services they are performing for you or for Schwabe North America. Some of these service providers may collect information on the Sites directly from you on our behalf; in such cases, these service providers are not permitted to use your Personal Information for their own use.
 
You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an interactive feature or third party application, that we share information about you with a third party, and we will typically do so under those circumstances.
 
We may offer sweepstakes, contests, and other promotions (collectively, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
 
We may also disclose your Personal Information: i) as required by law, such as to comply with a subpoena, or similar legal process; ii) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or iii) if Schwabe North America is involved in a merger, acquisition, or sale of all or a portion of its assets.
 

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

We collect information, and authorize our third party vendors to collect information, about users over time across our Sites and for other services. To do this, we and/or our third party vendors use several common tracking tools. These may include Cookies, Web Beacons, Flash Cookies, and similar technologies.
 
We may use these cookies and tracking technologies:
To recognize new or past customers.
  • To store your password if you are registered to our Site.
  • To improve our Sites.
  • To serve you with interest-based or targeted advertising
  • To observe your behaviors and browsing activities over time across multiple websites or other platforms.
  • To better understand the interests of our customers and our Site visitors.
  • In connection with an email delivery and marketing company to send emails that you have agreed to receive. Pixel tags and cookies are used in those email messages and at our Site to help us measure the effectiveness of our advertising, how our visitors use our Site and to enable us to provide more focused and subsequent email marketing communications to you.
 
Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with Web Beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content, which is often referred to as remarketing.
 
While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note that these companies may still collect information when you are online and opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Sites and elsewhere online.
 

7. DO NOT TRACK DISCLOSURES

At this time, there are no worldwide uniform or consistent industry standards or definition for responding to, processing, or communicating "Do Not Track" signals. As a result, the Site is unable to respond to "Do Not Track" signals. You can refer to the instructions in your browser to make sure the appropriate settings are selected, and to set your preferences with respect to "Do Not Track" signals.
 

8. SECURITY AND RETENTION

Schwabe North America has reasonable technical and organizational security measures in place to protect the loss, misuse or alteration of information under our control. However, Schwabe North America cannot guarantee that unauthorized third parties will never be able to defeat those security measures. Although we cannot guarantee that our systems are 100% secure 100% of the time, we periodically update our technology in order to improve the protection of customer information.
We retain personal information as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep information as otherwise required or permitted by law.
 

9. WE STORE INFORMATION BOTH IN AND OUTSIDE OF THE U.S.

Information we collect from you may be transferred to, or stored at, a destination in the United States or another destination outside of United States. It may be processed by staff operating in these locations who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. U.S. laws may not afford the same level or protection as those in your country.
 

10. GOVERNING LAW AND JURISDICTION

This Privacy Policy, and Schwabe North America's collection and use of customer information, shall be governed and interpreted in accordance with the laws of the United States and the State of Wisconsin. Any disputes arising out of this Privacy Policy shall be adjudicated in Milwaukee County, Wisconsin or a federal court of competent jurisdiction in the Eastern District of the State of Wisconsin.
 

11. GOVERNING LANGUAGE

Any translation of this Privacy Policy is done for local requirements and in the event of a dispute between the English and any non-English versions, the English version of this Privacy Policy shall govern.
 

12. CHANGES TO PRIVACY POLICY

Schwabe North America may make changes to this statement from time to time. We will post changes to our Privacy Policy here, so be sure to check back periodically.
 

13. HOW TO ACCESS AND MODIFY PERSONAL INFORMATION

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information.
 
You may request that we correct, update and delete your account by contacting us at privacyquestion@naturesway.com or by writing to us at Schwabe North America Customer Service at 825 Challenger Drive, Green Bay, WI 54311.
 
You may unsubscribe from receiving offers and promotions for our products and services through the unsubscribe mechanisms provided in our promotional communications. Even if you opt out of getting marketing messages, we will send you transactional messages. These include responses to your questions.
 

14. QUESTIONS, COMMENTS, CONCERNS

If you have any questions or comments about our use of Personal Information or about this Privacy Policy, please contact us at privacyquestion@naturesway.com. Schwabe North America will use reasonable efforts to promptly investigate any complaint you may have regarding our use of Personal Information and to comply fully with the legal and regulatory supervisory authorities responsible.
 

15. OUR SITES AND CHILDREN

Our Sites where this Privacy Policy is found are meant for adults. We do not knowingly collect Personal Information from children under 18 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 18 has given us information, you can contact us at privacyquestion@naturesway.com, or write to us at Customer Service at 825 Challenger Drive, Green Bay, WI 54311. Please mark your inquiries "COPPA Information Request." Parents in the United States, you can learn more about how to protect children's privacy on-line at www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.
 
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
 
Effective Date: December 29, 2019
 
Last Reviewed: December 29, 2019
 
This Privacy Notice for California Residents supplements the information contained in our Privacy Policy above and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.
 
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 consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
 
Category Examples Collected
  1. Identifiers.
A real name, Internet Protocol address, email address, or other similar identifiers Yes
  1. 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, 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
  1. Protected classification characteristics under California or federal law.
Age, 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
  1. Commercial Information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes
  1. 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. No
  1. Internet/electronic activity.
Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement. Yes
  1. Geolocation data.
Physical location or movements. Yes
  1. Sensory data.
Audio, electronic, visual, thermal, olfactory or similar information. No
  1. Professional or employment related information.
Current or past job history or performance evaluations. No
  1. 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
  1. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes
 
Personal information does not include:
 
  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
 
We obtain the categories of personal information listed above from the following categories of sources:
  • Directly from you. For example, when you sign up for email on our Site.
  • Indirectly from other sources, such as marketing partners, social events, and social networking sites.
 
Use of Personal Information
 
We may use, or disclose the personal information we collect for one or more of the following business purposes:
 
  • We use information that we collect including Personal Information for a variety of purposes. We use information to respond to your requests or questions. We use information to improve our Sites, products, programs and services. We might use your information to customize your experience with us.
 
  • We use information to administer our Site and for internal operations. For example, we may aggregate or anonymize your information for analytics, research or other business purposes. We combine information. For example, we may combine information that we have collected offline with information we collect online, to the extent permitted by law, for the transactional purpose, or by your consent. We may combine information we get from you with information about you we get from third parties.
 
  • We use information for security purposes. Where legally permitted, we may use your information to protect our company, our customers, and our websites.
 
  • We use information for marketing purposes. For example, we might send you information about new products or services or special offers. We might also use your information to serve you ads about our products, services and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. If you register with us, we’ll send you our promotional emails.
 
  • We use information to communicate with you about your account, purchases or our relationship. We may contact you about your account or for feedback. We might also contact you about this Privacy Policy or our Site Usage Terms and Conditions.
 
  • We use information to comply with applicable law, and as otherwise permitted by applicable law.
 
Sharing Personal Information
 
We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
 
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
 
Category Examples Disclosed for a Business Purpose
  1. Identifiers.
A real name, Internet Protocol address, email address, or other similar identifiers Yes
  1. 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, 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
  1. Protected classification characteristics under California or federal law.
Age, 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
  1. Commercial Information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. No
  1. 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. No
  1. Internet/electronic activity.
Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement. No
  1. Geolocation data.
Physical location or movements. No
  1. Sensory data.
Audio, electronic, visual, thermal, olfactory or similar information. No
  1. Professional or employment related information.
Current or past job history or performance evaluations. No
  1. 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
  1. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. No
 
We disclose your personal information for a business purpose to the following categories of third parties:
 
  • Our affiliates.
 
  • Service providers.  We engage certain third parties to perform functions and provide services to us, including direct marketing campaigns.  We may share your personal information with these third parties, only to the extent necessary to perform these functions and provide such services.  We also require these third parties to maintain the privacy and security of the personal information they process on our behalf.
 
In the preceding twelve (12) months, we have not sold any personal information.
 
Your Rights and Choices
 
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
 
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 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
 
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
 
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 consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
 
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
 
  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  6. 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 information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  10. Retain a record of deletion activities.
 
Exercising Access, Data Portability, and Deletion Rights
 
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
 
  • Calling us at 1-800-9NATURE (1-800-962-8873).
  • Emailing us at privacyquestion@naturesway.com.
 
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
 
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
 
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
 
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 the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
 
Response Timing and Format
 
We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons 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 consumer 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:
  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
 
If you disable cookies on our Sites, the Sites may not work properly, registration, ecommerce and any signup forms may be disabled.
 
Changes to Our Privacy Notice
 
We reserve the right to amend this Privacy Policy at our discretion and at any time. Please check periodically for updates.
 
Contact Information
 
If you have any questions or comments about this 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 at:  privacyquestion@naturesway.com.
 

* This statement has not been evaluated by the Food & Drug Administration. This product is not intended to diagnose, treat, cure or prevent any disease.

†† These indications are based solely on traditional homeopathic use. They have not been evaluated by the Food & Drug Administration.