Last modified: 5/8/2023

Introduction

28 Wellness, Inc. (the “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.28.co (our “Website”) or use our mobile application, 28 (the “App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect:

• On this Website or through the App.
• In email, text, and other electronic messages between you and this Website or the App.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates), including through any application or content (including advertising) that may link to or be accessible from or on the Website or the App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or the App. By accessing or using this Website or the App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website or the App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

Our Website and the App is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website or App. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or the App or on or through any of its features on the Website or App, make any purchases through the Website or App, use any of the interactive or public comment features of this Website or App or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at support@28.co.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website or App, including information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”); that is about you but individually does not identify you, such as your internet connection, the equipment you use to access our Website or App and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide To Us

The information we collect on or through our Website or App may include:

• Information that you provide by filling in forms on our Website or App. This includes information provided at the time of registering to use our Website or App, subscribing to our services, emails, or website, submitting content, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website or App.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes
• Details of transactions you carry out through our Website or App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or App.
• Your search queries on the Website or App.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website or App, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website or App.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.
• We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Website and App and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website and App according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website or App.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website or App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or App.
• Flash Cookies. Certain features of our Website or App may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website or App. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons.. Pages of the Website or App and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website or App are served by third parties, including 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 website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about any targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and App and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website and App or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website and App.
• For any other purpose with your consent.

Disclosure of Your Information

We will never sell your personal information. We will never disclose your personal information other than on a limited basis as described in this Privacy Policy.

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our parent company and subsidiaries.
• To contractors, service providers, and other third parties we use to support our business who are subject to an obligation of confidentiality.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of 28 Wellness, Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by 28 Wellness, Inc. about our Website and App users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including as required to respond to any government or regulatory request, but only to the extent legally required. We will never voluntarily provide your personal information to the government.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of 28 Wellness, Inc., our customers, or others.

However, with respect to any data you provide regarding monthly menstrual cycle tracking:

• The only cycle data we collect is data you choose to provide on a voluntary basis.
• Any cycle data you provide may be changed or deleted by you at any time.
• We do not store deleted cycle data. If you change or delete the cycle data you provided, it is gone forever.
• We will never disclose your cycle data to the government or any legal authority.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. We do not share personal information with unaffiliated or non-agent third parties for promotional purposes.

Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support@28.co.You can also unsubscribe at any time. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Targeted Advertising. We do not use information that we collect or that you provide to us to deliver advertisements to you.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah, may have additional personal information rights and choices. Please see “Your State Privacy Rights” for more information.

Accessing, Correcting, and Deleting Your Information

You may also send us an email at support@28.co to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah may have additional personal information rights and choices.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. For example, California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website and App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@28.co.

Consumer Privacy Rights in Other States

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please send an email to support@28.co. To appeal a decision regarding a consumer rights request send an email to support@28.co.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to this designated address: support@28.co. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We urge you to be careful about giving out information in public areas of the Website and App like the comment sections of articles. The information you share in public areas may be viewed by any user of the Website or App.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website or App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or App

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

support@28.co.