Privacy Policy

1. Introduction

This Privacy Policy describes how Kaerwell Holdings LLC and its affiliated companies (together, Kaerwell, we, or us) collect, use, and share information when you visit kaerwell.com (the Site), submit a form on the Site, or otherwise communicate with us through it.

This Policy covers the Site only. If you create an account on Kaerwell Health (kaerwellhealth.com), the Seller Portal, or a fulfillment client account, that account is governed by the Kaerwell Health Privacy Policy and the agreement you accept when you sign up. Where the two documents overlap, the account agreement controls for account data.

By using the Site, you agree to the practices described in this Policy. If you do not agree, please do not use the Site.

2. Our privacy principles

Data minimization. We collect only what we need to answer your inquiry, set up the service you asked for, and run the Site.

Transparency. This Policy is a plain statement of what we collect, why, and who sees it.

Control. You can ask us to correct, export, or delete the information we hold about you, and you can opt out of marketing email at any time.

Security. We protect personal information with commercially reasonable administrative, technical, and physical safeguards appropriate to its sensitivity.

3. Information we collect

3.1 Information you give us

Forms and inquiries. When you start a fulfillment account, join the rep program, contact us, or request a call, we collect what you enter: your name, email address, phone number, practice or company name, website, the e-commerce platform you use, your approximate monthly order volume, and the content of your message.

Communications. Anything you send us by email or through a scheduling link, including attachments.

3.2 Information we collect automatically

Device and browser information. Device type, operating system, browser type and version, screen size, and language settings.

Log and usage data. IP address, pages viewed, links clicked, date and time of access, and the page that referred you.

Cookies and similar technologies. As described in Section 8.

3.3 Information from other sources

We do not buy data about you. If you contact us after speaking with a brand representative or a Kaerwell rep, we may record who referred you so that referral commitments can be honored.

4. How we use information

• Responding to you. To answer your inquiry, schedule the call you requested, and set up the account or service you asked for.
• Onboarding. To hand your details to the Kaerwell company that will serve you (see Section 5) so an onboarding specialist can finish your setup.
• Marketing. To send you information about Kaerwell products, services, events, and educational content. You can opt out at any time (Section 6).
• Improving the Site. To understand which pages are used, diagnose problems, and improve content and design.
• Safety and compliance. To detect and prevent fraud and abuse, protect our systems, and meet legal obligations.

5. How we share information

We do not sell personal information, and we do not share it for targeted advertising.

Kaerwell companies. The Site is a front door for services provided by separate companies: Kaerwell Health LLC (the private label platform), Kaerwell Fulfillment LLC (warehousing and fulfillment), and Kaerwell Private Labeling LLC (private label services for brands). When you ask for one of those services, we share your inquiry with the company that provides it, and that company handles your information under its own agreement with you.

Service providers. Companies that help us run the Site and communicate with you, including our customer relationship management and form platform (HubSpot), our email service (Loops), our analytics provider, and our hosting provider. They may use your information only to perform services for us.

Legal requirements. When required by law, regulation, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud.

Business transfers. If Kaerwell or any of its companies is involved in a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in who controls your information.

With your consent. For any other purpose you agree to.

6. Marketing communications

If you submit a form on the Site, we may email you about Kaerwell products, services, events, and educational content. Every marketing email includes an unsubscribe link, and you can also opt out by emailing info@kaerwell.com. Opting out of marketing does not stop service messages about an account or order you have with a Kaerwell company.

If you provide a phone number, we may call or text you about your inquiry. Reply STOP to any text to end text messages.

7. Data retention

We keep inquiry and form data for as long as needed to respond to you and for a reasonable period afterward for our records. If you become a client of a Kaerwell company, your information is kept under that company's agreement and retention rules. We may keep information longer where the law requires it or to establish, exercise, or defend legal claims.

8. Cookies and tracking

Cookies are small files placed on your device when you visit the Site. We use:

• Strictly necessary cookies, which make the Site work and keep it secure. These cannot be turned off.
• Analytics cookies, which tell us which pages are visited and how the Site performs.
• Customer relationship cookies set by HubSpot, which connect the forms you submit to your prior visits so we can respond in context.

We do not currently use advertising or targeting cookies. If we ever do, we will update this Policy and give you notice and choice first.

You can remove or block cookies in your browser settings; some parts of the Site may not work without them. We honor Global Privacy Control signals as a valid opt-out of sale or sharing where state law provides that right.

9. Your privacy rights

Depending on where you live, you may have the right to know what personal information we hold about you, to correct it, to delete it, to receive a copy of it, to opt out of its sale or sharing for targeted advertising, and not to be discriminated against for exercising these rights. As stated above, we do not sell or share personal information for targeted advertising, and we do not profile you in ways that produce legal or similarly significant effects.

9.1 How to exercise your rights

Email info@kaerwell.com with the subject line "Privacy request." We will verify your identity, usually by confirming details we already hold, and respond within the time the law requires, generally 45 days. An authorized agent may act for you with proof of authorization; we may still ask you to confirm the request directly.

9.2 State-specific notices

California. Under the CCPA and CPRA you have the rights described above. The categories of information we collect and our purposes are in Sections 3 and 4. We do not use or disclose sensitive personal information for purposes beyond those the law permits.

Other states with comprehensive privacy laws. If you live in a state with a comprehensive consumer privacy law, you may exercise the rights above by contacting us as described in Section 9.1.

Washington and Nevada. The Site does not collect consumer health data as defined by the Washington My Health My Data Act or the Nevada consumer health data law. If that changes, we will publish the notices those laws require.

10. HIPAA

Kaerwell is not a healthcare provider, health plan, or healthcare clearinghouse, and is not a covered entity under HIPAA. The Site does not collect protected health information. Where a Kaerwell company processes protected health information on behalf of a covered entity, that processing is governed by a separate Business Associate Agreement, not by this Policy.

11. Children

The Site is intended for businesses and licensed health professionals. It is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18. If you believe we have, contact us and we will delete it.

12. Other websites

The Site links to Kaerwell Health, the Seller Portal, the fulfillment help center, scheduling tools, and other third-party services. Their privacy practices are described in their own policies, and this Policy does not apply to them.

13. Changes to this Policy

We may update this Policy from time to time. The effective date at the top tells you when it last changed. If a change materially affects how we use information you have already given us, we will notify you by email or with a notice on the Site before the change takes effect.

14. Contact us

This Policy is governed by the laws of the State of Florida, without regard to its conflict of laws principles, except where a state or federal privacy law gives you rights that cannot be waived.