Last Updated on September 28, 2022

PRIVACY POLICY

Standard Process Inc. and its affiliated entities (collectively, “Standard Process”) share your concerns about privacy. In order to better protect your privacy, Standard Process has provided this online privacy policy (“Privacy Policy”) explaining its online information practices and the choices you can make about the way your information is collected and used. This Privacy Policy applies to the information that Standard Process collects on websites owned and controlled by Standard Process, including without limitation www.standardprocess.com, https://wholisticmatters.com, www.organicsbylee.com, www.engineeringbylee.com, and www.mypossible.com (collectively, the “Sites”), and does not apply to information that Standard Process may collect by any alternative means or media unless specifically stated otherwise.

If you are a California resident, please also see Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.

1. Standard Process’ Collection of Your Information

In the course of using the Sites, Standard Process may ask users for their name, email address, postal address, mobile or other telephone number, fax number, care provider’s name, personal health information and payment information, and other relevant information. Standard Process may collect additional information depending on how you are using the Sites, such as:

• Health care providers may be asked to provide information specific to their clinics, such as clinic name, address, telephone number, and website URL. Standard Process may also collect account registration information, including usernames, passwords, and answers to security questions.
• For employment applications, Standard Process may collect additional information through a third party website (such as https://recruiting.ultipro.com), including previous work experience, education information, licenses and certifications, and other personal information.

In many cases, users choose the amount of information they supply. There may be instances in which some of the information that we ask users to provide is identified as mandatory and some as voluntary. In such cases, if users do not provide mandatory personal information with respect to a particular activity, users will not be able to engage in that activity. Standard Process also may collect certain information that is not personally identifiable when you visit our Sites, such as the type of browser you are using, the type of operating system you are using, the domain name of your Internet service provider, aggregate data about the number of visits to the Sites, and/or aggregate data about the pages visited.

Information gathered through the Sites may be transferred, used, and stored in the United States and in foreign jurisdictions in which we, our agents, customers, and other users of the Sites are located, and by accessing the Sites, you consent to the transfer, use, and storage of your information in those jurisdictions.

2. How Standard Process Uses the Information

Standard Process uses non-personally identifiable information—whether non-identifying, de-identified, anonymized, or aggregated (collectively, “De-identified Data”)—to improve the design and content of the Sites and to enable Standard Process to personalize your online experience. Standard Process may use the De-identified Data to analyze the Sites’ usage as well as create services and/or products to fit your needs. Also, Standard Process may share this De-identified Data with Standard Process’ related entities, advertisers, partners, and/or other third-party vendors. Standard Process shall own such De-identified Data and may maintain copies of such as part of its records.

Except as otherwise indicated, Standard Process uses the personally identifiable information (“Personal Information”):

• to process and fulfill your order(s) for products;
• to respond to any of your inquiries or questions about our products and/or services;
• for internal marketing purposes;
• to provide you with additional and updated information, materials, and other advertisements regarding Standard Process products and/or services;
• to offer you other materials and/or information that Standard Process believes may be of interest to you;
• to cooperate with government officials or parties in litigation under process of law, to prevent a crime, or as otherwise required by law;
• to enforce or comply with Standard Process’s contracts with you, your care provider, or other third parties or protect the security or integrity of the Site;
• to protect against fraud, identity theft, or a threat of safety or destruction of property;
• to protect against legal liability;
• to create and manage user accounts;
• to process payment;
• to communicate with the user’s health care provider regarding the user’s use of the Site; and/or
• to perform data analyses and/or research (including de-identification and aggregation of Personal Information).

Standard Process may share user product order information, including the items and quantities ordered, with the user’s health care provider who recommended the product(s). In all cases, however, Standard Process’ agents, employees, and contractors who have access to Personal Information are required to protect this information in a manner that is consistent with this Privacy Policy. Furthermore, Standard Process encourages all its business partners to adopt and adhere to standards of protection consistent with this Privacy Policy. If you do not wish to receive marketing materials or advertisements regarding Standard Process products, please contact Standard Process in the manner identified in the “Opt Out” section below.

The De-identified Data and Personal Information may be disclosed, transferred, assigned, licensed, distributed, and/or sold as part of Standard Process or its assets. In addition, if Standard Process becomes the subject of a bankruptcy or insolvency proceeding, whether voluntary or involuntary, Standard Process or its trustee in bankruptcy may disclose, sell, assign, license, or otherwise transfer such information in a transaction approved by the appropriate court.

3. Children

The Sites are not intended for children under the age of 16. Standard Process does not knowingly collect personal information from users under 16 years of age. In the event that Standard Process becomes aware that it has collected personal information from a user under 16 years of age, it will take steps to delete such information from its database. If you believe that we might have any information from or about a child under the age of 16, please contact us at privacy@standardprocess.com.

4. Do Not Track

The Site does not respond to “do not track” requests. All traffic is treated as equal and processed the same. If you desire to have your browsing be private, we suggest that you use your web browser’s private or incognito function, or similar options.

5. Opt Out

You may choose not to receive marketing materials regarding Standard Process products by simply notifying Standard Process directly at sporders@standardprocess.com or at 800-558-8740. Upon receipt and processing of an “opt-out” request, Standard Process will, within a commercially reasonable amount of time, remove your information from any future unsolicited marketing communications. Your request not to receive marketing materials will not apply to information that you request to receive.

If you are a California resident, please also see Appendix A titled “Privacy Information for California Residents” for further supplemental information about additional rights you may exercise.

6. Security, No Liability

Standard Process uses reasonable efforts to implement security measures designed to help protect against the risk of loss, misuse, and alteration of any information under Standard Process’ control. Nevertheless, please keep in mind that such security measures may not prevent all loss, misuse, or alteration of information on the Sites, and transmission of information over the Internet and on mobile platforms is not always secure, which means we cannot and do not guarantee the security or confidentiality of any information that you provide to us.  Given this reality, your use of our Sites and your decision to provide personal information to us is at your own risk.  Standard Process is not responsible for any damages or liabilities relating to any such security failures.

Furthermore, email is not a secure form of communication. Please do not send us your Social Security number, credit card number, or other sensitive personal information via email. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your data transmitted to and from our Sites or over mobile networks; any transmission is at your own risk. You understand that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties when communicated over the Internet.

7. Third Party Websites

The Sites contain links to other websites that do not belong to Standard Process. Standard Process is not responsible for nor can Standard Process ensure the privacy practices or content of such other websites, and this Privacy Policy does not apply to those other websites. You should always read the privacy policy of a website before disclosing any of your information.

For employment applications, you will be redirected to a website called https://recruiting.ultipro.com, which is controlled by Ultimate Software. The website will collect personal and employment related information about you. Please make sure to read Ultimate Software’s privacy policy, which is located at https://www.ultimatesoftware.com/Privacy-Policy.

8. IP Addresses and Cookies

Like other businesses, Standard Process uses your IP address to help diagnose problems with Standard Process’ servers, to administer the Sites, and for security purposes. A cookie is a small text file that is sent to your browser when you access a website, including the Sites. We and our third-party vendors may use session cookies. A session cookie is available only during the course of the browser session; the information is not sent to or stored on a computer’s hard drive. Closing the browser or logging off will invalidate the session cookie. We and our third-party vendors may also use machine cookies, which do remain on a computer hard drive after the end of a browsing session and gather information, sometimes over time and across sites. In addition, the Sites may contain advertisements that may contain cookies. In general, if you choose, you can disable the use of cookies by reviewing your browser’s preferences and options. Disabling the use of cookies will make some portions of the Sites inoperable.

9. Third Party Analytics

We may use third-party analytics on the Sites to enable us to continually improve the content we offer to you, for systems administration purposes, to evaluate your use of the Sites, to compile reports on activity, to analyze performance metrics, and to collect and evaluate other information related to the Sites. Some of our analytics can be used to track users over time, for geo-location purposes, and across third-party websites. For example, we use Google Analytics to help us understand how our customer interact with our websites. To learn more about Google Analytics’ privacy practices and the opt-out choices it offers, please visit the following websites: https://policies.google.com/privacy, https://tools.google.com/dlpage/gaoptout/. We also use DoubleClick cookies and/or pixels, along with Google Ads.

We may use the information we collect to serve you more relevant advertisements. Further, we may collect information about where you saw the ads we serve you and what ads you clicked on. You may see certain ads on the Sites or across other websites on the internet based on information we or the third-party analytics we use have collected. This may include information from your past visits to the Sites and other information that was collected through automatic means (such as cookies and web beacons).

10. Modification of Privacy Policy

Standard Process may change this Privacy Policy at any time by posting the changed or amended Privacy Policy on the Sites. Your continued viewing of or use of the Sites following the posting of any changes to this Privacy Policy will signify your assent to any such changes or amendments.

11. How to Contact Standard Process for Any Reason

You may contact Standard Process with questions or comments regarding this Privacy Policy or to update any Personal Information at privacy@standardprocess.com or at 800-558-8740.

Appendix A

1. Privacy Information for California Residents

This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”). This Appendix complies with the California Consumer Privacy Act of 2018, as amended, (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix does not apply to personal information outside the scope of the CCPA, including, for example:

• Personal health information collected, processed, sold, or disclosed pursuant to the Health Insurance Portability and Accountability Act (“HIPAA”).
• Personal information bearing on a consumer’s credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living as set forth in the Fair Credit Reporting Act.

2. Standard Processas a Service Provider

When Standard Process acts as a service provider for its business customers, it collects some personal information on behalf of its customers subject to its contractual obligations.  When Standard Process acts as a service provider for its business customers, it follows the instructions of its customer on how to process personal information on its customer’s behalf.  The provisions of this Appendix do not apply to the personal information that Standard Process processes on behalf of our business customers.

3. Disclosures

The below chart lists the categories of personal information that Standard Process may collect or has collected in the past 12 months and how it discloses such information. Standard Process may also disclose your personal information to a third party, such as a care provider, upon your request or at your direction.

4. Uses of Personal Information

Standard Process may use personal information for the following purposes:

• to process and fulfill your order(s) for products;
• to respond to any of your inquiries or questions about our products and/or services;
• for internal marketing purposes;
• to provide you with additional and updated information, materials, and other advertisements regarding Standard Process products and/or services;
• to offer you other materials and/or information that Standard Process believes may be of interest to you;
• to comply with legal obligations and cooperate with government officials or parties in litigation under process of law, to prevent a crime, or as otherwise required by law;
• to enforce or comply with Standard Process’s contracts with you, your care provider, or other third parties or protect the security or integrity of the Site;
• to protect against fraud, identity theft, or a threat of safety or destruction of property;
• to protect against legal liability;
• to create and manage user accounts;
• to process payment;
• to communicate with the user’s health care provider regarding the user’s use of the Site;
• to perform data analyses and/or research (including de-identification and aggregation of personal information) or to conduct surveys; and/or
• to evaluate you for employment at Standard Process or to begin the employment process.

Standard Process may share user product order information, including the items and quantities ordered, with the user’s health care provider who recommended the product(s).

5. Sensitive Personal Information

Sensitive Personal Information consists of: (1) government identifiers, such as Social Security Numbers and drivers’ license numbers; (2) account log-in information (e.g., financial account or credit card numbers in combination with any required access codes or passwords); (3) precise geolocation information; (4) racial or ethnic origin, religious or philosophical beliefs, or union membership; (5) content of postal mail, email, and text messages, unless the business is the intended recipient of the subject communications; (6) genetic data; and (7) biometric information that uniquely identifies a consumer or information concerning a consumer’s health, sex life, or sexual orientation.  To the extent we collect information that is considered Sensitive Personal Information under CCPA, it is listed in the chart above. Standard Process may use information regarding your health to make inferences that allow us to provide you with information and recommendations regarding our products.

6. Sources of Information

Standard Process may collect personal information from the following sources: you, your agents, through our third-party service providers, data analytics providers, social media networks, and your care provider.

7. Sale and Sharing of Personal Information

CPRA defines “Sharing” as any disclosure of personal information to third parties for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. “Cross-context behavioral advertising” is defined as the targeting of advertising based on your personal information obtained from your activity across websites, applications, or services outside of the Sites or Standard Process Services.

In the past 12 months, we have not sold personal information. To ensure we can share our products with you and tailor our advertisements, we do allow some of our advertising partners to use cookies, pixels and other technologies to collect personal information on our website or services, which may constitute Sharing under CPRA.

8. Data Retention

We will retain your personal information for no longer than is necessary for the purpose stated in this Privacy Policy, unless otherwise extending the retention period is required or permitted by law or subject to our retention policies as may be in place from time to time. The data storage period may vary with scenario, product, and service. The standards we use to determine the retention period are as follows: the time required to retain personal information to fulfill business purposes, including providing products and services; maintaining business records; controlling and improving the performance and quality of the Sites; handling possible user queries or conducting assessments of user complaints; whether you agree to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention.

9. California Residents’ Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information, described below. Below are your CCPA rights and how to exercise those rights.

10. Access to Specific Information and Data Portability Rights

You have the right to request that Standard Process disclose certain information to you about its collection and use of your personal information over the past 12 months. You may request:

• The categories of personal information Standard Process collected about you;
• The categories of sources of personal information Standard Process collected about you;
• Standard Process’ business or commercial purpose for collecting that personal information;
• The categories of third parties with whom Standard Process shares that personal information;
• The specific pieces of personal information Standard Process collected about you including whether or not Standard Process collects Sensitive Personal Information; or
• Whether information, if any, is Sold or Shared by Standard Process.

11. Deletion Request Rights

You have the right to request that Standard Process delete some or all of the personal information that it has collected from you and retained, subject to a number of exceptions. Standard Process is not required to delete personal information that is: (i) necessary to complete a transaction with you or for warranty or product recalls; (ii) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (iii) reasonable for Standard Process to use for internal purposes given its relationship with you; or (iv) compatible with the context in which you provided the information.  The list of exceptions above is not exhaustive, and we may also deny a deletion request as otherwise permitted by law.

12. Correction Rights

You have the right to request that Standard Process amend your personal information if it is inaccurate or outdated, such as an outdated address. Standard Process is not required to correct information that is subjective, such as an opinion.

13. Limiting Our Use of Your Information

In certain circumstances,  you have the right to limit our non-essential use of your personal information, including Sensitive Personal Information.

14. Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to Standard Process by either:

• Calling us at 800-558-8740.
• Visiting CCPA Request Form.

Only you, or a person 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. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.

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 Standard Process to reasonably verify you are the person about whom it collected personal information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Standard Process may not be able to fulfill your request or provide you with personal information if it cannot verify your identity or authority to make the request and confirm the personal information relates to you.  To verify your identity, Standard Process may request up to three pieces of personal information about you, and Standard Process reserves the right to take additional steps as necessary to verify your identity if it has reason to believe a request is fraudulent.

15. Response Timing and Format

Standard Process endeavors to respond to a verifiable consumer request within 45 days of its receipt. If Standard Process requires more time (up to 90 days), it will inform you of the reason and extension period in writing. Standard Process will deliver the written response by mail or electronically, at your option.

Any disclosures Standard Process provides will only cover the 12-month period preceding the date it receives your verifiable consumer request. The response Standard Process provides will also explain the reasons it cannot comply with a request, if applicable. For data portability requests, Standard Process 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.

Standard Process does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Standard Process determines that the request warrants a fee, it will tell you why it made that decision and provide you with a cost estimate before completing your request.

16. Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, Standard Process 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; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.