Privacy Policy

1. Introduction

This Privacy Policy (this “Privacy Policy”) describes the Personal Information and other information that Solarea Bio, Inc. (“Solarea,” “we,” “us,” or “our”) may collect, and how Solarea collects, uses and discloses such information when you access or use our website made available at https://journahealth.com and https://solareabio.com, which is hosted on Shopify (the “Shopify Site”), including when you make any purchases from the Shopify Site, as well as your choices related to your Personal Information. By accessing or using the Shopify Site, you acknowledge and consent to the practices described in this Privacy Policy regarding our collection, use and disclosure of your Personal Information. If you do not acknowledge and consent to the terms of this Privacy Policy, you may not use the Shopify Site.

2. The Personal Information We Collect.

“Personal information” is information that identifies, relates to, describes, or can be reasonably linked, directly or indirectly, to you as a particular individual or household. When you access or use the Shopify Site, Solarea may collect Personal Information in the following ways:

• Information You Provide: We collect information you provide directly to us. For example, we collect information when you participate in any interactive features of the Shopify Site, fill out a form, request customer support, use the Shopify Site or otherwise communicate with us. The types of information we may collect include:
  • identifiers, such as your full name, phone number, email address, postal mail address, online identifier, internet protocol address,
  • transaction information, including information about your purchases or receipt of products or services we offer,
  • financial account information, such as your credit card or other designated payment method used to purchase our products or services, and
  • any other information you choose to provide.
    
• Information We Collect Automatically: When you access or use the Shopify Site, Solarea may automatically collect information about you, including:
  • Log Information: We may collect log information about your use of the Shopify Site, including the type of browser you use, access times, pages viewed, your IP address, your general location and the page you visited before navigating to the Shopify Site.
  • Device Information: We may collect information about the computer or mobile device you use to access the Shopify Site, including the hardware model, operating system and version, unique device identifiers and mobile network information.
    
• Data provided by Others.
  We may obtain information about you from other companies and organizations, including inferences that may be made by such companies or organizations based on your information, such as data companies, payment processors, delivery partners, or other companies. We may combine the Personal Information you provide us with information that we obtain through other sources. As an example, if you purchase a product or service from the Shopify Site, we may receive certain information about your purchase and combine that with other information that we maintain about you. We may also draw inferences from any of the above-listed types of Personal Information we obtain to create a profile about you that reflects your preferences and characteristics.

3. Solarea’s Use of Information

Solarea may use Personal Information about you for various purposes, including to:

• Operate our business, including by providing the Shopify Site, our programs, and our products and services to you; and by processing your transactions, orders, or purchases;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about news and information we think will be of interest to you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Solarea and others;
  Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

4. Shopify.

Our store is hosted on Shopify Inc. (“Shopify”). Shopify provides us with the online e-commerce platform that allows us to sell our products and services to you. Your data is stored through Shopify’s data storage, databases and the general Shopify application. Please review Shopify’s Privacy Policy for more information about Shopify’s information practices: https://www.shopify.com/legal/privacy

5. Communication Preferences

By providing your contact information, you consent to receive electronic communications from Solarea (e.g., via email, text message or by posting notices on the Shopify Site). We may communicate with you about the Shopify Site, our products and other information that we think may be of interest to you. You agree that any notices, agreements, disclosures or other communications that we send to you electronically will satisfy any legal communication requirements, including, but not limited to, that such communications be in writing. You may manage your communication preferences by clicking the unsubscribe feature included in the email you receive.

By providing your phone number, you authorize Solarea (or those acting on its behalf) to communicate with you by telephone (including cell phone), text message, or any automated or prerecorded message or call for marketing, operational, informational and transactional purposes. You may opt out of automated calls or text messages by texting "STOP" to the number from which you received the call or text message. Your consent to receive calls and text messages is not required to make a purchase or to use our Shopify Site.

6. Data Collection Technologies

We and our service providers may use various tracking technologies, including cookies and web beacons, to collect information about you when you interact with the Shopify Site. Cookies are small data files stored on your hard drive or in device memory that help us improve the Shopify Site and your experience, see which areas and features of the Shopify Site are popular, and count visits. Web beacons are electronic images that may be used on the Shopify Site or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Shopify Site.

Analytics Services Provided by Others. We may allow others to provide analytics services on our behalf. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Shopify Site and other websites, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by Solarea and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Shopify Site and other websites and better understand your online activity.

Notice concerning Do Not Track. Do Not Track is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on the Shopify Site for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a “Do Not Track” privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals.

7. Disclosing Your Information.

We may share information about you, including Personal Information, as follows, or as otherwise described in this Privacy Policy:

• With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
• In response to requests from local, state, provincial or federal law enforcement officials, any judicial, administrative or similar proceeding or order, such as a subpoena if we believe disclosure is in accordance with, or required by any applicable law;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Solarea and others;
• To investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the Shopify Site’s rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among Solarea and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
  With your consent or at your direction;
• To comply with transparency or other public reporting obligations; and
• As otherwise permitted or required by law.

8. Security of Personal Information

Solarea has reasonable and appropriate safeguards in place to help protect the Personal Information that Solarea collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Although Solarea attempts to protect the Personal Information in our possession, no security system is perfect, and Solarea cannot promise that your Personal Information will remain absolutely secure in all circumstances.

9. Links to Third Party Websites

The Shopify Site may contain certain links to third party websites. Solarea is not responsible or liable for the privacy practices or content found on these websites. You should check the privacy notice and policies of each website you visit. Links to third party websites are provided solely for your convenience and any use or submission of data to such websites shall be at your sole risk.

Additionally, Solarea is not responsible for Shopify’s independent processing of your Personal Information. Please review Shopify’s Privacy Policy for more information about Shopify’s information practices: https://www.shopify.com/legal/privacy

10. Your Privacy Rights

Individuals in certain jurisdictions may have legal rights with respect to their Personal Information. You may have the right to: (i) request additional disclosures about the Personal Information we collect, use, and share; (ii) request access to and deletion of your Personal Information, subject to certain exceptions; (iii) opt out of the sale and sharing of your Personal Information; (iv) correct inaccurate Personal Information that we maintain about you; (v) limit the use and disclosure of sensitive Personal Information; and (vi) obtain a copy of your Personal Information. We will not discriminate against you for exercising any of these rights.

Methods for submitting requests. If you wish to exercise any of these rights, please email info@journahealth.com with the phrase “Privacy Rights” in the subject line. You may also send a request to us via mail at Solarea Bio, 100 Beaver St, Waltham, MA 02453 (please mark the envelope ‘Data Protection Officer’), or call us toll-free at 833-456-8762. We will process your request within the timeframe provided by applicable law. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. You may have the right to appeal our decision with respect to a request you have submitted by emailing us at info@journahealth.com. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a privacy rights request.

If you make a request related to Personal Information about you, you will be required to supply a valid means of identification as a security precaution. We will verify your identity with a reasonably high degree of certainty using the following procedure where feasible: we will match identifying information you provide when making the request to the Personal Information maintained by us, or use a third-party identity verification service. If it is necessary to collect additional information, we will use the information only for verification purposes and will delete it as soon as practicable after complying with your request. For requests related to particularly sensitive information, we may require additional proof of your identity.

Authorized Agents. You may use an authorized agent to submit a right to know or right to deletion request. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request for you. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit adequate proof that you authorized them to act for you.

Sales and Sharing of Personal Information. Under the CCPA, a ‘sale’ is defined broadly to include disclosing or making available Personal Information to a third-party in exchange for monetary compensation or other benefits or value, and ‘share’ broadly includes disclosing or making available Personal Information to a third party for purposes of cross-context behavioral advertising. As such, while we do not disclose Personal Information to third parties in exchange for monetary compensation, we may, pursuant to the CCPA or other applicable law, sell or share Personal Information with advertising networks and third party ad companies and data analytics providers in order to analyze use of the Shopify Site, optimize and develop our products and services, improve and measure our ad campaigns, and reach users with more relevant ads and content. However, we do not knowingly sell or share Personal Information about individuals who are younger than 16.

Verification. When you exercise your right to know or right to delete, we will take steps to verify your identity with a reasonably high degree of certainty before processing your request. We may ask for additional information so that we can verify your identity. If it is necessary to collect additional information, we will use the information only for verification purposes and will delete it as soon as practicable after complying with your request. We will only use the personal information you provide to us in response to this request to verify your identity and to process your request, unless you initially provided the information for another purpose. 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.

Shine the Light: Individuals who are California residents may request (i) a list of categories of Personal Information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please send us an email or a letter to the addresses in the section entitled "Contact Us" below and specify you are making a "California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

11. Transfer of Information to the United States

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Shopify Site or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S.

12. Changes to the Privacy Policy

Solarea may change this Privacy Policy at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Policy, which if we do so may be by means such as by posting a notice directly on the Shopify Site, by sending an e-mail notification (if you have provided your e-mail address to us), or by other reasonable methods. In any event, if you use the Shopify Site after changes to this Privacy Policy, you have accepted the changes. If you do not agree with the changes, please stop using the Shopify Site.

13. Contact Us

If you have any questions or concerns related to this Privacy Policy, please contact us at:

Journa Health
@ Solarea Bio
100 Beaver Street
Waltham, MA 02453
Phone: 833-456-8762
Email: info@journahealth.com