The undersigned, Reboot Holdings Pty Ltd, a private limited company, with registered office in 433 Broadway, New York, NY 10013, United States (“Reboot”) hereby provides this information notice (the “Privacy Policy”) regarding the protection of personal data, in compliance with applicable laws and regulations, in particular, where applicable, European Regulation no. 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movements of such data (the “GDPR”)

For the purposes of this Privacy Policy, “Personal Data” means any information concerning an identified or identifiable natural person; “identifiable” means any natural person who can be directly or indirectly identified, by reference to an identifier such as, for example, a name and surname, date and place of birth, address, email address and telephone number.

This Privacy Policy applies to the website https://rebootwithjoe.com owned and operated by Reboot as well as to Reboot’s mobile device applications (i.e. “Reboot Juice Diet: Reboot Tracker” and “Thyroid Diet App”, together the “Apps”) for iPhone, iPad and mobile devices running on Android operating system. This Privacy Policy also applies to any information obtained by Reboot from any third party website or service which is integrated with the Reboot website or Apps or on which Reboot publishes its own advertisements, such as Facebook, Google+ or Twitter (“Social Networking Websites”).

The processing of your Personal Data, provided and/or subsequently acquired by Reboot, is performed by Reboot in compliance with the principles of lawfulness, fairness and transparency and granting the protection of confidentiality, by means of appropriate security measures and provided that you give your consent, when required.

Reboot acknowledges the importance of your privacy and respects your privacy choices. Furthermore, Reboot wants to ensure that you are perfectly aware of how the information relating to your Personal Data may be used.

The security of your Personal Data is important to Reboot. Reboot uses commercially reasonable administrative, technical, personnel and physical measures to safeguard your Personal Data in our possession against loss, theft and unauthorized use, disclosure or modification.

Notwithstanding Reboot’s efforts to protect your Personal Data, you should be aware that it is not possible to completely exclude the risk that an unauthorized third party may circumvent our security systems or intercept the transmission of your Personal Data over the Internet.

This Privacy Policy reflects Reboot’s commitment to the principles referred above and explains:

A. Categories of processed data
B. Lawfulness of processing
C. Purposes of the processing of the Personal Data
D. Recipients or categories of recipients to whom or which the Personal Data may be communicated
E. Retention of Personal Data
F. Processing of Personal Data of minors
G. Data subject rights
H. Data controller and data processors
I. Changes to this Privacy Policy
J. Caution when Sharing Information in Community Forums.

A. CATEGORIES OF PROCESSED DATA

A.1 Personal Data

Should you provide it, Reboot may collect the following Personal Data:

• Name
• Age
• Email Address
• Mailing Address
• Telephone Number(s)
• Social Networking Handle or Username
• Photo or Video
• Personal Health Information (e.g. weight, waist, blood pressure, blood work’s data, etc.)

In relation to Personal Data concerning health, Reboot will work to maintain the privacy of all health information that you may provide. Reboot is currently not subject to the privacy and security requirements of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or any other laws applicable to medical professionals and healthcare providers (or other “covered entities”).

If you chose to use any Social Networking Websites, if a specific consent is given, Reboot may receive Personal Data from such Social Networking Websites, including, but not limited to:

• Name
• Nickname or Username
• Email Address
• Photo or Graphic Avatar
• Unique Third Party Website Identifier (e.g., Facebook User ID)
• Biographical or Demographic Information (e.g., gender, college attended, professional title, etc.)
• Likes and Interests
• Personal Contacts Friends / Associations
• Any Information that Is Publicly Available on Third Party Websites

Any information Reboot receives from Social Networking Websites will be processed according to this Privacy Policy, provided that Reboot is not responsible for compliance with the policies or practices of any Social Networking Site. You should ensure that you are comfortable with the information such Social Networking Sites may make available to Reboot by reviewing those Social Networking Sites’ privacy policies and service terms, and by modifying your privacy settings and preferences on those web sites accordingly.

With respect to Personal Data collected by Reboot through the Reboot Apps, a random number will be assigned to your App installation, which cannot be used to identify you, unless you choose to become a registered user of a Reboot App. Reboot does not obtain any information about your mobile device other than the brand, model and type of operating software your device uses, which do not qualify as Personal Data.

Personal Data is stored in the US, through Amazon Web Services, whose servers are located in Virginia and which acts in its capacity as processor on behalf of Reboot.

A.2 Non-Personal Data

Please refer in particular to Paragraph “Reboot with Joe Cookies Policy”.

B. LAWFULNESS OF PROCESSING

The Personal Data is processed by Reboot only if the data subject has given consent to the processing of his/her Personal Data, for one or more of the specific purposes set out in Paragraph C of this Privacy Policy.

C. PURPOSES OF THE PROCESSING OF PERSONAL DATA

Reboot uses the Personal Data obtained from you in order to provide you with products and services, to fulfill your requests, to improve our products and services, to personalize and tailor your experience on the Reboot website, to operate Reboot’s business, and to understand how users are engaging with Reboot. More specifically, the Personal Data collected is processed by Reboot for the following purposes:

i. registration on the Reboot website, in relation to the services provided by Reboot through its website, to the extent strictly necessary for the supply of such services (as a way of example, participating in the Reboot forum community), and in particular to manage the user account, to respond to inquiries and to issue communications in connection with the required services;

ii. delivery of commercial communications, advertising, informative or promotional material for direct marketing purposes, by means of non-automated/traditional decision-making (such as phone calls or paper-based mails) and/or automated decision-making (such as emails);

iii. provide a nutrition tracking to the users of the Reboot Apps, subject to your freely given, specific, informed, unambiguous and explicit consent;

iv. delivery of commercial products purchased by users through the e-commerce channel on the Reboot website;

v. fulfillment of requests for customized services, subject to your freely given, specific, informed and unambiguous consent.

The contribution of your Personal Data is free and optional. Reboot suggests that you give your consents to the processing of your Personal Data for one or more of the above-mentioned purposes only after having read the full Privacy Policy. However, if you choose not to provide Personal Data in relation to items (i), (iii), (iv) and (v) above you may still use the Reboot website but you may be unable to access certain features or services, as for example the participation in the forum community, the supply of a nutrition tracking or the shipping of the orders made by the user through the e-commerce channel on the Reboot website.

D. RECIPIENTS OR CATEGORIES OF RECIPIENTS TO WHOM OR WHICH THE PERSONAL DATA MAY BE COMMUNICATED

Reboot does not provide any of your Personal Data to third parties, unless required by law. Your Personal Data may be communicated by Reboot for the same purposes described in paragraph C above to (i) its employees and external workers, (ii) companies and/or external workers entrusted with the management of administrative services on behalf of Reboot, in relation to the fulfillment of their contractual or legal obligations, or (iii) other third parties who cooperate to the implementation of the services provided by Reboot.

Such parties to which your Personal data are communicated shall act as data processors or persons in charge of the processing of your Personal Data and shall be duly appointed and instructed by Reboot accordingly.

Notwithstanding the foregoing, from time to time, Reboot may provide you with the opportunity to opt-in to receive promotional offers and marketing communications from our affiliates and commercial partners. If you do not opt-in, Reboot will not send you any such promotional offers. In case you give your specific, informed and unambiguous consent, you may also opt-out of receiving any such promotional offers, at any time, by clicking on a dedicated link which is provided in the body of any of such communication received.

E. RETENTION OF PERSONAL DATA

Personal Data acquired by Reboot shall be stored for the following periods, depending on the purposes for which it has been collected. In particular, if collected:

i. pursuant to Paragraph C(i) above, Personal Data can be used by Reboot until the user does request to unsubscribe from the Reboot website and to disable its account;

ii. pursuant to Paragraphs C(ii) and (C)(iii), Personal Data can be used until the user revokes its consent;

iii. pursuant to Paragraphs C(iv), and C(v), Personal Data can be used for a period no longer than the time strictly necessary to provide the services offered by Reboot.

Please note that, under all circumstances, Reboot shall be entitled to store Personal Data for a period no longer than ten years for the sole purpose of complying with the obligations and controls required by law (e.g., anti-fraud controls, anti-money laundering controls, identity theft, etc.).F. PROCESSING OF PERSONAL DATA OF CHILDREN UNDER THE AGE OF 13

Reboot is committed to protecting the privacy of children. The Reboot website is not designed or intended to attract children below the age of 16 years. The Reboot website does not collect Personal Data from any person Reboot is aware being below the age of 16 years.

G. DATA SUBJECT RIGHTS

Users rights:

You may, at any time, exercise any right provided for by applicable laws, including:

i. the right to request the access to, and rectification or erasure of, your Personal Data or restriction of the processing concerning your Personal Data;

ii. the right to object to the processing of your Personal Data;

iii. the right to the portability of your Personal Data;

iv. the right to withdraw consent at any time, without affecting the lawfulness of the processing of Personal Data as carried out based on the consent provided before such withdrawal; and

v. the right to lodge a complaint before a supervisory authority

More specifically:

x. you may correct, update or review any Personal Data you have submitted through your registration in the Reboot website and/or Apps and/or Social Networking Websites and the update of your registration information. Once registered, if you wish Reboot not to use your Personal Data any longer, you should delete such information from your account (please note that, in given circumstances, it is not technically possible to remove immediately each and all of your records from our servers); and

y. you may update, at any time, your Personal Data that is stored on the Reboot website and/or change your account preferences on the Reboot website:

1. if you have an account on the Reboot website, you can log-in and update or change your account information;

2. you may unsubscribe to any of our email updates, posts, newsletters or supply of products by following the unsubscribe instructions included in the body of any communication sent by Reboot; and

3. you may contact Reboot on Personal Data-related matters at help@rebootwithjoe.com.

California Users Rights
California Law permits California residents who visit the Reboot website to request information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. To make such a request, California users should contact Reboot at the email address referred to above, including the contact details (i.e., name and address) which you would like to receive our response to.

H. DATA CONTROLLERS AND DATA PROCESSORS
The data controller in relation to your Personal Data is Reboot Holdings Pty Ltd, a private limited company with registered office in 433 Broadway, New York, NY 10013, United States, as duly represented by its pro tempore legal representative. A list of data processors in relation to your Personal Data is available at the Reboot’s Privacy Office.

The external data processors in relation to your Personal Data are:

• The Rocket Science Group (MailChimp);
• Acadaca LLC

If you have any queries or comments regarding this Privacy Policy, including any uncertainty related to the exercise of the aforementioned rights, please do not hesitate to contact Reboot, addressing your request to help@rebootwithjoe.com. You can also contact Reboot’s Privacy office at:

433 Broadway, Suite 416
New York, NY 10013

I. CHANGES TO THIS PRIVACY POLICY

Reboot reserves the right to change or modify this Privacy Policy or any of our tools or services at any time; any changes will be effective upon release unless explicitly declared otherwise. Should Reboot determine to make any material changes to this Privacy Policy, you will be notified by email (sent to the email address specified when you register) and/or by means of a notice on this website prior to the change becoming effective. Reboot encourages you to periodically review the Reboot website for the latest updates on the privacy practices. If you do not accept the terms of this Privacy Policy, you should not register and not use the Reboot website. Shall this be the case, please exit the Reboot website at your earliest convenience.

J. CAUTION WHEN SHARING INFORMATION IN COMMUNITY FORUMS

Reboot features public forums where users with similar interests can share information and support one another. Such forums are open to the public and should not be considered private. Any information (including Personal Data) you share in any online community area is not private. You should think carefully before posting any Personal Data in any public forum: the content of your post can be seen, disclosed to or collected by third parties and may be used by others in ways Reboot cannot control or predict, including to contact you for unauthorized purposes. Similarly to any public forum hosted on any other website, the information you post may also show up in third-party search engines.

If you mistakenly post your Personal Data in our community areas and would like it to be removed, you can send an email requesting such removal by using the “Contact Us” link on each page of the Reboot website. Nevertheless, you should be aware that, in some cases, your Personal Data may not be removed.