PRIVACY POLICY

Soteria LLC (“Company,” “we,” or “us”) has developed this document (“Privacy Policy”) to explain what information we collect about visitors and users of our website located at www. strikewithavital.com and our “Strike with Avital™” mobile application, and users and subscribers (together referred to as “Users” or “you”) of our Services (as defined in the Terms of Use) and how we use this information. This Privacy Policy applies to all Services offered by and through us, regardless of how you access or use them. If you have any questions about this Privacy Policy, you can contact us at support@strikewithavital.com.

Any capitalized terms not defined in this Privacy Policy have the meaning assigned to them in our Terms of Use (“Terms”).

The privacy of those who use our Services is important to us. We design and operate our technology and services with our Users’ protection and privacy in mind. This Privacy Policy outlines the types of information we gather when Users access or use the Services or contact us, as well as some of the steps we take to safeguard it against unauthorized use.

1. WHAT INFORMATION IS COLLECTED ABOUT YOU

1.1. We do not routinely collect Personally Identifying Information from Users using the Services; however, Users may submit it voluntarily. From time to time, we may allow third parties to ascertain certain data through the use of web analytics services and tools to collect statistical data on the use of the Services. This data includes, but is not limited to, how individual Users interact with the Services, how frequently Users log in, what features are utilized, and how long a User spends on the Services, allowing us to create a more personalized experience.

1.2. We may automatically receive and store certain technical information about your device and the systems you use to connect with us and use our Services. We may use software tools to collect information about visits to our website and the use of our Services. For example, we may make use of a standard feature found in browser software, called a “cookie,” to assign each visitor a unique, random number. Cookies allow us to track the pages on our website visited by Users and to collect other statistical information. Using cookies helps us to deliver a more personalized service to our Users and to improve our services. We may further use cookies to monitor potential fraud and abuse of the accounts or use which is not in accordance with the Terms. It is your choice whether to accept or reject cookies and you can set your browser to reject cookies altogether or to reject our cookies in particular or to delete these cookies. However, if you choose to reject cookies or delete them, it may limit some of the functionalities available or affect your experience with the Services.

1.3. We do not knowingly collect or maintain Personally Identifying Information from Minors.

1.4. We will only retain Collected Information (as defined in Section 2.1) for as long as is necessary for the purposes for which it was collected.

2. WHAT WE DO WITH COLLECTED INFORMATION

2.1. We may use and disclose the information collected, including, without limitation, Personally Identifiable Information and Anonymous Information (collectively, “Collected Information”) in various ways, including without limitation to:

We may disclose Anonymous Information for any purpose, subject only to limitations by applicable law or unless otherwise agreed to in writing.

3. USE, REGISTRATION, AND SUBSCRIPTION

3.1. MINORS MAY NOT USE THE SERVICES WITHOUT CONSENT OF A PARENT/LEGAL GUARDIAN. IF WE LEARN THAT ANY PERSONAL INFORMATION ABOUT ANY MINOR HAS BEEN COLLECTED WITHOUT PROPER CONSENT, WE WILL TAKE REASONABLE STEPS TO DELETE ANY SUCH INFORMATION.

3.2. A NOTE TO KIDS UNDER 18: You must get permission from your parents/legal guardians before using the Services. The Services may offer subscription based services. If you wish to subscribe to any of the Services, your parents/legal guardians need to complete the subscription form for you.

3.3. As part of our subscription and/or registration process, you may be asked to voluntarily submit limited personal information in order to create an account (including, without limitation, (i) full name, email address, telephone number and physical address; (ii) user name and password; and (iii) payment information (if applicable)).

3.4. We will not sell or market directly to Minors and always seeks parental or legal guardian’s authorization whenever we identify that a Minor attempts to purchase a Company product or service or provide Personally Identifying Information to us. We will not knowingly allow minors to subscribe, register, or otherwise submit Personally Identifying Information, without verifiable consent from a parent or guardian.

3.5. We will use subscription or registration information provided by Users only to provide or update our services.

3.6. Unless otherwise prohibited by law, we may provide your contact information to our partners, business affiliates or to third party service providers who work with us or operate some of our functionalities or our related services or communications with you. For example, we may use third parties to help us deliver our Services to you, process payments, provide customer service, conduct market research or information analysis or contact you in connection with our Services. However, the partners and business affiliates are authorized to use the contact information only to deliver our services or notices regarding our services, such as customer support, billing or other ancillary services, to you. In no event shall the business affiliates or partners be authorized by us to use the contact information for other purposes, which are not related to delivering our services or notices to you and will not be authorized to contact you directly for other purposes. You may be able to register to receive updates and promotions or site surveys. The contact information you submit will not be used for these purposes unless you specifically opt in. If you opt in to receive updates, promotions, or site surveys, you may opt out at any time thereafter by following the link embedded in any individual transmission.

3.7. We may use the collected information about your browser, operating system or other technical details of your usage to improve your experience with our services. We may further use the collected Anonymous Information about usage patterns, time of usage and form of usage, to improve the experience and to be able to improve the offering of our services to you.

3.8. We may allow you to download mobile applications, including without limitation the “STRIKE WITH AVITAL” mobile application, from us and/or from third party providers for your use on your mobile device. Your use of such mobile applications is subject to our Terms and this Privacy Policy and may require our collection of certain additional Personally Identifying Information that uniquely identifies your mobile device, including, but not limited to the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, mobile carrier information, geolocation information (if you enable this feature), information about the way you use the mobile applications, and information that we may obtain from device features you allow us to access such as photos and voice data. Depending on the nature of the mobile device and the network you are utilizing to access the mobile applications, additional Personally Identifying Information about you and your device may be collected as a result of network and device settings.

4. TRANSFER OF PERSONALLY IDENTIFYING INFORMATION IN BUSINESS TRANSITION

If the Company, in the future, will go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personally Identifying Information may be among the assets transferred. You expressly acknowledge that such transfers may occur, and that any acquirer of the Company or its assets may continue to use your Personally Identifying Information as set forth in this Privacy Policy. You hereby consent to such use if done according to this Privacy Policy.

5. USE OF METADATA

Where applicable and permitted by law, we may use the metadata, including, but not limited to, tags, search history, links, comments, posts and clickstreams, which is created in the process of using the Services to enrich User experiences and provide Users and affiliates with useful information, in accordance with this Privacy Policy. We may use this collected information for targeted services and contextualized placement of sponsored content. However, search history information may be shared with third parties only in its anonymous form (i.e. the Anonymous Information) and without disclosing any Personally Identifying Information which is associated with or related to this information.

6. SECURITY PRACTICES

6.1. We take reasonable steps, commensurate with the industry practices, to protect the Personally Identifying Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. We have put into place reasonable organizational, technical, physical, and managerial procedures to safeguard and secure the Personally Identifiable Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and while maintaining this information.

6.2. No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot guarantee the security of Personally Identifiable Information on or transmitted via the Internet.

7. NEWSLETTERS AND SERVICE-RELATED ANNOUNCEMENTS

If a User wishes to subscribe to our newsletter(s), we will use his or her name and email address to send the newsletter. We provide a simple way to unsubscribe from the newsletter at the bottom of each email. We will send Users service-related announcements on rare occasions when it is necessary or advisable to do so. For instance, if our service is temporarily suspended for maintenance, we might send an informational email.

8. LEGALLY REQUIRED DISCLOSURE

We reserve the right to disclose your Personally Identifiable Information if we are required to do so by law or if we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process.

9. DISCLAIMER REGARDING LINKED SITES

While using the Services, you may be linked from or to third parties sites. While we are not responsible for information, content, terms of use of privacy policy at these sites, we take careful notice in choosing business partners and affiliates and aim to associate only with reliable partners which are committed to users’ privacy. However, remember that when you use a link to go from the Services to a third party website, this Privacy Policy is no longer in effect. By your browsing and interacting on any other website, including websites which have a link on the Services, you are subject to that website’s own rules and policies. Please read those rules and policies carefully before proceeding.

10. LEGAL JURISDICTIONS

10.1. The Services are hosted in the United States of America. If you are accessing the Services from other jurisdictions, please be aware that you are transferring your personal information to us in the United States. By using any of the Services, or providing us with any information, you fully understand and consent to the collection, transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.

10.2. In providing the Services to you, you understand that information may be stored or processed in different locations around the world by us or by third party service providers. For example, information collected within the European Economic Area may be transferred to countries outside of the European Economic Area for the purposes described in this policy. If you reside in the European Economic Area, you have certain rights to the Personally Identifiable Information that we have collected about you. To exercise your rights to your Personally Identifiable Information please contact us at support@strikewithavital.com.

10.3. Any persons accessing the Services from any jurisdiction with applicable laws or regulations governing the use of the Internet, including personal data collection, use and disclosure, may only use the Services in a manner lawful in their jurisdiction. If your use of the Services would be unlawful in your jurisdiction, you must not use the Services.

11. CALIFORNIA RESIDENTS

California residents may have additional personal information rights and choices. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information including without limitation the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To learn more about your California privacy rights, please contact us at support@strikewithavital.com.

12. CHANGES TO THIS PRIVACY POLICY

The Internet is a dynamic and ever changing medium and as new or changed products and services are released and threats and technologies evolve, changes to this policy may be required. We reserve the right to amend this Privacy Policy at any time. We expect most such changes to be minor, but there may be cases where changes may be more significant. We urge you to examine this Privacy Policy for changes when using the Services. Posting the modified Privacy Policy on the Services will give effect to the revised terms. Your continued use of the Services indicates your acceptance of any revised terms. If you do not agree to the Privacy Policy as in effect from time to time, you must not use the Services.

13. CONTACT US ABOUT PRIVACY

If you have any questions or concerns about this Privacy Policy, or our software or website practices, or anything related to the Services, please contact us at support@strikewithavital.com.