Last revised: November 16, 2020

This Privacy Policy (the “Policy”) describes the type of information Healthy Spot LLC, or any of its divisions or affiliates (collectively “Healthy Spot,” “we,” or “us”) collect from and about you when you visit our website (www.Healthyspot.com or the “Site”), visit or make a purchase at our stores (each a “Store”), or otherwise contact or interact with us through our online service providers (“Online Services”) or offline (“Offline Services”). The Site, Stores, Online Services, and Offline Services are collectively referred to as the “Services.” This Policy also explains how Healthy Spot may use and share your personal information, as well as your ability to control certain uses of it. This Policy applies to all visitors, users, and others who use the Services (“consumers” or “you”). We adopt this Policy in compliance with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. By accessing or using the Services, you agree to the collection, storage, use and disclosure of your personal information as described in the Policy and agree to the Healthy Spot Terms of Service (https://healthyspot.com/termsofservice) which are incorporated by reference. Please do not use or access the Services if you do not agree, thank you.

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, through your use of the Services, we have collected the following categories of personal information within the last twelve (12) months:

Categories	Examples	Do we collect or have we collected in last 12 months?	Do we “sell” your personal information that we collect?	Do we disclose your personal information for a “business purpose?”
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers	YES	NO	YES
Personal information categories listed in Cal. Civ. Code § 1798.80(e)	A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information	YES	NO	YES
Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)	NO	NO	NO
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies	YES	NO	YES
Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data	NO	NO	NO
Internet or other electronic activity information	Browsing history, search history, and information on a consumer’s interaction with an Internet Web site, application, or advertisement	NO	NO	NO
Geolocation Data	Physical location or movements	NO	NO	NO
Sensory Data	Audio, electronic, visual, thermal, olfactory, or similar information	NO	NO	NO
Professional or employment-related information	Current or past job history or performance evaluations	NO	NO	NO
Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records	NO	NO	NO
Inferences	Inferences that could be used to create a profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities or aptitudes	YES	NO	YES

Personal information does not include:

• Publicly available information from government records;
• De-identified or aggregated consumer information;
• Information excluded from CCPA’s scope, like personal information protected by other certain sector-specific federal or California statutes.

2. HOW WE COLLECT PERSONAL INFORMATION

We obtain the categories of personal information listed above from the following categories of sources:

• Directly From You: The information you provide while using the Services whether online or in person at our Stores.
• Indirectly From You: We, or our service providers may use various technologies such as cookies, web beacons, pixel tags, log files, HTML5, or other technologies to collect personal information about visitors to, and users of our Site and our Online Services. We may also collect personal information through your interactions with our emails and online advertisements. We use this information to keep track of analytics and certain statistical information, to ensure the Site and Online Services function properly, to better understand how users interact with the Site and the Online Services, and for other purposes consistent with this Policy.
  
  or example, we or our service providers may automatically collect certain information from you, including but not limited to your browser type, device type, operating system, Internet Protocol (“IP”) or Media Access Control (“MAC”) address, unique device identifier of any of your computer(s) or device(s) that are used to access the Site, software version, and the domain name from which you accessed the Site. We or our service providers may also collect information about your use of the Site, including the date and time you visit, the areas or pages that you visit including types of products or services, the amount of time you spend viewing or using the Site, the number of times you return to the Site, other click-stream or Site usage data, and emails that you open, forward or click-through to our Site.
• Collected and/or Received From Third Parties: We use third party analytics and tracking tools to understand who is using the Services, how they are using the Services and how to improve the quality of the Services. We, or our service providers may use information about your visits to our Site or use of the Online Services, and information from your email to serve more targeting advertising to you. These third parties may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, HTML5 cookies, or other technologies to collect and store information automatically collected. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

3. HOW WE USE PERSONAL INFORMATION

We may use the personal information we collect for one or more of the following purposes

• To fulfill or meet the reason you provided the information;
• To provide, support, and personalize our products and services for and through our Services;
• To create, maintain, and service accounts;
• To process your requests and payments, and fulfill orders and transactions;
• To verify consumer information;
• To personalize your experience for certain Services and to deliver content and product and service offerings relevant to your interests, including targeted offers and advertisement through our Site and via mail or email (with your consent, where required by law);
• To provide advertising and marketing services;
• To provide analytic services;
• To detect and respond to security incidents or policy violations;
• To improve our Services;
• For testing, research, analysis, and product development;
• For auditing related to a current interaction with the user and concurrent transactions, including but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with laws and other standards;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• To establish, exercise, or defend legal claims or as otherwise permitted by law;
• As described to you when collecting your personal information or as otherwise set forth in the CCPA;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Healthy Spot’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Healthy Spot about our Services’ users is among the assets transfers.

Healthy Spot will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

4. SHARING PERSONAL INFORMATION

Healthy Spot may disclose your personal information to a third party for a business purpose. When we disclose your personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to keep your personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category:	Identifiers
Category:	Personal information categories listed in Cal. Civ. Code § 1798.80(e)
Category:	Commercial information
Category:	Inferences drawn from any of the information identified above

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers: Companies that provide services for direct mail, marketing emails, marketing paid advertising, direct customer outreach for operations/transactions, reviewing customer footage on traffic cameras.

• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information and therefore also do not have actual knowledge of any sales of personal information of minors under the age of 16.

5. DATA SECURITY

We have implemented measures designed to secure and safeguard your personal information from accidental loss and from unauthorized access and disclosure. We maintain physical, electronic, and administrative procedures to limit access to your non-public personal information.

Unfortunately, transmission of information via the internet is not completely secure. Although we take reasonable precautions to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Sites or other electronic means. Any electronic transmission of personal information is at your own risk.

6. YOUR RIGHTS AND CHOICES

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you, based on the nature of your request for access:

• The categories of personal information we collected about you;

• The categories of sources for the personal information we collected about you;

• Our business or commercial purpose for collecting that personal information;

• The categories of third parties with whom we share that personal information;

• The specific pieces of personal information we collected about you; and/or

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• sales, identifying the personal information categories that each category of recipients purchased; and

• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• Debug products to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• Comply with a legal obligation;

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access and Deletion Rights

To exercise the access and/or deletion rights described above, please submit a verifiable consumer request to us by either:

• Visiting www.HealthySpot.com/CCPA

• Emailing us at help@HealthySpot.com

• Calling our toll-free number and leaving a voicemail at (800)309-4021

Only you, or someone legally authorized 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.

You may only make a verifiable consumer request related to your personal information twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This may include, without limitation, your first name, last name, email address, and phone number. You may also be required to sign a declaration under penalty of perjury that the person making the request is the person about whom the personal information was collected.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

• If your request is being made through your authorized agent, in addition to the above, please have the agent provide signed permission from you for Healthy Spot to interact with the agent with respect to the requests being made, or in the alternative, please contact us directly to confirm that the agent has the authority to make requests on your behalf. The authorized agent may also submit a valid power of attorney.

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. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will use only personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For requests for specific pieces of personal information, we 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. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

7. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or service;

• 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;

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

8. CHANGES TO OUR PRIVACY NOTICE

Healthy Spot reserves the right to amend this Policy at our discretion and at any time. When we make changes, we will update the Policy’s effective date, notify you via email at the last email address that you provided us, and post the updated notice on the Site. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

9. CONTACT INFORMATION

If you have any questions or comments about this Policy, the ways in which Healthy Spot collects and uses your information described herein, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: www.HealthySpot.com
Email: help@HealthySpot.com
Phone: (800)309-4021

Postal Address:
Healthy Spot LLC
6089 Bristol Parkway, Suite 200
Culver City, CA 90230

10. NOTICE OF FINANCIAL INCENTIVE

• The MIND BODY BOWL Benefits Loyalty Program provides Participants the opportunity to receive and redeem loyalty rewards points (“Points”), on an individual basis and solely for their own account. The MIND BODY BOWL Benefits Loyalty Program may be structured to offer certain benefits based on the Participant’s current number of "redeemable" Points (that is, Points that have been received and that have not previously been redeemed).

• Participants in good standing will receive 5 Points for every $1 spent on qualifying purchases at any Healthy Spot location or at www.healthyspot.com. Sales tax, shipping fees, tips and purchases made with a Healthy Spot gift card do not qualify for points. Third party purchases via Instacart, DoorDash, Amazon etc. do not qualify for points either.

• For your purchase to qualify for the MIND BODY BOWL Benefits Loyalty Program, you must be enrolled as a Participant in the MIND BODY BOWL Benefits Loyalty Program and (a) your in-store account must be linked to your online MIND BODY BOWL Benefits Loyalty account at the time of purchase online or your online account registration must be completed within 24 hours of signing up in store; or (b) you must be signed into your MIND BODY BOWL Benefits online account when making an online purchase at www.helathyspot.com. To participate in the program, you must provide your first name, last name and email address.

• Customers can opt into the program at any Healthy Spot store by letting the team member know they would like to join the program and the team member will then update the customer’s Loyalty Status to “New Member.” The customer will receive an email to verify their email address and set up their account. The customer’s account must be created and confirmed at healthyspot.com in order to be valid. Customer can also register for an account at healthyspot.com at www.healthyspot.com/account/register.

• The customer can deactivate their account at any time by clicking on the link “Looking to close your account?” provided at www.healthyspot.com/account.

• It is necessary for Healthy Spot to retain your name and email address in order for Healthy Spot to be able to provide these incentives to you. The value of your name and email address are also reasonably related to the financial incentive offered. The value of your name and email address is derived by considering the additional profit generated by Healthy Spot from the collection and retention of customers’ names and email addresses, which is approximately 5%. This additional profit increase was calculated by utilizing historical data from comparable loyalty programs and as advised by the expertise from our loyalty program partner.