PRIVACY POLICY

If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using our Site or if you agreed to our Terms of Use Agreement, you agreetothis privacy policy. This policy may change from time to time (see Changes to Our Notice).Yourcontinued use of our Site after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates.  

Personal Information We Collect About You 

We collect several types of information from and about users of our Site, including information: 

• By which you may be personally identified, such as name, dates of birth, postal address, email address, cell and work telephone numbers, passport details, travel details including flight manifests, locations details, creditcardnumber, debit card number, or any other financial information and any other identifier by which you may be contacted online or offline ("personal information");  

• Regarding your commercial transactions, including records of or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; and 

• About your internet connection, IP address, the equipment you use to access our Site, your history on the Site, location information, telemetry data, user history and usage details.  

For example, we collect the following information:  

• When you register with us, we ask for information such as your name, postal address, zip code, email address, and telephone number. We also acquire your Internet protocol address and/or mobile device identification, whichcertainjurisdictions consider to be personal data because it could be used to identify an individual or device if it were combined with other identifying information. 

• We may also obtain your personal data with your express consent when you visit our spa and register for our treatment, information requested could include your name and date of birth and some health-related questions whichhelpdetermine if a treatment is right for you.  

• We may capture user information when users send us questions or comments via email. Information collected in this manner will only be used to contact the user and/or respond to the user’s inquiry/issue. Sending us an email will notenrollyou on our email list unless you specifically request it. 

• For purchases made on the Site, a third-party payment processor such as Authorize.net, Amazon Pay or Apple Pay may collect your name, email address, postal address, contact details and credit or debit card information. This record willbestored and processed in the United States and other countries (see further below under “How we use information about you” and “How we store and process information about you”). By making a purchase, you grant to us and to all otherpersonsand entities involved in the operation of the Site, the right to use, store, monitor, retrieve and transmit your account information in connection with the operation of the Site and as otherwise provided herein. You also agree thatsuchaccess and use of your Personal data is governed by their privacy policies. We are not responsible or liable for the content, activities or privacy policies of any third-party sites. Accordingly, please refer totheirrespective privacy policies. 

• We generally do not request on or through the Site other information that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personalhealthinformation, or government issued identification numbers (e.g., social security number, drivers’ license number, or passport number), although we reserve the right to do so when such information is necessary to offer youcertainservices. 

• We take reasonable precautions to protect the confidentiality and security of your personally identifiable information by using industry recognized security safeguards such as site monitoring, secured networks and servers, firewallsand/orencryption. When we ask for sensitive information, we protect it using encryption during transmission, such as SSL (Secure Socket Layer). Unfortunately, no method of transmission over the Internet is completely secure.Therefore,while we strive to protect your personally identifiable information within industry standards, we cannot guarantee its absolute security. 

• We may also obtain your Personal data through your use of social media and/or other websites such as Facebook, Twitter, Instagram, YouTube or Amazon, depending on your settings or the privacy policies of these websites. Tochangeyour settings on these services, please refer to their respective privacy notices. 

Lawful Basis for Processing Your Information  

How We Collect Personal Information About You 

We collect personal information about you: 

• Directly from you when you voluntarily provide it to us. 

• Automatically as you navigate through the Site and from your browser or device. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, andothertracking technologies used by SRMS. 

• Records and copies of your correspondence (including email addresses), if you contact us or submit an online request. 

• Through an account profile, if you create one with us.  

• When you contact us for assistance using our online chatbot 

• Through user history on our Site.  

A.    Information You Provide to Us  

The information that you provide to us through our Site may include: 

• Information that you provide by filling in forms on our Site. This includes information provided at the time of using our service, posting material, or requesting further services. We may also ask you for information when requestanassessment, purchase our products or services, talk with our employees, or when you report a problem with our Site. 

• Records and copies of your correspondence (including email addresses), if you contact us. 

• Details of transactions and reservations you carry out through our Site. You may be required to provide personal and financial information before using our Services and Site. 

• Through creation of accounts through our Site.  

B.    Information We Collect About You Automatically   

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: 

•  Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site. 

• Information about your computer and internet connection, including your IP address, operating system, and browser type. 

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Contact information on how you can opt out of behavioraltrackingon this Site and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking. 

The information we collect automatically includes statistical and analytical data and, in some instances, personal information. We collect such data automatically because it helps us to improve our Site and to deliverabetter and more personalized Service, including by enabling us to: 

• Estimate our audience size and usage patterns. 

• Store information about your preferences, allowing us to customize our Site Interface according to your individual interests. 

• Speed up your searches. 

• Recognize you when you return to our Site. 

The technologies we use for this automatic data collection may include: 

• Cookies (or browser cookies) [Link to Cookie Notice]. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookiesbyactivating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies,oursystem will issue cookies when you direct your browser to our Site.  

C.    Third-Party Use of Cookies and Other Tracking Technologies 

We do not use third parties to collect personal information. 

Data Controller and Joint Controller  

There are times we act as the Data Controller related to your personal information There are cases when we partner with our trusted partners and this responsibility is shared with such partners  

Our commitments with regards to your data are as follows:  

• We will provide an opportunity for you to be able to exercise your legal rights. 

• We will work with our partners to define roles and responsibilities for each partner with regards to your personal data. 

• We will ensure transparency when it comes to what are the joint purposes that we use or have when it comes to processing your personal data.  

Who we share your personal data with 

In certain instances, we may share your personal information with other companies both in the United States and in other countries around the world. We may disclose aggregated information about our users, and information that does notidentifyany individual, without restriction. Where we share your personal information with third parties, we will put in place contractual measures to require them to take reasonable precautions to safeguard your personal information, asrequiredby applicable laws. 

We may disclose personal information that we collect, or you provide as described in this privacy policy: 

• To our subsidiaries and affiliates. 

• To contractors, service providers, and other third parties we use to support our business. 

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all SRMS’s assets, whether as a going concern or as part ofbankruptcy,liquidation, or similar proceeding, in which personal information held by SRMS about our Site users is among the assets transferred. 

• To third parties to market their products or services to you if you have consented to and/or not opted out of these disclosures.  

• To fulfill the purpose for which you provided it.  

• For any other purpose disclosed by us when you provide the information. 

• With your consent. 

We may also disclose your personal information: 

• To comply with an appropriate UK or EU court order, law, or legal process, including to respond to any appropriate government or regulatory request. 

• To enforce or apply our Terms of Use and other agreements including for billing and collection purposes. 

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SRMS, our customers, or others. This includes exchanging information with other companies and organizations for the purposes offraudprotection and credit risk reduction. 

For example: 

• Service Providers. We may share information about you with companies we have chosen to handle our order dispatch service, any delivery company that we may use from time to time and with other companies that provide supportservicesto us, including website hosting companies, IT service providers and fraud management solution providers. We may also share your information with other companies who sell or promote our products and services, (including social mediaandinternet search platforms who you independently subscribe to), in order to provide you with an enhanced customer experience. In addition, we may also share certain limited information with companies who assist use with other services,forexample, in analyzing our customer data in order to better understand, profile and monitor customer patterns so we can consistently improve our products and services and understand what may be of interest to you and other customers.Ineach case, we will only provide these companies with the information which they need to carry out their services and they will not be permitted to use the information for other purposes. They will only be allowed to use your informationinthe way in which we instruct them and as permitted by applicable laws. 

• Order Dispatch and Delivery Partners. Where your order is delivered by one of our third-party delivery or order dispatch service providers (e.g. FedEx and UPS), only that information necessary for theirdeliverypurposes is provided. The privacy policy of that third party delivery or order dispatch service provider may also apply where that service provider also processes your personal data in their capacity as a data controller underapplicabledata protection laws. For more information, please visit the privacy policy on the website(s) of the applicable delivery or order dispatch service provider which delivers your order. 

• Financial Institutions, Payment Processing Partners and Fraud Management Solution Providers. Payments using our Site are made through our payment solutions providers. In such a case, you will be providing creditordebit card information direct to our providers who process payment details further. When you make a payment we may share your information, including details of your transaction, with service providers who provide fraud detectionandmanagement solutions related to your transaction.  

• Legal Disclosures. In certain circumstances (where required or permitted under applicable laws or with your consent (if so required by applicable laws), we may disclose personal information relating to you to thirdparties(including in other jurisdictions) in order to conform to any requirements of law, to comply with any legal or regulatory process, for the purposes of obtaining legal advice, for the purposes of credit risk reduction, to prevent anddetectfraud, At all times where we disclose your information for the purposes of credit risk reduction, fraud prevention and/or sanctions screening, we will take all steps reasonably necessary to help ensure that it remains secure. 

Additionally, in the following situations, we may share personal data with outside parties: 

• In connection with their content and advertisements, our Affiliates may collect personally identifiable information. For example: 

• SRMS is an Amazon Associate. In connection with the Amazon Affiliate Program, Amazon may monitor, record, use and disclose personal data about you obtained in connection with SRMS’ display of special links and programcontent(please review the applicable terms and policies, including the privacy and data gathering practices of Amazon for more information); and  

• SRMS has teamed up with Commission Junction LLC, a Conversant company (“CJ Affiliate”), to spread the word out about SRMS! CJ Affiliate may collect and share Personal data about you, such as your full name, home address,telephonenumber or email address, to help us provide digital advertising on browsers, mobile applications and televisions, in a variety of ways, from banner and video ads to coupon codes. For more information about CJ Affiliateor toopt-out, please review their applicable terms and policies. 

• Subsidiaries and Site Consultants and Service Providers. We may disclose personal data to our subsidiaries, third party consultants and service providers (such as providers of hosting, support, maintenance; thirdpartypayment processing agencies; and remedial and repair services) to the extent that they require access to our databases, or the information contained in our databases, to service us and the Site. 

• Reorganization or Sale. If we merge with or become a part of another organization, or if we are sold, we sell all or substantially all our assets, or we are otherwise reorganized, the information you provide willbeone of the transferred assets to the acquiring or reorganized entity. 

• Aggregated Information. We may aggregate information that you provide with information provided by other individuals in such a manner that the information is not personally identifiable to you, and we may transfer thataggregatedinformation to third parties. 

• We may make available services such as blogs, message boards and chat functionality to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on theSitebecomes public information and may be available to visitors to the Site and to the general public. In addition, when you choose to make a posting on such services certain Personal data will be available for otherusersto view. We urge you to exercise discretion and caution when deciding to disclose Personal data about you, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD PARTY OFANY PERSONALDATA YOU VOLUNTARILY DISCLOSE THROUGH ANY SUCH SERVICES OR OTHERWISE ON THE SITE; and 

• With your express consent. 

Personal data received from third parties