California Consumer Privacy Act

Notice to California Residents; Last Update:  February 1st, 2021

This Notice to California Residents (“CCPA Notice”), provided by Refresh Wellness LLC and its affiliates and subsidiaries (collectively “Refresh,” “we,” “us,” or “our”) pursuant to the California Consumer Privacy Act (“CCPA”), applies to California residents (“consumers” or “you”), that visit or access our website at (the “Website”), such as purchase products or services from us, or engage or interact with us. Any terms used herein but not defined shall have the meaning assigned in our Privacy Policy or the CCPA, as applicable.   

In the event of any conflict or inconsistency between this CCPA Notice and our Privacy Policy, this CCPA Notice shall control only with respect to the Personal Information (as defined in CCPA) of consumers, their households or devices. If you are located outside of the State of California this CCPA Notice does not apply to you and you should refer to our Privacy Policy. 

Information We Collect

Categories of Personal Information. Refresh Wellness has or may have collected and/or received the Categories of Personal Information identified below (with examples) from or about consumers, their households or devices, within the twelve (12) months preceding the Last Update of this CCPA Notice (“Last Update”).  Personal Information does not include (i) publicly available information from government records; (ii) deidentified or aggregated Personal Information; or (iii) information excluded from the CCPA including information regulated by certain sector-specific data protection laws including the Health Insurance Portability and Accountability Act of 1996,  the California Confidentiality of Medical Information Act, the Gramm-Leach-Bliley Act of 1999, and the California Financial Information Privacy Act. 

Identifiers.  Name, postal address, unique personal identifier, online identifier, IP address, email address, account name.

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)). A name, signature, address, telephone number, credit card number.

Protected classification characteristics under California or federal law. Age (40 years or older), sex (including gender, gender identity, gender expression).

Commercial Information. Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Professional or employment-related information. Current or past job history.

Categories of Sources. We collect the Categories of Personal Information listed above from the following Categories of Sources: (i) directly from consumers (e.g., forms, surveys, responses, or other direct interactions from or with consumers), (ii) indirectly from consumers (e.g., consumer activity online, interactions with our Website and other sites), and (iii) through our affiliate program.            

Use of Personal Information. We may use or disclose the Personal Information we collect for one or more of the following commercial or business purposes (each, a “Business Purpose”): (i) to investigate and to manage enquiries, disputes and legal proceedings, (ii) to comply with court orders, mandatory dispute resolution determinations and mandatory government authority or law enforcement orders or directions, (iii) as described to you when collecting your Personal Information or as otherwise permissible under the CCPA, (iv) to evaluate or consummate a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information is among the assets transferred, (v) to process and fulfill orders and payments, (vi) to communicate with Website visitors, customers, subcontractors and vendors, including through email marketing, (vii) to develop, implement, market, promote, and sell our products and services, (viii) to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, (ix) to help troubleshoot technical errors, (x) to create, maintain, customize, and secure your account with us, (xi)  to review and assess market trends and activities impacting our products and services, and (xii) to personalize your Website experience and to deliver content, product, and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

Categories of Third Party Recipients. We may share your Personal Information with the following Categories of Third Party Recipients for Business Purposes:

  • Service Providers, which include cloud hosting providers, technical assistance and security, database management/back-up services, analytics, digital marketing (e.g., marketing automation), customer relationship management, customer service, providers of administrative services, payment processors, suppliers, distribution channels, email marketing, reviews platform.

  • Social networks used for retargeting and creating audiences (“Social Networks”)

Disclosures and Sale of Personal Information for a Business Purpose. In the twelve months preceding the Last Update, we may have disclosed or sold the Categories of Personal Information for a Business Purpose to the Categories of Third Parties set forth in Table I.    

Table I

Categories of Personal Information Collected

Categories of Third Parties with Whom We Share this Personal Information for a Business Purpose

Categories of Third Parties with Whom We Sell this Personal Information for a Business Purpose


Service Providers

Social Networks

Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e))

Service Providers


Protected classification characteristics under California or federal law

Service Providers

Commercial Information

Service Providers


Internet or other similar network activity

Service Providers

Social Networks

Professional or employment-related information.

Service Providers



Your Rights and Choices

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes such rights and explains how to exercise them. 

Right to Know About Personal Information. You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your Personal Information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request): 

  • Specific pieces of Personal Information we collected about you in the preceding twelve months.

  • Categories of Personal Information we collected about you in the preceding twelve months.

  • Categories of Sources from which the Personal Information was collected 

  • Our Business Purpose for collecting that Personal Information  

  • Categories of Personal Information we disclosed or sold for a Business Purpose and the Categories of Third Party Recipients to whom the Personal Information was disclosed or sold

Right to Request Deletion. You have the right to request that we delete any of Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and verify your request, we will delete your Personal Information from our records, unless an exception applies. 

Exercising Rights to Know or Request Deletion. To exercise the rights to know or request deletion described above, please submit a verifiable consumer request to us by submitting your request by email at

You may only make a verifiable consumer request under the right to know twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 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 related to you. 

Verification Process. To submit a verifiable consumer request, the consumer may be required to provide up to three data points, which may include additional Personal Information, to enable us to verify the consumer’s identity with the degree of certainty required by the CCPA. We will use Personal Information provided in a verifiable consumer request solely for the purpose of verifying the requestor’s identity or authority to make the request. We or a third party on our behalf may follow up with you to determine whether a request is a verifiable consumer request under applicable law. If we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, we will deny the consumer request in whole or in part and will not to disclose the information requested or, as applicable, will not delete the information requested. We will respond to any such consumer request with a denial, and will also explain why it has no reasonable method by which it can verify the identity of the requestor.

Response Timing and FormatWe will confirm receipt of a verifiable consumer request within (10) business days. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. We will deliver our written response by mail or electronically. Any disclosures 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 data portability requests, 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. 

Right to Opt-Out of the Sale of Personal Information. 

If you are 21 years of age or older, you have the right, at any time, to direct us to not sell your Personal Information (the “right to opt-out”).

Our Services are not intended for children. Children under the age of 21 are not allowed to use our Services, and we do not knowingly collect information from children under the age of 21. If we suspect that a user is under age 21, we will promptly delete any personal information in that user’s account. 

Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, you or your authorized agent may submit a request by submitting your request via email at

Once you make an opt-out request, we will not ask you to reauthorize Personal Information sales for at least twelve (12) months. However, you may change your mind and opt back in to Personal Information sales at any time by sending us an email with an opt-in request at

You do not need to create an account with us to opt-out. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Right to Non-DiscriminationWe will not discriminate against you for exercising any of your CCPA rights. We will not deny you products or services, will not charge you different prices or rates for products or services, including discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CCPA, see below), will not provide you a different level or quality of products or services, and will not suggest that you may receive a different price or rate for products or services or a different level or quality of products or services.  

Our newsletter sign-up incentives involve the collection of personal information in exchange for promotions and other perks, they may be interpreted as “financial incentives” under the CCPA. To withdraw from any of our programs or incentives described in this Notice of Financial Incentives, please contact us at

Right to Designate an Authorized Agent

If you submit a request to know, delete or opt-out of the sale of your Personal Information through the use of an authorized agent, we may need that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

Other California Privacy Rights

Pursuant to California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. 

To make such a request, please contact us.  

Changes to Our CCPA Notice

This CCPA Notice is effective as of the date of the Last Update stated at the top of this CCPA Notice. We may change this CCPA Notice from time to time with or without noticing you. By visiting the Website, purchasing products or services from us, or engaging or interacting with us after we make any such changes to this CCPA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CCPA Notice in current effect.  Please refer back to this CCPA Notice on a regular basis. 

Contact Us

If you have any questions regarding this notice, or the ways that we collect and use your information described above and in the CCPA Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please contact us at: 



Mailing address:  

Suite 330, 4340 Von Karman Ave,

Newport Beach, CA, 90226