EFFECTIVE DATE: 12/01/2020

Sculpted Partners LLC, d/b/a The DB Method (“The DB Method,” Company,” “we,” “us,” “our”), provides this Privacy Policy to inform you about our collection, use, and disclosure of information when individuals visit our DB Method Applications (“Apps”) that link to this policy. This Privacy Policy may be updated from time to time. If we make changes, we will post the new Privacy Policy here. You are advised to consult this policy regularly for changes.

INFORMATION COLLECTION
When using our Apps, you may voluntarily provide information about yourself including, but not limited to, contact information such as your name, address, email address, and profile picture. We also may collect any other information you voluntarily provide, including information as part of participating in our subscription service, and information you publish or display on public areas of the Apps. We collect this information when you purchase our products, subscribe to a newsletter that we offer, send an email to us requesting information, respond to our surveys, or interact with us for any other purpose.
We collect information relating to your interactions with us and our Apps, including workout completion, number of workouts, type of workouts, and other workout-based data points to better understand the user experience and make improvements to the app. We also collect browser type, IP address, geolocation information, pages visited and other activities on the Apps, device type, time and date of usage, and other information we collect using SDKs and analytics tools. See the “Online Behavioral Advertising” section of this Privacy Policy to learn more about the use of this information and the choices available to you.

INFORMATION USE
We may use your information for any lawful purpose, including the following:
• To respond to your inquiries;
• To provide, activate, and manage your access to and use of DB Method services;
• To process and fulfill a request, order, download, subscription, or other transaction related to DB Method services;
• To operate and improve our Apps, including to provide better services, products, and opportunities to our customers and visitors to our Apps;
• To operate, personalize, and improve the Apps, including for analytics purposes;
• To send targeted advertisements, surveys, promotions, marketing materials, notices and other information that may be of interest to you or related to DB Method services;
• To prevent and detect fraud;
• To comply with the law and to maintain the security of our Apps; or
• With your consent, or as otherwise disclosed at the time information is collected.

INFORMATION SHARING
We may share the information we collect with other parties described in this section.
Affiliates. We may share information with our affiliates, which will handle the information under their own respective privacy policies. Per our agreements with our affiliates, the affiliates are required to keep your information confidential.
Services Providers. We may employ third-party companies and individuals to facilitate services for the Apps, to provide services on our behalf, to perform service-related functions (for example, payment processing, maintenance, database management, marketing, security and fraud purposes, App or advertising analytics, and improvement of the App’s features) or to assist us in analyzing how the Apps are used. Per our agreements, the service providers are required to keep your information confidential.
Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your information, in connection with a potential or actual merger, acquisition, reorganization or sale of some or all of our assets or in the event of bankruptcy.
With Consent. We may share your information with your consent or as otherwise disclosed at the time of data collection or sharing.
Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with applicable laws and regulations. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of The DB Method or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, harmful, unethical or legally actionable activity.
Aggregated or Anonymized Information. We may share information that has been anonymized or aggregated, or any other technical information, without limitation.

DIGITAL ADVERTISING & ANALYTICS
We may partner with ad networks and other ad serving providers that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information advertising providers collect about your use of the Apps and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising. We adhere to the {Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this activity}.
For more information on how to opt out of receiving interest-based advertisements, or to learn more about interest-based advertising please visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance at http://www.aboutads.info/choices/. For interest-based advertising in apps please use the DAA’s “AppChoices application” available at http://www.aboutads.info/appchoices. If you opt out, you may need to renew your opt-out choices exercised through the DAA AppChoices tool. Note that electing to opt out will not stop advertising from appearing in your application. It may make the ads you see less relevant to your interests.
We may also work with third parties that collect data about your use of the Apps and other apps over time for non-advertising purposes. The DB Method uses Google Analytics, together with Google Firebase and other third-party services, to improve the performance of the Apps and for analytics and marketing purposes. Google Firebase collects the following types of events: User interaction events in the app; content consumption data; device information such as manufacturer, model, and OS version; IP address and geographic location of the device based on the IP address; other general anonymous usage statistics. For more information about how Google Analytics collects and uses data when you use our Apps, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.

THIRD-PARTY LINKS AND TOOLS
The Apps may provide links to third-party websites or apps. We distribute the Apps through Apple and Google distribution platforms. We do not control the privacy practices of those websites or apps, and they are not covered by this Privacy Policy. You should review the privacy notices of other apps that you use to learn about their data practices.
The Apps may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Apps, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy notices of the companies that provide those features. We encourage you to carefully read the privacy notices of any accounts you create and use.

SECURITY
We have implemented commercially reasonable security measures in order to protect the information we collect. While DB Method strives to protect your personal information, we cannot guarantee the security of any information you disclose online.

YOUR CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Protection Act, California residents have certain rights with respect to the personal information collected by businesses. This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.
Personal Information We Collect. In the preceding 12 months, we collected the following categories of personal information about California consumers:

Personal and online identifiers (such as first and last name, email address, or unique online identifiers);
Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information);
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered);
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
Biometric information (such as call recordings);
Geolocation information;
Inferences drawn from the above information about your predicted characteristics and preference;
Other information about you that is linked to the personal information above.

Categories of Sources.
We collect personal information from the following categories of sources:

• Consumers;
• Advertising networks;
• Data analytics providers;
• Operating systems and platforms;
• Social networks;
• Service providers; and
• Affiliated entities.

Why We Collect, Use, and Share California Information. We use and disclose the personal information we collect for our commercial and business purposes, as further described in this Privacy Policy. These commercial and business purposes include, without limitation:
• Our commercial purposes, including:
o To provide you with products and services;
o To advertise our products and services;
o To provide you with news and information;
• Our business purposes as identified in the CCPA, which include:
o Auditing related to our interactions with you;
o Legal compliance;
o Detecting and protecting against security incidents, fraud, and illegal activity;
o Debugging;
o Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
o Internal research for technological improvement;
o Internal operations;
o Activities to maintain and improve our services; and
o Other one-time uses.

Recipients of California Personal Information. We may sell the categories of personal information designated above to the categories of third parties listed below:
• Advertising/marketing companies;
• Advertising networks;
• Internet service providers;
• Social networks; and
• Affiliated entities.
We disclose the categories of personal information designated above to the categories of third parties listed below for business purposes:
• Service providers who process data on our behalf;
• Our partners, including distributors and dispensaries that we provide products and services to;
• Affiliates;
• Government entities;
• Advertising networks;
• Internet service providers;
• Data analytics providers;
• Operating systems and platforms;
• Social networks; and
• Consumer data resellers.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:
• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have either sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• The right to request that we delete the personal information we have collected from you.
• The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:
• By phone at 1-844-484-2028 or email at help@thedbmethod.com.
• Online at https://thedbmethod.com.
• If you have an online account with us, through the settings page in your account.

Verification Process and Required Information
Note that we may need to request additional information from you (e.g. email address) to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled.
Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf by emailing us at help@thedbmethod.com and making the subject of your email “Authorized Agent Request.” .
Minors’ Right to Opt In. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

YOUR NEVADA PRIVACY RIGHTS
Under the Nevada Privacy of Information Collected on the Internet from Consumers Act, Nevada residents have certain rights with respect to “covered information” under such law. Nevada residents may submit a request directing us not to make certain disclosures of personal information we maintain about them.
To exercise this right, please contact us:
• By email at help@thedbmethod.com

YOUR CHOICES
To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. You may also opt out or unsubscribe from future emails by sending a request to help@thedbmethod.com using the subject line “Unsubscribe from email communications.” To ensure your opt out request is properly processed, be sure to send your message using the same email account which we sent our correspondence.
Note that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
UPDATING YOUR INFORMATION
You may request to review, change, or update your contact information by contacting us.
CHANGES TO OUR PRIVACY POLICY
If our information practices change, we will post these changes on this page. We encourage you to visit this page periodically to learn of any updates.

CONTACT
If you have questions, comments, or concerns about this Privacy Policy, please contact us:
Via email at: help@thedbmethod.com or
Via postal mail: Attn: Privacy Compliance Officer, The DB Method, 225 Broadway, New York, NY 10038.