Lark Wellness LLC (the “Company”) respects your privacy and is committed to
This policy describes the Company’s practices for collecting, using,
maintaining, protecting, and disclosing the personal data it may collect
from you or that you may provide when you visit any Back To Life Program
website (collectively, the “Website”) and the Company’s practices for
collecting, using, keeping, protecting, and disclosing that information.
This policy applies to the personal data collected through the Website,
regardless of the country where you are located.
The Website may include links to third-party websites, plug-ins, services,
social networks, or applications. Clicking on those links or enabling those
connections may allow the third party to collect or share data about you.
The Company does not control these third-party websites, and the Company
Please read this policy carefully to understand the Company’s policies and
practices for processing and storing your personal data. By engaging with
the Website, you accept and consent to the practices described in this
policy. This policy may change from time to time (see
). Your continued engaging with the Website after any such revisions
indicates that you accept and consent to them, so please check the policy
periodically for updates.
Data the Company may collect about you
Personal data, or personal information, means any information about an
individual from which that person can be identified. It does not include
data where the identity has been removed (anonymous data).
The Company may collect, use, store, and transfer different kinds of
personal data about you, which the Company has grouped together as follows:
Identity Data includes first name and last name.
Contact Data includes billing address, delivery address, email
address, and telephone numbers.
Financial Data includes payment card details.
Transaction Data includes details about payments from you and other
details of products you have purchased from the Company.
Technical Data includes internet protocol (IP) address, your login
data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform,
and other technology on the devices you use to access this Website.
Profile Data includes your purchases or orders made by you, your
interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use the Company’s
Website, products, and services.
Marketing and Communications Data includes your preferences in
receiving marketing from the Company and its third parties and your
The Company also collects, uses, and shares Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data may be
derived from your personal data but is not considered personal data in law
as this data does not directly or indirectly reveal your identity. For
example, the Company may aggregate your Usage Data to calculate the
percentage of users accessing a specific website feature. However, if the
Company combines or connects Aggregated Data with your personal data so
that it can directly or indirectly identify you, the Company treats the
combined data as personal data which will be used in accordance with this
The Company does not collect any Special Categories of Personal Data about
you (this includes details about your race or ethnicity, religious or
philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health, and genetic and
biometric data). Nor does the Company collect any information about
criminal convictions and offenses.
If you fail to provide personal data
Where the Company needs to collect personal data by law or under the terms
of a contract it has with you and you fail to provide that data when
requested, the Company may not be able to perform the contract it has or is
trying to enter into with you (for example, to provide you with goods or
services). In this case, the Company may have to cancel a product or
service you have with the Company, but the Company will notify you if this
is the case at the time.
How the Company collects data about you
The Company uses different methods to collect data from and about you
Direct interactions. You may give the Company data about you by
filling in forms or by corresponding with the Company by phone,
email, or otherwise. This includes personal data you provide when
place an order; review a product; request marketing to be sent to
you; request information about the Company’s products; enter a
competition, promotion, or survey; give the Company feedback; and
when you report a problem with the Website.
Automated technologies or interactions. As you interact with the
Website, the Company may automatically collect technical data about
your equipment, browsing actions, and patterns as specified above.
The Company collects this data by using cookies, server logs, and
other similar technologies (see
Cookies and automatic data collection technologies
Third parties or publicly available sources. The Company may
receive data about you if you visit other websites employing the
Company’s cookies or from third parties including, for example,
business partners (including affiliates in the Website’s affiliate
marketing program); subcontractors in technical, payment, and
delivery services; advertising networks; analytics providers; and
search information providers.
Cookies and automatic data collection technologies
other automatic data collection technologies to distinguish you from other
Website users. This helps the Company deliver a better and more
personalized service when you browse its Website. It also allows the
Company to improve its Website by enabling it to:
Estimate the Website’s audience size and usage patterns.
Store your preferences so the Company may customize the Website
according to your individual interests.
Speed up your searches.
Recognize you when you return to the Website.
You may refuse to accept browser cookies by activating the appropriate
setting on your browser. However, if you select this setting, certain parts
of the Website may become inaccessible and certain features may not work
Company’s system will issue them.
Some content or applications, including advertisements, on the Website are
served by third parties, including advertisers, ad networks and servers,
content providers, and application providers. These third parties may use
cookies alone or in conjunction with web beacons or other tracking
technologies to collect data about you when you use the Website. They may
associate the data collected with your personal data or they may collect
data, including personal data, about your online activities over time and
across different websites and other online services. They may use this data
to provide you with interest-based (behavioral) advertising or other
The Company does not control how these third-party tracking technologies
operate or how they may use the collected data. If you have any questions
about an advertisement or other targeted content, you should contact the
responsible provider directly.
How the Company uses your personal data
The Company uses your personal data to provide you with products, offer you
services, communicate with you, deliver advertising and marketing, or to
conduct other business operations, such as using data to improve and
personalize your experiences. Examples of how the Company may use the
personal data it collects includes to:
Present the Website and provide you with the information, products,
services, and support that you request from the Company.
Meet the Company’s obligations and enforce its rights arising from
any contracts with you, including for billing or collections, or
comply with legal requirements.
Fulfill any orders placed through the Website (including processing
your payment information, arranging for shipping, and providing you
with invoices or order confirmations).
Communicate with you.
Screen orders for potential risk or fraud.
Fulfill the purposes for which you provided the data or that were
described when it was collected.
Notify you about changes to the Website, products, or services.
Ensure that the Company presents the Website content in the most
effective manner for you and for your computer.
Administer the Website and conduct internal operations, including
for troubleshooting, data analysis, testing, research, statistical,
and survey purposes.
Improve the Website, products or services, marketing, or customer
relationships and experiences.
Enable your participation in the Website’s interactive, social
media, or other similar features.
Protect the Website, the Company’s employees, or the Company’s
Measure or understand the effectiveness of the advertising the
Company serves to you and others, and to deliver relevant
advertising to you.
Make suggestions and recommendations to you and other users of the
Website about goods or services that may interest you or them.
The Company may also use personal data to contact you about its own and
third parties’ goods and services that may be of interest to you via email,
direct mail, or otherwise. For more information, see
Your personal data use choices
The Company may use personal data to enable it to display advertisements to
its advertisers’ target audiences. Even though the Company does not
disclose your personal data for these purposes without your consent, if you
click on or otherwise interact with an advertisement, the advertiser may
assume that you meet its target criteria.
If you are an European Economic Area (EEA) resident, please note that the
Company is processing your data to fulfill contracts it might have with you
(for example, if you make an order through the Website), to comply with a
legal obligation, or otherwise to pursue its legitimate business interests,
more specifically its economic interest in offering you products and
services, growing its business, making you personalized offers, and in
recovering any debts due to it.
The Company may use nonpersonal data for any business purpose.
Disclosure of your personal data
The Company may share your personal data with:
Any member of the Company’s corporate group, which means its
subsidiaries, its ultimate holding company and its subsidiaries,
Business partners, suppliers, service providers, subcontractors,
and other third parties that the Company uses to support its
business (such as analytics and search engine providers that assist
the Company with Website improvement and optimization). For
example, the Company uses ClickBank to power its online store (you
can read more about how ClickBank uses your personal data here:
). The Company also uses Google Analytics to help the Company
understand how its customers use the Website (you can read more
about how Google uses your personal data here:
). You can also optout of Google Analytics here:
. The Company contractually requires these third parties to keep
that personal data confidential and use it only for the contracted
Third parties such as third-party publishers and advertisers to
market their products or services to you if you have not opted out
of these disclosures. We contractually require these third parties
to keep that personal data confidential and use it only for the
contracted purposes. For more information, see
Your personal data use choices
Advertisers and advertising networks that require the data to
select and serve relevant adverts to you and others.
The Company may also disclose your personal data to third parties:
If the Company sells or buys any business or assets, in which case
the Company may disclose your personal data to the prospective
seller or buyer of the business or assets.
To a buyer or other successor in the event of merger, divestiture,
restructuring, reorganization, dissolution, or other sale or
transfer of some or all the Company’s assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar
proceeding, where one of the transferred assets is the personal
data the Company holds.
To comply with any court order, law, or legal process, including to
respond to any government or regulatory request.
To enforce or apply the Company’s Terms-of-Use Agreement,
Terms-of-Sale Agreement, and other agreements.
To protect the rights, property, or safety of the Company’s
business, its employees, its customers, or others. This includes
exchanging information with other companies and organizations for
the purposes of cybersecurity, fraud protection, and credit risk
To fulfill the purpose for which you provide it.
For any other purposes that the Company discloses when you provide
With your consent.
The Company may share nonpersonal data without restriction.
Cross-border data transfers
The Company is based in the United States. For operational reasons the
Company may process, store, and transfer personal data it collects, in and
to a country outside your own, with different privacy laws that may or may
not be as comprehensive as your own.
Where the Company does so, and where the Company is required to under local
law, the Company will put in place appropriate mechanisms to ensure that
your personal data receives an adequate level of protection where it is
If you are located outside the United States, the Company advises you that
your personal data may at times be accessible by persons who are located
worldwide including in countries that the European Commission or other
geopolitical regions have not determined to provide the same adequate level
of data protections in your country, province territory, or geopolitical
region. By submitting your personal data or engaging with the Website, you
consent to the Company’s transfer, storing, or processing, including the
transfer of your data across international boundaries to jurisdictions
anywhere in the world as permitted by local law.
If you are a European Economic Area (EEA) or Switzerland resident or
otherwise located in the EEA or Switzerland, please note that your
information will be transferred outside of the EEA or Switzerland,
including to the United States.
If you are a Canadian resident or otherwise located in Canada, please note
that personal data transfers outside of Canada may result in your data
becoming accessible to foreign jurisdiction’s law enforcement or other
Your personal data use choices
The Company strives to provide you with choices regarding certain personal
data uses, particularly around marketing and advertising. The Company has
established the following personal data control mechanisms:
Promotional offers from the Company. If you do not want the Company
to use your Contact Data to promote its own products and services,
or third parties’ products or services, you can opt out by sending
the Company an email with your request to
. You may also opt out of further marketing communications by
replying to any promotional email the Company has sent you or
following the opt out links on that message. This opt out does not
apply to information provided to the Company as a result of a
product purchase, product service experience, or other
Third-Party Advertising. If you do not want the Company to share
your personal data with unaffiliated or non-agent third parties for
promotional purposes, you can opt out by sending the Company an
email stating your request to
Tracking Technologies and Advertising. You can set your browser to
refuse all or some browser cookies, or to alert you when websites
note that some parts of this Website may become inaccessible or not
function properly. For more information about tracking
technologies, please see
Cookies and automatic data collection technologies
Targeted Advertising. If you do not want the Company to use data
that it collects or that you provide to the Company to deliver
advertisements according to its advertisers’ target-audience
preferences, you can opt out by sending the Company an email
stating your request to supportbacktolifesystem.com. For this opt
out to function, you must have your browser set to accept browser
The Website may, from time to time, contain links to and from the websites
of the Company’s partner networks, advertisers and affiliates, or plug-ins
enabling third-party features. If you follow a link to any third-party
website or engage a third-party plug-in, please note that these third
parties have their own privacy policies and that the Company does not
accept any responsibility or liability for these policies. Please check
these policies before you submit any personal data to these third parties.
Accessing and correcting your personal data
You may send the Company an email at supportbacktolifesystem.com to
request access to, correct, or delete any personal data that you have
provided to the Company. The Company may not accommodate a request to
change data if the Company believes the change would violate any law or
legal requirement or negatively affect the data’s accuracy.
The security of your personal data is very important to the Company. The
Company uses reasonable and appropriate security measures designed to
protect your personal data from loss, misuse, and unauthorized access, use,
alteration, or disclosure. The Company stores all personal data behind
firewalls on severs employing security protections. The Company encrypts
any payment transactions using SSL technology.
The safety and security of your information also depends on you. Where the
Company has given you (or where you have chosen) a password for access to
certain parts of the Website, you are responsible for keeping this password
confidential. The Company asks you not to share your password with anyone.
The Company urges you to take care when providing information in public
areas of the Website, which any Website visitor can view.
Unfortunately, the transmission of information via the Internet is not
completely secure. Although the Company does its best to protect your
personal data, the Company cannot guarantee the security of your personal
data transmitted to the Website. Any transmission of personal data is at
your own risk. The Company is not responsible for the circumvention of any
privacy settings or security measures contained on the Website.
How long will the Company use my personal data for?
The Company will only retain your personal data for as long as reasonably
necessary to fulfill the purposes it collected it for, including for the
purposes of satisfying any legal, regulatory, tax, accounting, or reporting
requirements. The Company may retain your personal data for a longer period
in the event of a complaint or if the Company reasonably believes there is
a prospect of litigation in respect to its relationship with you.
To determine the appropriate retention period for personal data, the
Company considers the amount, nature, and sensitivity of the personal data;
the potential risk of harm from unauthorized use or disclosure of your
personal data; the purposes for which the Company processes your personal
data and whether it can achieve those purposes through other means; and the
applicable legal, regulatory, tax, accounting, or other requirements.
By law the Company has to keep basic information about its customers
(including Contact, Identity, Financial, and Transaction Data) for seven
years after they stop being customers or affiliates for tax purposes.
In some circumstances you can ask the Company to delete your data: see
Accessing and correcting your personal data
In some circumstances the Company will anonymize your personal data (so
that it can no longer be associated with you) for research or statistical
purposes in which case the Company may use this information indefinitely
without further notice to you.
Children’s online privacy
The Company does not direct its Website to minors and it does not knowingly
collect personal data from individuals under 18-years old. If the Company
learns it has mistakenly or unintentionally collected or received personal
data from an individual under 18-years old, it will delete it. If you
believe the Company mistakenly or unintentionally collected data from or
about an individual under 18-years old, please contact the Company at
Do Not Track policy
Do Not Track (“DNT”) is a privacy preference that you can set in your
browser. DNT is a way for you to inform websites and services that you do
not want certain information about your webpage visits collected over time
and across websites or online services. The Company is committed to
providing you with meaningful choices about the information it collects and
that is why the Company provides you the ability to opt out. But the
Company does not recognize or respond to any DNT signals as the Internet
industry works toward defining exactly what DNT means, what it means to
comply with DNT, and a common approach to responding to DNT. For more
information, visit www.allaboutdnt.com.
Your California privacy rights
If you are a California resident, you may have certain additional rights.
California Civil Code Section 1798.83 permits you to request information
regarding the disclosure of your personal data by the Company to third
parties for the third parties’ direct marketing purposes. Further, if you
are a California resident and would like to opt out from the disclosure of
your personal data to any third party for direct marketing purposes, please
send an email to supportbacktolifesystem.com. If you opt out from
permitting your personal data to be shared, you may still receive selected
offers directly from the Company in accordance with California law.
Your EU GDPR and Swiss privacy rights
If you reside in the European Economic Area (EEA) or Switzerland, under
certain circumstances, you have rights under data protection laws in
relation to your personal data. Your rights may include the following:
Request access to your personal data (commonly known as a “data
subject access request”). This enables you to receive a copy of the
personal data the Company holds about you and to check that the
Company is lawfully processing it.
Request correction of the personal data that the Company holds
about you. This enables you to have any incomplete or inaccurate
data the Company holds about you corrected, though the Company may
need to verify the accuracy of the new data you provide to the
Request erasure of your personal data. This enables you to ask the
Company to delete or remove personal data where there is no good
reason for the Company continuing to process it. You also have the
right to ask the Company to delete or remove your personal data
where you have successfully exercised your right to object to
processing (see below), where the Company may have processed your
information unlawfully, or where the Company is required to erase
your personal data to comply with local law. Note, however, that
the Company may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to you,
if applicable, at the time of your request.
Object to processing of your personal data where the Company is
relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you
want to object to processing on this ground as you feel it impacts
on your fundamental rights and freedoms. You also have the right to
object where the Company is processing your personal data for
direct marketing purposes. In some cases, the Company may
demonstrate that it has compelling legitimate grounds to process
your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables
you to ask the Company to suspend the processing of your personal
data in the following scenarios: (a) if you want the Company to
establish the data’s accuracy; (b) where the Company’s use of the
data is unlawful but you do not want the Company to erase it; (c)
where you need the Company to hold the data even if the Company no
longer requires it as you need it to establish, exercise, or defend
legal claims; or (d) you have objected to the Company’s use of your
data but the Company needs to verify whether it has overriding
legitimate grounds to use it.
Request the transfer of your personal data to you or to a third
party. The Company will provide to you, or a third party you have
chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to
automated information which you initially provided consent for the
Company to use or where the Company used the information to perform
a contract with you.
Withdraw consent at any time where the Company is relying on
consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you
withdraw your consent. If you withdraw your consent, the Company
may not be able to provide certain products or services to you. The
Company will advise you if this is the case at the time you
withdraw your consent.
If you wish to exercise any of the rights set out above, please contact the
Company at supportbacktolifesystem.com.
You will not have to pay a fee to access your personal data (or to exercise
any of the other rights). However, the Company may charge a reasonable fee
if your request is clearly unfounded, repetitive, or excessive.
Alternatively, the Company may refuse to comply with your request in these
The Company may need to request specific information from you to help it
confirm your identity and ensure your right to access your personal data
(or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right
to receive it. The Company may also contact you to ask you for further
information in relation to your request to speed up its response.
The Company tries to respond to all legitimate requests within one month.
Occasionally it may take the Company longer than a month if your request is
particularly complex or you have made a number of requests. In this case,
the Company will notify you and keep you updated.
page. If the changes materially alter how the Company uses or treats your
personal data, it will notify you through a notice on the Website home
of the page. You are responsible for ensuring that the Company has an
up-to-date active and deliverable email address for you. Please check back
Questions, comments, requests, and complaints regarding this policy or the
Company’s privacy practices are welcomed and should be addressed to