Privacy Policy

Welcome to the Website of TruLean, a California company (“ENPV”, “we,” or “us”). This privacy policy describes how we collect, use, disclose and otherwise process Personal Information from users of our Website at trulean.com, and subsidiaries thereof (the “website”) and our account management services through our customer portal on the website, our email processing operations, and our customer service contact center, as well as all related applications, widgets, software, tools, and other services provided by us or on which a link to this policy is displayed (collectively, together with the Site and our service, our “services”). By purchasing any of our products, you consent to the collection and use of Personal Information in accordance with this policy. Unless separately defined in this Privacy Policy, all terms used with initial letters capitalized in this policy have the meanings set forth in our Terms of Service or in this privacy policy.

1. THE INFORMATION WE COLLECT

We may collect information, which includes Personal Information, in various ways. “Personal Information” means any information that relates to an identified or identifiable individual, such as name, address, telephone number, or email address. We indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so, at the time of the collection of your Personal Information. If you do not provide the Personal Information necessary to provide you with our products and services, you will not be able to benefit from them.

Information Collected via Automated Means

When you visit our website and/or purchase our Products, some information is automatically collected, such as your IP address, browser type, system type, the content and pages that you access on our website, “referring URL” (i.e., the page from which you navigated to our website), the pages you navigate to on the website, and from which you leave the website, as well as the time you spend on the website. We may use IP address to derive your approximate location.

We collect this information via automated means, such as standard server logs, cookies, clear GIFs (also known as “Web beacons”) and similar technologies. We use this information to administer, operate, and improve our services and systems, and to provide products, content and advertising that are tailored to you.

Also, please be aware that third parties may set cookies on your hard drive or use other automated means to collect information about your use of their services or content.

We use analytics providers such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. These services may also collect information regarding the use of other websites, apps and online resources. You can learn about Google Analytics’ practices by going to https://www.google.com/analytics/terms/us.html, or opt out of them by contacting ENPV’s office of Governance Risk and Compliance at supplements@fitbodybootcamp.com.

Information Provided by You

We collect Personal Information that our users provide to us in a variety of ways in the purchasing process. For instance, when you purchase an ENPV product, update your account information online, leave a comment on our blog/Facebook, or otherwise post or transmit any information or content on or to our Company, request information about any products or services that we may provide, request help and support regarding any of our order or account, or otherwise communicate with us, we collect the Personal Information that is provided to us. We may collect Personal Information such as name, email address, city, state, country, other demographic information, and your interests and preferences in these manners. We also collect any information that you include in the content of messages you send to us.

Information from Other Sources

We may receive Personal Information about you from third parties, including public databases and industry-standard data vendors, and may combine this information with other Personal Information we maintain about you.

2. HOW WE USE YOUR INFORMATION

We use Personal Information for a number of purposes, including to:

Provide products, services and information that you request, respond to comments and questions, and otherwise provide support to users;

Enhance, improve, operate, and maintain our products, our products, programs, services, website, and other systems, including to protect against and prevent fraud;

Prevent fraudulent use of our services or products;

Tailor your user experience;

Maintain a record of our dealings with you;

Understand and analyze the usage trends and preferences of our users, to improve the services, and to develop new products, services, features, and functionality;

Contact you for administrative and information purposes—this may include providing customer service or sending communications, including changes to our terms and conditions;

Develop and provide promotional and advertising materials that may be useful, relevant, valuable, or tailored to you, or otherwise of interest;

Achieve business purposes, such as account verification, audits, security, compliance with applicable laws and regulations, fraud monitoring and prevention;

Enforce our Terms of Service or as necessary to establish, exercise or defend legal rights;

Achieve purposes for which we provide specific notice at the time of collection.

If you are located in the European Economic Area or Switzerland, we will rely on a lawful legal ground for the processing of your Personal information, including when:

You consented to the use of your Personal Information (e.g., for our uses of cookies or similar technologies, to send you marketing communications or personalize our offerings).

Necessary to provide you with products and services, or to respond to your inquiries.

The processing is required by applicable law or necessary to comply with a legal obligation.

We, or a third party, have a legitimate interest in using your Personal Information, such as to ensure and improve the safety, security, and performance of our products and services, to protect against and prevent payment fraud or to carry out data analyses.We will not engage in what is known as “automated decision-making,” which involves making decisions with legal or similarly significant effects solely based on automated processing of Personal Information, unless you explicitly consented to the processing, the processing is necessary for entering into, or to perform a contract, or when authorized by applicable law.

3. HOW WE DISCLOSE YOUR INFORMATION

When serving our customers, we do not disclose Personal Information about you to our service account to third parties, and take all necessary measures to help prevent fraudulent processing of online payments.

Conversely, we may disclose Personal Information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

In addition, information about our users, including Personal Information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information could be transferred to third parties as one of our business assets.

4. YOUR RIGHTS AND CHOICES

Promotional Emails

If you receive promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving promotional emails from us by sending us an email or by writing to us at the address given at the end of this policy.

Please be aware that if you opt-out of receiving promotional email from us, it may take up to ten business days for us to process your opt-out request, and you may receive promotional email from us during that period. Additionally, even after you opt-out from receiving promotional messages from us, you may continue to receive administrative messages from us regarding updates to your customer account.

Cookies and Similar Technologies

If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/. If, however, you do not accept cookies, you may experience some inconvenience in your use of the ENPV website.

ENPV does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use or visit our website.

Access and Deletion - Right to Erasure

As part of the user account functionality on our services, you may have the ability to access and update many categories of Personal Information that you provide to us by logging into your account and accessing your account settings. If you wish to amend or erase any other Personal Information that you have provided to us, or that may have been collected from you by ENPV, please send us an email with your full name, the email which you are being solicited at, and (if applicable) the order number of the last order that you received. Please send this information to the Office of Governance, Risk and Compliance at supplements@fitbodybootcamp.com

ENPV acknowledges our customer’s “Right to Erasure”. If you request that we delete information associated with your ENPV orders, we will do so within a reasonable period of time, but we may need to retain some of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.

European Users

If you are located in the European Economic Area or Switzerland, you may have the right to:

Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.Those rights may be limited in some circumstances by local law requirements. You may exercise your rights by contacting us as specified below.

5. LINKS

For your convenience, our website and marketing material may contain links to other websites, products, or services that we do not own or operate. Please be aware that this Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties operating any Website or service to which the services link. We encourage you to carefully review the privacy policies applicable to any Website or service you visit other than our services before providing any Personal Information on them.

6. CHILDREN

Children’s safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our products are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information from a child under the age of 13 on our website, we will delete that information as quickly as possible. If you believe that we may have collected any such Personal Information on our website, please notify us at supplements@fitbodybootcamp.com.

7. DATA TRANSFERS

Our website is hosted in the United States and are intended generally for United States users. However, individuals located outside of the United States may also benefit from our products and services. We may transfer your Personal Information to countries other than the country where you are located, including to the United States where we are headquartered.

We may also transfer your Personal Information to countries which provide an adequate level of protection under EU law, or in limited situations we may use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses. You may contact us as specified below to with any questions in regards to the international transfer of Personal Information.

8. SECURITY

We use reasonable security measures that are designed to protect Personal Information in our control from loss, misuse, unauthorized access, use, disclosure, alteration, or accidental, unlawful or unauthorized destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any Personal Information or other information or that it will not be accessed, viewed, or acquired by unauthorized persons.

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

9. UPDATES TO THIS POLICY

We may occasionally update this policy. When we do, we will also revise the “last updated” date at the beginning of the policy. Your continued use of our services after such changes will mean that you accept the revised policy. We encourage you to periodically review this policy to stay informed about how we collect, use, and disclose Personal Information.

10. SMS/MMS MOBILE MESSAGING MARKETING PROGRAM

We respect your privacy. We will only use information you provide through the Program to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY. Nonetheless, We reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect Our rights or property. When you complete forms online or otherwise provide Us information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in Our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, We may refuse you access to the Program and pursue any appropriate legal remedies.

California Civil Code Section 1798.83 permits Users of the Program that are California residents to request certain information regarding our disclosure of the information you provide through the Program to third parties for their direct marketing purposes. To make such a request, please contact us at the following address:

ENP Ventures

5867 Pine Ave. Chino Hills, CA 91709

orders@trulean.com

This Privacy Policy is strictly limited to the Program and has no effect on any other privacy policy(ies) that may govern the relationship between you and Us in other contexts.

11. CONTACTING US

If you have any questions, comments, or concerns about this privacy policy, or if you would like to exercise your rights in relation to your Personal Information, please contact us using the following contact information:

Office of Governance, Risk and Compliance: orders@trulean.com

Direct Mail:

ENP Ventures

5867 Pine Ave. Chino Hills, CA 91709