Last updated:  November 29, 2022

GRLPWR, LLC (doing business as and referred to herein as “NuVita”, “our”, “us” or “we”) is committed to respecting the privacy rights of those visiting our websites, including our Affiliates’ Replicated Websites, mobile websites, mobile applications, and any other digital services and platforms officially operated or used by NuVita (hereafter collectively referred to as the “Website” or “Websites”).  Any personal information, such as your name, address, email address or phone number that you provide is extremely important to us.  To earn your trust, we respect your privacy in handling Personal Information relating to you and your transactions with us, whether made through nuvitacbd.com or one of our related Websites.  NuVita created this Privacy Policy to give you confidence as you visit and use the Websites, and to demonstrate its commitment to fair information practices and to the protection of privacy.

This Privacy Policy generally describes the Personal Information we gather about you, what we do with it, the safeguards we have in place to protect it, and how you can control our use of it.  By visiting or using the Websites, you agree, without limitation or qualification, to be bound by this Privacy Policy, and you are accepting the practices described in this Privacy Policy.  When you provide Personal Information to our Websites, you are consenting to the manner in which NuVita will collect, use, disclose, and otherwise manage your Personal Information, as set out below.

This Privacy Policy is only applicable to the Websites and not to any Third-Party websites, which may have data collection, storage and use practices and policies that differ materially from this Privacy Policy.  For additional information, see the Section V(A) concerning Links to Third-Party Websites, below.

Each time you use the Website, the then-current version of this Privacy Policy will apply.  Accordingly, each time you use the Website you should check the date of this Privacy Policy (which appears above) and review any changes since the last time you visited the Website.  For additional information, see the section concerning Updates and Changes to Privacy Policy, below.

BY USING THE WEBSITE, YOU REPRESENT AND WARRANT THAT YOU HAVE READ AND UNDERSTOOD, AND AGREE TO THE TERMS OF, THIS PRIVACY POLICY.  IF YOU DO NOT UNDERSTAND OR DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY, YOU MUST IMMEDIATELY LEAVE THE WEBSITE.

I. WHO MAY USE THE WEBSITES

A. Children’s Privacy. NuVita is committed to the safety of children.  The Websites are not intended or designed to attract users under the age of 21.  Persons under the age of 21 may not enroll as NuVita Affiliates or register as Customers.  Persons under the age of 21 may not purchase products through any of our Websites.  NuVita does not solicit or knowingly collect personally identifiable information from children under the age of 13.  If NuVita obtains actual knowledge that it has collected personally identifiable information from a child under the age of 13, NuVita will immediately delete such information from its database.  Because NuVita does not collect personally identifiable information from children under the age of 13, NuVita has no such information to use or disclose to third parties.  NuVita has designed this Privacy Policy in order to comply with the Children's Online Privacy Protection Act.B. Users Outside of the United States.The Websites are intended for users from the United States and those not governed by privacy policies of other countries.  Users from the European Union are advised not to disclose Personal Information to NuVita.  Information sent to us will be housed on servers located in the state of Michigan, in the United States.  Do not send us information unless you consent to the application of U.S. law and to the use and disclosure of your information consistent with this Privacy Policy.
II. INFORMATION COLLECTION

NuVita is the sole owner of the Website, including Replicated Websites.  We collect information from Independent Affiliates (“Affiliates”), Customers and visitors to the websites at different points on the websites.

A. Traffic Data. Like most website operators, NuVita automatically gathers information of the sort that browsers automatically make available, including: (i) IP addresses; (ii) domain servers; (iii) types of devices accessing the Website; and (iv) types of Web browsers accessing the Website (collectively “Traffic Data”).  Traffic Data is anonymous information that does not personally identify you.B. Cookies. A “Cookie” is a string of information that a website stores on a user's computer, and that the user's browser provides to the website each time the user submits a query to the website.  The purpose of a Cookie is to identify the user as a unique user of the Website.  NuVita uses Cookies to customize your experience on the Website to your interests, to ensure that you do not see the same informational messages repeatedly, and to store your username so you do not have to re-enter it each time you visit the Website.  For additional information on NuVita's uses of Cookies, see the section concerning Information Use and Disclosure Practices/Traffic Data and Information Gathered Using Cookies, below.  IF YOU DO NOT WISH TO HAVE COOKIES PLACED ON YOUR COMPUTER, YOU SHOULD SET YOUR BROWSERS TO REFUSE COOKIES BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT CERTAIN OF THE SERVICES AND CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY WITHOUT THE AID OF COOKIES.  IF YOU REFUSE COOKIES, YOU ASSUME ALL RESPONSIBILITY FOR ANY RESULTING LOSS OF FUNCTIONALITY.We use JavaScript to record your usage behavior on our website in order to adapt our web services to the needs of our users.  In doing so, we determine your browser type, location, time, and duration of your use, URL, page name, and the website that referred you to our page.  You can stop us from recording this data by disabling JavaScript directly in your browser.  We also use the following tools:

• Google Analytics - This is a web analytics tool by Google Inc., 1600 Amphitheatre Parkway Mountain View, California 94043, United States, hereinafter referred to as “Google”, to record your online activities on our site and to determine how many users are visiting us, what contents of our page are viewed, and how many times.  The evaluation is done anonymously.  Google Analytics cookies, including the Google Analytics tool “anonymous IP address” and usage data, are usually transmitted to a Google server in the United States and stored there.  For further information, please refer to https://support.google.com/analytics/answer/6004245?hl=en. 

At https://tools.google.com/dlpage/gaoptout?hl=en.%20 Google Analytics offers the option to opt out of data collection.  

• Salesforce Marketing Cloud - We may use this to record your behavior on our website to optimize our product offering.  It helps us determine how many users visit us in the Internet, which content of our site is viewed, and how often.  The evaluation is done anonymously and is used automatically by predictive intelligence to improve the presentation of our product offering.  For registered members, the user-related behavior on the website is recorded to improve the user experience and is used to display the relevant content.  Salesforce cookies are usually delivered to a Salesforce server in the United States and stored there.

C. Personal Information.Through your use of or visits to our websites, you may be required or requested to provide personally identifiable information (hereafter “Personal Information”) to us.  Personal Information is any piece of information which can potentially be used to uniquely identify, contact, or locate a single person.  Such information includes, without limitation: (1) “Contact Data” (such as your name, membership number, title, gender, date of birth, mailing address, address coordinates (longitude and latitude), phone number(s), fax number, and e-mail address); (2) “Demographic Data” (such as your age, gender, profession, education level, relationship status, religious affiliation, country, state, city and likes and dislikes,); (3) “Financial Data” (such as your credit/debit card number and expiration date); and (4) “Shopping Preferences” (such as items purchased, purchase date, place of purchase, time of purchase, purchase amount, currency and shopping cart).  For certain transactions, we may be required to collect information to comply with legal requirements.  In each case, you will be asked to provide Personal Information; the Website will not gather it surreptitiously.  NuVita may supplement the Personal Information you provide with additional personal information gathered from public sources or from third-parties (e.g., consumer reporting agencies) who may lawfully provide such information to NuVita.  You are under no obligation to provide Personal Information, with the caveat that your refusal to do so may prevent you from using certain of the features and services available on the Website or from purchasing any of our products.D. Non-Personal Information. “Non-Personal Information” is anonymous information is that information we collect that is not traceable to any individual person or computer.  We utilize this data to analyze trends and understand customer needs while shopping and interacting on our site so that we can provide a better user experience.  For example, we may use cookies, web beacons, log files and other technologies to collect information about visitors to our Website, and interactions with our online advertisements and offerings.E. Device Information.  Depending on the permissions you have granted and other factors, we may receive information about your location and your mobile device when you download from our Websites, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, certain player search results, and other personalized content. Examples of the device information we collect include:

• Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers. 
• Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals.
• Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.F. Affiliate and Customer Registration.In order to become an Affiliate, an applicant must provide Personal Information to us and/or a third-party like Interchecks (who we use to process payments).  We also may require an applicant’s Social Security Number or Federal Tax ID Number so that we may prepare and file necessary non-employee compensation forms for the IRS.  Certain customers may be required or decide to register in order to purchase products directly from us (which are referred to herein as “Customers”).  Customers will be required to provide Personal Information.  We use this information to maintain contact with Affiliates and Customers, and to process Affiliate and Customer orders.  G. Product or Service Purchases.When a retail customer, Customer, or Affiliate purchases products or services from us through any of our websites, the purchaser must provide us with Personal Information.  This information is used for billing and payment purposes and to fill orders.  H. Information that you make Public.\The Website may contains features (e.g.  public profiles, forums, and message boards) that permit you to upload, post, transmit, display, perform or distribute content, information or other material, including some of your Personal Information.  Any information that you choose to disclose by means of such features becomes public information over which NuVita is unable to exercise control.  You should exercise caution when deciding to disclose your Personal Information by means of such features, and you agree to assume all responsibility for doing so.III. INFORMATION USE AND DISCLOSURE PRACTICESA. Traffic Data and Information Gathered Using Cookies. We use "cookies" to recognize you as you use or return to our sites.  This is done so that we can provide a continuous and more personalized shopping experience for you.  A cookie is a small text file that a website or email may save to your browser and store on your hard drive.  Most cookies are "session cookies," meaning that they are automatically deleted from your hard drive once you sign out from Nuvita.com or close your web browser.  We use cookies to provide features and services, such as:

• allowing you to enter your password less frequently;
• remembering your preferences;
• presenting information that is targeted to your interests;
• measuring the effectiveness of our sites, services, content, and advertising; and
• providing other services and features that are available only through the use of cookies.

NuVita analyzes Traffic Data and information gathered using Cookies to help NuVita better understand who is using the Website and how they are using it.  By identifying patterns and trends in usage, NuVita is able to better design the Website to improve your experience, and to serve you more relevant and interesting content.  From time to time, NuVita may release Traffic Data and information gathered using Cookies in the aggregate, such as by publishing a report on trends in the usage of the Website.  NuVita does not attempt to link information gathered using Cookies to Personal Information.B. Web Beacons. We may also use web beacons.  A "web beacon" is an electronic image placed in the code of a web page.  Beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our website and other sites were effective.  We use web beacons to monitor the traffic patterns of users from one page to another and to improve site performance.C. Personal Information.Personal Information that is collected from retail customers, Customers, and Affiliates through Affiliate and Customer Registration, Product or Services Purchases and/or Surveys is used and disclosed as described in this Privacy Policy.  Except as specifically set forth in this Privacy Policy, NuVita DOES NOT share Personal Information.  NuVita may share aggregated information from time to time with its partners, vendors or other third parties.  When such aggregate information is shared by NuVita, no Personal Information is shared.D. Disclosure Practices. Except under the following circumstances and otherwise as set forth in this Privacy Policy, NuVita will keep your Personal Information private and will not sell it to or share it with third parties.

• Disclosure in Connection with Services.  Some of our operations, such as our electronic commerce, may be managed by Service Providers who are unaffiliated companies.  These companies may share Personal Information with their affiliates and service providers whom they engage to perform services related to our Websites or the operation of our business.  Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, Website hosting and evaluation, data storage, analysis, or security and, where applicable, data cleansing.  These companies may have access to your Personal Information on a confidential basis only to the extent necessary to perform their functions.  In no event will we authorize these companies to use your Personal Information for any reason other than to provide you with those specific services.  If your purchases are being shipped to you, your shipping information will be shared with our delivery service providers (U.S.  Postal Service, UPS, FedEx, or other delivery companies we or you select).  Our delivery service providers are asked not to use your Personal Information for any purpose other than making the delivery.
• Sharing.  The website contains “Share” buttons for the social networks Twitter LLC, 795 Folsom Street, Suite 600, San Francisco, California 94107, United States; XING, which is operated by XING AG, Dammtorstrasse 30, 20354 Hamburg, Germany; LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, United States; Facebook, 1601 South California Avenue, Palo Alto, California 94304, United States; YouTube, LLC. 901 Cherry Avenue, San Bruno, California 94066, United States; Pinterest, 808 Brannan St. San Francisco, California 94103, United States; and GooglePlus of the social network Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, United States.  In addition, there is also a “Share” button for e-mail.  The “Share” buttons can be recognized by their respective logos.  All “Share” buttons are set up in compliance with data protection requirements.  A direct connection between your browser and the server of the operator of the respective social network is established only when you click on the respective “Share” button on this website (and only then).  According to the operators of the social networks mentioned, no personal data is collected by the social networks without a click on the respective “Share” button.  Only data of logged-in Affiliates and Customers, , including the IP address, is collected and processed.  If you do not wish to associate your visit to our website with your user account of the respective social network, please log out of the user account of that social network.  We do not receive any information regarding the content of the data transmitted and its use by the social networks.  For more information about the use of data by the social media networks, please refer to the privacy policies of the social networks mentioned.
• By Law or to Protect Rights.  NuVita discloses Personal Information when required to do so by law, or in response to a subpoena or court order, or when NuVita believes in its sole discretion that disclosure is reasonably necessary to protect the property or rights of NuVita, third parties, or the public at large.
• Legally Required Law Enforcement, Judicial and Administrative Agency Disclosures.  NuVita will provide confidential and personally identifiable information as necessary to comply with judicial and administrative orders, subpoenas, Civil or Criminal Investigative Demands, Administrative and Regulatory Demands and other legal obligations.  In order for NuVita to conduct business in certain jurisdictions, NuVita must disclose certain personally identifiable and confidential information to regulatory authorities in such jurisdictions.  Such information may include, but is not limited to, income information and personally identifiable information.
• Business Transfers or Bankruptcy.  NuVita reserves the right, in its sole and absolute discretion, to transfer all Personal Information in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of NuVita’s assets.  Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred Personal Information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and an opportunity to affirmatively opt-out of it.  Personal Information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by NuVita’s successor organization.
• Unpaid Accounts.  If you fail to pay any balance owed in consideration of Services, NuVita may, as permitted by law, report your Personal Information, including without limitation your unpaid balance, to consumer credit reporting services, collection agencies and others.
• Lead Assignment and Affiliate Locator Features.  NuVita may occasionally assign prospective sales and new Affiliate leads to Affiliates.  In these cases, we will provide the lead with the appropriate Affiliate’s name and contact information and/or provide a distributor with the prospective lead’s name and contact information.  In addition, Nuvita may have an Affiliate Locator feature on its website.  Pursuant to this feature, a prospective customer or new Affiliate can locate a nearby NuVita Affiliate.  In order to make the Affiliate Locator feature and the lead assignments effective, the company will provide the prospective customer or new Affiliate with the Affiliate’s name and contact information, which may include his/her telephone number, address, and/or email address.
• If you use an Affiliate code or link to make a purchase, some of your Personal Information may be shared with the Affiliate, such as your name, order history, and contact information.  
• To help Affiliates in NuVita’s network marketing program manage their independent businesses, we may provide your NuVita sponsor and other upline NuVita Affiliates with your name, rank, address, telephone number, and email address as well as data relating to your sales and recruitment activity through the Back-Office to the Website.  We may also provide downline Affiliates with the names, rank, address, telephone number, and email address of their sponsor and certain specified upline Affiliates.

IV. COMMUNICATIONS FROM USA. Special Offers and Updates. By enrolling as an Affiliate, registering as Customer, or making a purchase or other inquiry through the Website, you may elect to receive periodic email and other communications from us and from our NuVita Affiliates.  You may also receive email from NuVita containing product and event information, product tips or promotions.  B. Service Announcements.On rare occasions it is necessary to send out a strictly service related announcement.  For instance, if our service is temporarily suspended for maintenance we might send Affiliates and/or Customers an email.  Generally, Affiliates may not opt-out of these communications, though they can deactivate their account.  However, these communications are not promotional in nature.  C. Affiliate and Customer Service. NuVita communicates with Affiliates and Customers via email, regular mail and telephone on a regular basis to provide requested services and in regards to issues relating to their NuVita business.  NuVita communicates with other Customers with respect to products or services purchased by such Customers from NuVita.  Such communications may be by email, regular mail, or telephone.D. Privacy Preferences/Opt-Out. NuVita allows you to unsubscribe or opt out of emails and other communications from NuVita.  To remove yourself from our mailing list you can click on the "unsubscribe" hyperlink contained in promotional emails we send you or by contacting us at: NuVita, Attn: Privacy Manager, 4500 Empire Way, Suite 4, Lansing, Michigan 48917, or by e-mailing us at info@nuvitacbd.com.

V. MISCELLANEOUSA. Links. NuVita’s websites may contain links to other sites.  Please be aware that NuVita is not responsible for the privacy practices of such other sites.  We encourage users to be aware when they leave our site and to read the privacy statements of each and every website that collects Personal Information.  This privacy statement applies solely to information collected by NuVita websites.  B. Text Messaging.By enrolling as an Affiliate, registering as Customer, or making a purchase or other inquiry through the Website, you may elect to provide your mobile phone number and receive periodic email and other communications from us and from our NuVita Affiliates.  By submitting your mobile phone number, you consent to receive text message alerts from NuVita containing product and event information, product tips or promotions that may be sent using automated dialing systems ("Text Messages").  Your consent to receive Text Messages is not otherwise required to purchase any goods or services from us.  You may not consent to receive Text Messages on behalf of someone else or provide someone else’s phone number.  You agree to enter into, sign and provide your consent to receive Text Messages electronically.  You may receive a limited number of texts from NuVita per month in connection with various promotions and in connection with an order.  We do not charge a fee for you to receive Text Messages from us, however, your mobile service provider may charge you for sending and/or receiving text messages and air-time, as well as any other standard applicable rates charged by your mobile service provider.  Text Messages are distributed via third party mobile network providers and, therefore, we cannot control certain factors relating to message delivery or guarantee availability or performance of this service, including liability for transmission delays or message failures.  To receive help with Text Messages, please email info@nuvitacbd.com.You may unsubscribe from receiving NuVita Text Messages any time by replying with the word "STOP" from your device.  You may also choose not to receive Text Messages by emailing info@nuvitacbd.com and specifying that this is your preference.We may also obtain the date, time and content of your messages in the course of your use of Text Messages.  We will use the information we obtain in connection with our Text Messages in accordance with this Privacy Policy.From time to time you may be asked to provide your mobile phone number to NuVita in connection with specific text messaging programs, which is in addition to the general NuVita marketing text messaging program.  That text messaging program may have additional or different terms and conditions from those set forth above, which will be presented you at the time that you opt-in to receive those text messages.  In general, in order to stop receiving text messages from a specific NuVita text messaging program, you can text STOP to the five digit short code for the text messaging program from which you no longer wish to receive message (i.e., the five digit number from which its text messages are being sent).  You will then receive confirmation of your opt-out of that text messaging program.  This will only opt you out of the specific text messaging program associated with that five digit short code.  You will remain opted in to any other NuVita text messaging programs that you have signed up for.C. Security of Personal Information.We maintain administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control.  We also are committed to employing reasonable technology in order to protect the security of our Websites.  However, even with the best technology, no website is 100% secure.  We will take reasonable measures which we believe are appropriate to protect your Personal Information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer such information to take comparable steps to protect that security.D. Secure Shopping. When you place orders on our Websites, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology.  SSL technology causes your browser to encrypt your order information before transmitting it to our secure server.  SSL technology, an industry standard, is designed to prevent someone other than operators of our Websites from capturing and viewing your Personal Information.  Since any order information you provide to us on our Websites will be transmitted using a secure connection, if your Web browser cannot support this level of security, you will not be able to order products through our Websites.  The most recent versions of Google Chrome, Netscape Navigator, Apple Safari, and Microsoft Internet Explorer can support a secure connection and can be downloaded for free from the Google, Netscape, Apple, or Microsoft website respectively.E. Passwords. To provide you with an increased level of security, online access to your Personal Information is protected with a password you select.  We strongly recommend that you do not disclose your password to anyone.  NuVita will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or e-mail messages).F. Lost or Stolen Information. You must promptly notify us if your credit, banking, other financial information, user name or password is lost, stolen or used without permission.  In such an event, we will remove that credit card number, bank account information, other financial institution information, user name or password from your account.G. Promotional Activities. From time to time, NuVita may conduct contests, giveaways and other promotions (collectively, “Promotional Activities”).  Any information submitted in connection with Promotional Activities will be treated in accordance with this Privacy Policy.  From time to time, NuVita may also ask you to participate in surveys designed to help NuVita improve the Websites, its products, services, or the NuVita network marketing program.  Any Personal Information provided to NuVita in connection with any survey will be used only in relation to that survey, and will be disclosed to third parties not bound by this Privacy Policy only in aggregated form.H. Changes to this Privacy Policy.NuVita reserves the right to amend or change this Privacy Policy at any time at its sole discretion.  It is your responsibility to periodically access this Privacy Policy by clicking on the Privacy Policy link at our home page.  You can determine the date this Privacy Policy was last updated by referring to the effective date found at the beginning of the policy.   When material changes or amendments are made to the Privacy Policy, we will announce the same at our home page for a period of 10 days following implementation of the amended Privacy Policy.I. Making Changes to Your Personal Information. Affiliates and Customers may update their personal information as necessary by logging into their NuVita online Back Offices or Customer Accounts, which allows them to access and edit their registration account information.  In addition, Affiliates and Customers may contact us at info@nuvitacbd.com to update their profiles.J. Information Sharing Disclosure Requests. If you are a California resident, you have the right to request one Notice of Information-Sharing Disclosure per year which will identify the third parties with whom NuVita or any of our affiliates has shared the Personal Information we have collected from you.  You may request the Notice of Information-Sharing Disclosure by writing to us at.  NuVita, Attn: Privacy Manager, 4500 Empire Way, Suite 4, Lansing, Michigan 48917, or by e-mailing us at info@nuvitacbd.com.  We will respond to your request for a Notice of Information-Sharing Disclosure within 30 days.K. Questions. Questions regarding this Privacy Policy should be directed to info@nuvitacbd.com, or by mail to NuVita, 4500 Empire Way, Suite 4, Lansing, Michigan 48917.