The Service is intended for individuals who are at least eighteen (18) years of age (or the age of majority in their jurisdiction). Individuals ages 13–17 may be permitted to use limited parts of the Service only as described in the Terms & Conditions and with parent or legal guardian consent. The Service is not directed to children under 13.

If we obtain actual knowledge that we collected personal information from a child under 13, we will take reasonable steps to delete it unless we are required or permitted to retain it by law.

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Requests for Removal of Minor Information (Under 16)

If you are under 16, you (or your parent/legal guardian) may request removal of content or information posted on the Platform by submitting a “Request for Removal of Minor Information”:

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By mail:
Thrivelab Co., Attn: Privacy Officer
701 North Green Valley Parkway, Suite #213
Henderson, NV 89074-6177
(Recommended: U.S. Certified Mail, Return Receipt Requested)

By email: privacy@thrivelab.com
Subject line: “Removal of Minor Information”

Include: (i) the nature of your request, (ii) the content to be removed, (iii) where it appears (URL or specific location), (iv) your name and contact information, and (v) how you prefer to receive our response (mail or email).

We may not be able to remove content in certain circumstances, including where retention is required by law, where it is part of a provider’s medical record, where content was reposted by a third party, where it has been de-identified, or where the request is incomplete or improperly submitted.

We collect information from and about you in the following categories:

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A. Information You Provide to Us

• Identifiers and contact information (name, email, phone number, billing and shipping address)
• Account credentials and profile information
• Demographic information (such as date of birth, gender, and zip code)
• Communications with us (support requests and correspondence)
• Transaction information (purchases, subscriptions, fulfillment and shipping information)
• Electronic signatures and acknowledgements
• Photos or videos you submit for identification or non-clinical purposes (where applicable)
• Information about people you refer to us (name and contact information)

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B. Information Collected Automatically

• Device and browser data (IP address, device identifiers, operating system, browser type, connection information)
• Usage data (pages viewed, clicks, session activity, time on page, referring URLs)
• Cookie and similar technology data (see Section 6)

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C. Information From Third Parties

• Payment processors (e.g., Stripe) for transaction processing
• Analytics and marketing service providers
• Advertising and social platforms (where you interact with our ads or connect accounts)
• Service providers assisting with customer support, security, and fraud prevention

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D. Health-Related Information
When you use clinical components of the Service, you may submit health information to medical groups and providers. Thrivelab may process certain information on behalf of medical groups, providers, laboratories, and pharmacies to facilitate services (for example, intake information routing, shipping coordination, and enabling access to Service features). Medical groups and providers may also maintain their own notices and policies governing protected health information.

Thrivelab is generally not a “covered entity” under the Health Insurance Portability and Accountability Act (“HIPAA”). Depending on the relationships involved, Thrivelab may in some cases act as a business associate to a covered entity (such as a medical group or pharmacy) for limited functions. Where HIPAA applies to Thrivelab in that role, we will handle “protected health information” as required by applicable law and relevant agreements.

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Not all health-related information is HIPAA-protected. Information you provide for account setup, billing, shipping, and general platform access is generally not “protected health information” under HIPAA, even if it may be considered sensitive.

We use cookies and similar technologies (such as pixels, web beacons, and scripts) to operate the Service, remember preferences, understand usage, improve performance, and support marketing and advertising.

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You can control cookies through your browser or device settings. If you block or disable cookies, parts of the Service may not function properly.

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We do not permit third-party tracking technologies to access communications you have with medical providers or information submitted for diagnosis and treatment through protected clinical workflows, except as necessary for Service operation, security, and fraud prevention.

• Provide, operate, and maintain the Service
• Create and manage accounts, authenticate users, and provide customer support
• Process payments, subscriptions, fulfillment, and transactions
• Facilitate coordination with medical groups, providers, labs, and pharmacies when you request or receive related services
• Provide and administer coaching, community, and educational experiences (including Transformation Content)
• Improve and personalize user experience (including content and feature optimization)
• Perform analytics, debugging, and product development
• Communicate with you about Service updates, transactional notices, and support
• Send marketing communications where permitted by law and consistent with your preferences
• Detect, prevent, and respond to fraud, security incidents, or misuse
• Comply with legal obligations and enforce our agreements

We may disclose information in the following circumstances:

A. Service Providers
We share information with vendors that help us operate the Service (hosting, analytics, customer support, communications tools, security, payment processing). They may access information only to perform services for us and are required to protect it.

B. Medical Groups, Providers, Labs, and Pharmacies

Where you request or receive clinical services, we may share information as needed to facilitate those services, such as intake details, fulfillment data, and communications routing.

C. Chris Powell, TransformNation, and Circle (Transformation Content)

If you access Transformation Content (including live coaching, group coaching, exercise training videos, and community experiences), Thrivelab may share certain information with Chris Powell, TransformNation, and the third-party platforms and service providers used to deliver those experiences, including Circle (collectively, “Transformation Partners”), solely as reasonably necessary to provide, administer, secure, and support the Transformation Content.

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Information disclosed may include:

• Identifiers and contact information (such as name, email address, phone number, and user ID)
• Enrollment and participation status (such as program access, attendance, and progress status)
• Community and coaching interactions that you choose to submit within Circle or other Transformation Partner experiences (such as posts, comments, messages, and reactions)
• Technical and usage information needed to provide, secure, and support the Transformation Partner experience (such as device and log data)
  

Clinical and diagnosis/treatment information.

Thrivelab does not share information you submit for diagnosis and treatment with medical providers (including intake answers intended for clinical decision-making, provider communications, clinical notes, prescriptions, and lab results) with Chris Powell, TransformNation, Circle, or other Transformation Partners unless: (i) you expressly direct or authorize such sharing, (ii) it is necessary for Service delivery and permitted by applicable law, or (iii) it is de-identified so you cannot reasonably be identified.

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‍Independent third-party platforms. Circle is a third-party platform with its own privacy practices. Your use of Circle is subject to Circle’s terms and privacy policy, and Thrivelab does not control Circle’s practices. We encourage you to review Circle’s privacy policy carefully.

D. Corporate Transactions

We may disclose information in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, subject to reasonable confidentiality protections.

E. Legal and Safety

We may disclose information to comply with law, respond to lawful requests, protect rights and safety, investigate fraud or security issues, or enforce our Terms & Conditions.

F. With Your Consent or Direction

We may share information for other purposes when you direct us or give consent.

We retain information for as long as reasonably necessary to:

• Provide the Service and maintain your account
• Administer subscriptions, transactions, and program access
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements
• Maintain security and prevent fraud

Medical groups, providers, labs, pharmacies, and Transformation Partners may retain information pursuant to their own legal obligations and policies.

A. Communications Preferences
You may opt out of promotional emails by using the unsubscribe mechanism in the message or contacting us. You may still receive non-promotional communications related to your account, purchases, subscriptions, safety, and Service operations.

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B. Access, Correction, and Deletion Requests
You may request access to, correction of, or deletion of certain personal information by emailing privacy@thrivelab.com. We may need to verify your identity and may deny requests where we are legally permitted or required to retain information (for example, security, fraud prevention, compliance, dispute resolution, and records maintained for medical groups/providers).
If your request concerns information held by a medical group, provider, lab, pharmacy, or Transformation Partner (including Circle), you may need to direct the request to that entity, depending on the context and the applicable laws.

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C. Cookies and Tracking Controls
You can control cookies through browser/device settings. Some advertising platforms also offer opt-out mechanisms for interest-based advertising.

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D. Do Not Track
We do not currently respond to “Do Not Track” signals.

We use reasonable administrative, technical, and physical safeguards designed to protect information under our control. No method of transmission or storage is completely secure. You are responsible for keeping your login credentials confidential and for all activity under your account.

The Service may link to third-party websites or applications. This Privacy Policy does not apply to third parties, and we are not responsible for their privacy practices. Please review third-party privacy policies carefully.

This site may be monitored by one or more third-party monitoring tools to improve service quality and security. If opt-out options are made available by a monitoring provider, they will be provided by that provider under its own policies.

This Privacy Policy and Thrivelab’s privacy practices are governed by applicable U.S. law. To the extent state law applies and is not preempted, Nevada law governs disputes arising out of or relating to this Privacy Policy.

If you have questions about this Privacy Policy, contact:

Email: privacy@thrivelab.com or hello@thrivelab.com

‍Mail:
Thrivelab Co.701 North Green Valley Parkway, Suite #213Henderson, NV 89074-6177

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