Consumer health data

WHO THIS POLICY IS FOR

This policy explains how ELUJE collects,
uses, shares and protects your personal
health data when you use eluje.com
or purchase our products.

This policy applies to all customers
in all regions including the United States,
European Union, United Kingdom,
Canada and Australia.

Questions?
Email us at hello@eluje.com.
We are real people. We read every email.

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THE SHORT VERSION

We collect health-related information
only when you choose to share it with us.

We use it only to serve you better.
We never sell it.
We never share it with advertisers.
You are always in control.

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1. WHAT IS CONSUMER HEALTH DATA

Consumer health data is any personal
information that relates to your
physical or mental health condition,
health history, or health-related
purchases and behaviours.

For ELUJE customers this may include:

→ Information you share about being
   postpartum or breastfeeding
→ Health concerns you mention when
   contacting our support team
→ Symptoms or conditions you describe
   in quiz responses or feedback forms
→ Products you purchase that indicate
   a health-related need
   (for example — postnatal supplements,
   sleep support, cognitive support)
→ Survey responses about how you feel
   before and after using our products
→ Any other health information you
   voluntarily share with us

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2. HOW WE COLLECT YOUR HEALTH DATA

We collect consumer health data in the
following ways:

DIRECTLY FROM YOU
→ When you complete our quiz funnel
   and share information about your
   postpartum experience
→ When you contact our support team
   and describe health-related concerns
→ When you respond to our email surveys
   about your recovery progress
→ When you submit a product review
   that includes health information
→ When you participate in our
   Stay Her community

FROM YOUR PURCHASES
→ The products you buy may indicate
   health-related needs
   (for example — purchasing Elixir
   Premium Postnatal indicates you are
   in a postpartum recovery period)

WE DO NOT COLLECT
→ Medical records or clinical data
→ Prescription information
→ Data from health apps or wearables
→ Genetic information
→ Any health data from children
   under 18 years old

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3. WHY WE COLLECT YOUR HEALTH DATA

We collect consumer health data for
the following purposes only:

TO SERVE YOU BETTER
→ Personalise your recovery experience
→ Send relevant content through
   our Stay Her subscription
→ Tailor our email recovery sequences
   to your specific postpartum stage
→ Recommend the right products
   for your situation

TO IMPROVE OUR PRODUCTS
→ Understand which ingredients and
   formulations work best for mothers
   at different postpartum stages
→ Improve our quiz and recommendation
   system
→ Develop new products that address
   real postpartum needs

TO PROVIDE CUSTOMER SUPPORT
→ Help you effectively when you
   contact us with health-related
   questions about our products
→ Process refund requests that involve
   health-related feedback

WE NEVER USE YOUR HEALTH DATA TO
→ Sell to third parties
→ Share with advertisers or
   data brokers
→ Make automated decisions that
   significantly affect you
→ Discriminate against you in
   any way
→ Deny you access to our products
   or services

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4. HOW WE SHARE YOUR HEALTH DATA

We do not sell your consumer health data.
Ever. To anyone. Under any circumstances.

We share your health data only with
the following trusted service providers
who help us operate our business:

KLAVIYO — EMAIL PLATFORM
We use Klaviyo to send personalised
recovery emails to Stay Her members.
Klaviyo may process health-related
information contained in your
email responses.
klaviyo.com/legal/privacy

SHOPIFY — STORE PLATFORM
Shopify processes your orders and
stores your purchase history.
Your product purchases may indicate
health-related information.
shopify.com/legal/privacy

CUSTOMER SUPPORT TOOLS
If you contact us by email, our
support team has access to the
health information you share
in that conversation.

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ALL THIRD PARTIES WE WORK WITH ARE:

→ Contractually required to protect
   your health data
→ Prohibited from selling or sharing
   your health data
→ Required to use your data only
   for the specific purpose we
   share it with them
→ Required to delete your data
   when our relationship ends

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5. HOW WE PROTECT YOUR HEALTH DATA

We take the security of your health data
seriously. We use the following measures
to protect it:

ENCRYPTION
→ All data transmitted between your
   browser and our site is encrypted
   using SSL/TLS
→ All stored data is encrypted at rest

ACCESS CONTROLS
→ Only authorised ELUJE team members
   can access your health data
→ Access is limited to what is necessary
   to perform their role
→ All team members are trained on
   data privacy and security

THIRD PARTY SECURITY
→ We only work with third parties
   who meet our security standards
→ All third party agreements include
   data protection requirements

DATA MINIMISATION
→ We collect only the health data
   we actually need
→ We do not collect health data
   speculatively or in advance

INCIDENT RESPONSE
→ In the event of a data breach
   we will notify affected customers
   within 72 hours
→ We will notify relevant authorities
   as required by law

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6. HOW LONG WE KEEP YOUR HEALTH DATA

PURCHASE-RELATED HEALTH DATA
We keep records of your purchases
for 7 years for legal and accounting
purposes. This includes the products
you bought which may indicate
health-related information.

SUPPORT CONVERSATIONS
We keep support emails containing
health information for 2 years
so we can help you effectively
if you contact us again.

SURVEY AND FEEDBACK DATA
We keep survey responses for 3 years
to help us improve our products.
After 3 years this data is anonymised
or deleted.

QUIZ RESPONSES
We keep quiz responses for 12 months.
After 12 months this data is anonymised
or deleted.

STAY HER CONTENT ENGAGEMENT
We keep records of your engagement
with our monthly identity content
for 12 months.

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7. YOUR RIGHTS OVER YOUR HEALTH DATA

You have the following rights regarding
your consumer health data:

RIGHT TO KNOW
You can request a full list of all
consumer health data we hold about you.
We will provide this within 30 days.

RIGHT TO ACCESS
You can request a copy of all consumer
health data we hold about you in a
portable, readable format.

RIGHT TO CORRECT
You can ask us to correct any inaccurate
health data we hold about you.
We will do so within 14 days.

RIGHT TO DELETE
You can ask us to delete all consumer
health data we hold about you.
We will do so within 30 days —
except data we are legally required
to retain for tax or legal purposes.

RIGHT TO WITHDRAW CONSENT
You can withdraw your consent for us
to process your health data at any time.
This will not affect processing that
already took place before withdrawal.

RIGHT TO RESTRICT PROCESSING
You can ask us to stop using your
health data for specific purposes
while keeping it on file.

RIGHT TO OPT OUT OF SHARING
You can ask us to stop sharing your
health data with any third party
at any time.

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HOW TO EXERCISE YOUR RIGHTS

Email:     hello@eluje.com
Subject:   Health Data Request — [Your Name]

Tell us:
→ Which right you want to exercise
→ What specific data it relates to
→ Your order number if relevant

We will respond within 30 days.
We will never charge you for
exercising your rights.

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8. SPECIFIC REGIONAL RIGHTS

EUROPEAN UNION — GDPR

If you are located in the EU you have
additional rights under the General
Data Protection Regulation (GDPR).

Our legal basis for processing your
consumer health data is:

→ Contract performance — to fulfil
   your order and subscription
→ Legitimate interests — to improve
   our products and serve you better
→ Consent — for marketing emails
   and quiz responses

You have the right to lodge a complaint
with your national data protection
authority if you believe we have
mishandled your data.

UNITED KINGDOM — UK GDPR

If you are located in the UK your
rights are equivalent to EU GDPR rights
under the UK GDPR and Data Protection
Act 2018.

You can lodge a complaint with the
Information Commissioner's Office (ICO)
at ico.org.uk.

UNITED STATES — STATE LAWS

If you are located in Washington State
your health data is protected under
the Washington My Health MY Data Act.

If you are located in California
your health data is protected under
the California Consumer Privacy Act (CCPA)
and California Privacy Rights Act (CPRA).

Under these laws you have the right to:
→ Know what health data we collect
→ Access your health data
→ Delete your health data
→ Opt out of the sale of your data
   (we do not sell your data —
   but you have the right to confirm this)
→ Non-discrimination for exercising
   your rights

To exercise your California or
Washington State rights:
Email hello@eluje.com
Subject: State Privacy Request — [Your Name]

CANADA — PIPEDA

If you are located in Canada your
health data is protected under the
Personal Information Protection and
Electronic Documents Act (PIPEDA).

You have the right to access and
correct your personal health data
and to withdraw consent at any time.

AUSTRALIA — PRIVACY ACT

If you are located in Australia your
health data is protected under the
Privacy Act 1988 and the Australian
Privacy Principles (APPs).

You can lodge a complaint with the
Office of the Australian Information
Commissioner (OAIC) at oaic.gov.au.

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9. SENSITIVE HEALTH DATA

We recognise that postpartum health
information is sensitive.

We treat all consumer health data
with the highest level of care —
regardless of whether it is legally
classified as sensitive in your region.

We never use your health data to:
→ Make assumptions about your
   mental health status
→ Share information about postpartum
   depression or anxiety with
   any third party
→ Target you with advertising based
   on sensitive health conditions
→ Discriminate against you in
   any way based on your health status

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10. CHILDREN'S HEALTH DATA

Our products are intended for adults.

We do not knowingly collect health data
from anyone under 18 years old.

If you believe a child has provided
us with health information,
please contact us immediately at
hello@eluje.com and we will delete
it within 24 hours.

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11. CHANGES TO THIS POLICY

We may update this policy from time to time
as our practices change or as laws change.

When we do:
→ We update the date at the top
   of this page
→ We notify you by email if the changes
   are significant
→ Your continued use of eluje.com
   after changes are posted means
   you accept the updated policy

Previous versions are available
on request — email hello@eluje.com.

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12. CONTACT

Questions about this policy?
Concerns about your health data?
Want to exercise your rights?

We are here.

Email:      hello@eluje.com
Subject:    Health Data — [Your Question]
Response:   Within 24 hours on business days

Postal address:
ELUJE
[Your Business Address]
[City, Country, Postcode]

We are real people.
We take your health data seriously.
We will sort it out.

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DISCLAIMER

Our products are food supplements.
They are not medicines.
They are not intended to diagnose,
treat, cure, or prevent any disease.

These statements have not been evaluated
by the Food and Drug Administration.

Always consult your healthcare provider
before starting any new supplement —
especially if you are pregnant,
breastfeeding, taking medication,
or have a medical condition.

Individual results may vary.