Privacy Policy

Last Updated: April 10, 2025

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using our site or submitting information through the site, You agree to the terms of this Privacy Policy and consent to the collection and use of your user-identifiable information in accordance with this Privacy Policy.

Definitions
For the purposes of this Privacy Policy:

You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User.

• Company (referred to as either "the Company", "We", "Us" or "Our") refers to Aspire Vitality PLLC, 275 Turnpike Street, Suite 206, Canton, MA 02021. For the purpose of the GDPR, the Company is the Data Controller.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party.
• Account means a unique account created for You to access our Service.
  Website refers to Aspire Vitality, accessible from https://aspirevitality.com
• Service refers to the Website.
• Country refers to: MA, United States.
• Service Provider refers to any natural or legal person who processes data on behalf of the Company.
• Third-party Social Media Service refers to any platform used for account creation/login.
• Facebook Fan Page is a public profile created by the Company on Facebook, accessible from https://www.facebook.com/
• Personal Data is any information that relates to an identified or identifiable individual.
• Cookies are small files placed on Your device by a website.
• Device means any technology that can access the Service.
• Usage Data refers to data collected automatically from the Service.
• Data Controller refers to the Company, Aspire Vitality PLLC, under GDPR.
• Do Not Track (DNT) is a user preference setting to prevent tracking.
• Business, under the CCPA, refers to Aspire Vitality PLLC.
• Consumer, under the CCPA, means a California resident.
• Sale, under the CCPA, means transferring personal data for monetary or other valuable consideration.

General
We do not share mobile information with third parties for marketing. You may opt out of messaging by texting STOP. We may collect user and non-user identifiable information.

Non-user identifiable data includes IP address, pages viewed, device type, browser version, and location (if enabled), used for analytics and improvement purposes.

We may share data with service providers for functionality and analytics. We do not sell your identifiable data for third-party marketing.

Cookies, web beacons, and similar technologies may be used to enhance your experience.

Tracking Technologies and Cookies
We use Cookies and similar tracking technologies for the purposes listed below:

Necessary / Essential Cookies

• Type: Session
• Administered by: Us
• Purpose: To provide the core functionalities of the Website.

Cookies Policy / Notice Acceptance Cookies

• Type: Persistent
• Administered by: Us
• Purpose: To determine if you accepted our use of cookies.

Functionality Cookies

• Type: Persistent
• Administered by: Us
• Purpose: To remember preferences such as language or login.

Tracking and Performance Cookies

• Type: Persistent
• Administered by: Third Parties
• Purpose: To analyze usage and test new features.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data may include:

• Email address
• First and last name
• Address, State, ZIP/Postal Code, City
• Usage Data

Usage Data is collected automatically and may include:

• IP address
• Browser type and version
• Pages visited, time and date
• Device identifiers
• Diagnostic data

We collect information from both web and mobile access points.

Aspire Vitality PLLC (“Aspire,” “we,” “us,” or “our”) maintains this Privacy Policy to explain how user-identifiable information collected via our Site is used. “User identifiable information” includes your name, email, phone number, or other linked data.

Aspire also maintains a HIPAA Notice of Privacy Practices applicable to “protected health information” (PHI) as defined under 45 CFR §160.103.

Use of Your Personal Data
The Company may use your Personal Data for purposes such as:

• Operating and maintaining our Service
• Managing Your Account
• Contract fulfillment
• Communicating via email, phone, or app notifications
• Sending updates and promotional content (unless opted out)
• Managing user requests
• Improving internal operations and user experience
• Legal obligations, such as mergers or acquisitions

Sharing Your Personal Information
We may share your data under the following circumstances:

• Emergency Situations: Medical or safety-related disclosures
• Legal Requirements: Government or law enforcement requests
• With Service Providers: For analytics, payments, or contact purposes
• Business Transfers: In connection with a sale, merger, or acquisition
• With Affiliates: Controlled entities bound by this policy
• With Business Partners: For co-branded offerings or promotions
• With Other Users: Information you share publicly or via social media integrations

• Retention of Your Personal DataThe Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

  The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

  Transfer of Your Personal Data
  Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

  Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

  The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

  Disclosure of Your Personal Data

  Business Transactions/Transfers
  If the Company is involved in the event of a merger, sale, acquisition, or similar event, user data may be transferred as part of business assets. Your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy. We cannot guarantee how such data will be treated in bankruptcy or insolvency events.

  Law enforcement
  Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

  Other legal requirements
  The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  Comply with a legal obligation

  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

  Security of Your Personal Data
  The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

  Detailed Information on the Processing of Your Personal Data
  Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose.

  Analytics

  We may use third-party Service providers to monitor and analyze the use of our Service.

  Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy

  Email Marketing
  We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

  We may use Email Marketing Service Providers to manage and send emails to You.
  Payments
  We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

  We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

  Advertisements
  Any advertisements on our Site may collect data directly or link to third-party sites. Aspire is not responsible for their privacy practices.

  Surveys
  We may occasionally offer voluntary surveys. If identifiable information is collected, it may be used internally or shared with contractors as described.

  International Users
  If you are located outside the U.S., your information may be transferred to and processed in the U.S. or other countries. By using the Site, you consent to this transfer.

  Anonymous Aggregate Data
  We may share anonymized, aggregated information with third parties. While this data does not directly identify individuals, it may be combined with other sources to potentially identify users.

  Opting Out
  To stop receiving direct marketing communications, you may email us to opt out. Please note that:

  Your opt-out applies only to Aspire;
  It does not affect third parties who have received your information;
  Processing of your opt-out may take time.
  Security

  We implement security measures to protect your information, but we cannot guarantee complete protection. By using the Site, you acknowledge that no security is perfect.

  GDPR Privacy
  Legal Basis for Processing Personal Data under GDPR

  We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

  In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

  Your Rights under the GDPR
  The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

  You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
  • Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

  Exercising of Your GDPR Data Protection Rights
  You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

  You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

  Facebook Fan Page
  Data Controller for the Facebook Fan Page
  The Company is the Data Controller of Your Personal Data collected while using the Service. As operator of the Facebook Fan Page, the Company and the operator of the social network Facebook are Joint Controllers.

  The Company has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service: https://www.facebook.com/terms.php

  Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

  Facebook Insights
  We use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

  For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

  Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

  For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

  CCPA Privacy
  Your Rights under the CCPA
  Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
  • The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting our "Do Not Sell My Personal Information" section.
  • The right to know about Your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
    1. The categories of Personal Data collected
    2. The sources from which the Personal Data was collected
    3. The business or commercial purpose for collecting or selling the Personal Data
    4. Categories of third parties with whom We share Personal Data
    5. The specific pieces of Personal Data we collected about You
    6. The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
    7. The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:
       1. Denying goods or services to You
       2. Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
       3. Providing a different level or quality of goods or services to You
       4. Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

  Exercising Your CCPA Data Protection Rights
  In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or call us or visit our "Do Not Sell My Personal Information" section.

  The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

  Do Not Sell My Personal Information
  We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

  If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

  Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that you use.

  Desktop Browser
  You can opt out of receiving ads that are personalized as served by other Service Providers by following our instructions presented on the Service:

  Use an "Ad Block" browser extension

  Mobile Devices
  Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices
  • "Limit Ad Tracking" on iOS devices
  • You can also stop the collection of location information from Your mobile device by changing the preferences on your mobile device.

  "Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)
  Our Service does not respond to Do Not Track signals.

  However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

  Children's Privacy
  Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

  If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

  Links to Third Party Websites
  Our Service may contain links to other websites that are not operated by Us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

  We cannot guarantee that third parties will not re-disclose your information in a manner not authorized by us.  If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

  Changes to this Privacy Policy
  We reserve the right to change this Privacy Policy. We will publish updates at least 30 days before they become effective. Your continued use of the Site after changes are made constitutes your acceptance of those changes. This privacy policy does not create any legal right for you or any third parties.

  We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

  You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

  Access, Correction, Deletion, or Transfer of Information
  You may revoke your authorization or request access to, correction of, or deletion of your personal information by emailing us. We will take reasonable steps to fulfill such requests.

  Contact Information
  If you have questions about this Privacy Policy or the practices of this Website, please contact us at:

  Aspire Vitality PLLC
  275 Turnpike Street, Suite 206
  Canton, MA 02021
  Email:info@aspirevitality.com
  Website: https://aspirevitality.com