Privacy Policy

Effective Date of this Version: January 19, 2021

1. Overview

Reform RX, Pilates Equipment Limited. (“Reform RX”, “we”, or “us”) provides an online fitness community and related products, equipment, services, content and features (collectively the “Services”) through website (the “Site”), the interfaces on tablets connected to Reform RX equipment, and through mobile, desktop, or device applications (including iOS and Android applications (“Apps”)) and Reform RX-controlled social media pages (including on Facebook, Instagram, and Twitter). This Privacy Policy governs the manner in which Reform RX collects, uses, maintains and discloses information collected from its current, prospective, and former customers, members, users, visitors, and guests (each, a “User”). This Privacy Policy applies to Users of the website (“Site”) as well as all Products and Services offered by Reform RX.

2. Scope

This Privacy Policy applies to Personal Information that is Processed by Reform RX in the course of our business, including via the Site, the interfaces on tablets connected to Reform RX equipment, and through our Apps, forums, social media accounts, blogs, studios, retail showrooms, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Reform RX, the “Services”). All individuals whose responsibilities include the Processing of Personal Information on behalf of Reform RX are expected to protect that data by adherence to this Privacy Policy.

3. Collection of Personal Information

We may collect Personal Information from Users in a variety of ways, including, but not limited to, when users visit our site, register on the site, subscribe to the newsletter, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site.

Users may be asked for, as appropriate, their name, email address, phone number. Users may, however, visit our Site anonymously. We may also collect Personal Information when Users purchase REFORM RX

Products or Services from REFORM RX including fitness equipment and accessories, apparel, live in-studio classes or subscription services offered through any device. Such personal identification information may include information such as Users’ name, email address, mailing address, phone number, payment information, such as credit card number (“Financial Information”) and/or other related information that may be required for a User to complete a purchase. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information, except that it may prevent them from engaging in certain Site related activities. Personal Information may be collected in the following ways:

User Profiles.

Users who purchase REFORM RX Products and Services may be asked to create a “User Profile.” Personal Information collected as part of a User Profile may include a username, email address, age, location, phone number, image or avatar, and certain health information including, but not limited to, your height and weight.

Once your User Profile is created, anytime you log in to participate in a studio class in-person or via our subscription service, we may collect additional information and add it to your User Profile, such as the total number of classes taken, the dates you took those classes, fitness performance history (including leaderboard rank, achievements earned, total output, speed, distance and calories burned), your followers and who you are following, and, to the extent you have worn a heart rate monitor that you have connected to your fitness equipment, information about your heart rate over the course of the class and any other information that may be available from time to time.

You acknowledge that your User Profile information may be personal to you, and by creating an account and providing such information through the use of our Services, you allow others, including REFORM RX, to identify you and therefore you may not be anonymous. Information included in your User Profile, including any achievements or milestones may be displayed on in-studio digital signage if you come to a live class at any of our studios. REFORM RX User Profiles are set to public by default, which means that other registered REFORM RX users will also be able to view your User Profile, including, potentially, your fitness performance history (as described above), your REFORM RX leaderboard name, and your location and age (if you have provided it), and those users can contact or follow you through the Services. You have the option to set your profile to “Private,” which means that only members who you approve as followers can see your profile and fitness performance history, and you can remove other users from your followers.

Other User Information.

REFORM RX may also collect other information from you as a result of your use of the Services, such as in-studio attendance history, purchase history, fitness and health related information. We may associate this information with other Personal Information that you have provided in order to improve and provide the Services and as otherwise described in this Privacy Policy.

Communications with Us.

We may collect Personal Information from you such as your email address, phone number or mailing address, when you choose to request information about our services, visit our retail showrooms, register to receive REFORM RX communications over email or text messaging, participate in promotions, or loyalty programs that we may offer from time to time, request to receive member or technical support or otherwise communicate with us.

Surveys and Reviews.

From time to time, we (or third parties acting on our behalf) may contact you to participate in research, surveys or beta testing or to provide reviews and testimonials. If you decide to participate, you may be asked to provide certain information, which may include personal Information. All information collected from your participation in our research, surveys, reviews or testimonial process, or beta testing is provided by you voluntarily. We may use such information to improve our products, our Site and/or Services, and in any manner consistent with this Privacy Policy.

Posting on the REFORM RX or Third Party Services. REFORM RX may offer publicly accessible blogs, social media pages, product review pages, private messages, video chat or community forums. You should be aware that, when you disclose information about yourself on REFORM RX’s blogs, social media pages, product review pages, private messages, community forums, and within video chat sessions, REFORM RX will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content, including reviews, to any public area of the Services or on any public sites operated by third parties, such content will be considered “public” and will not be subject to the privacy protections provided in this Privacy Policy.

Registration for Sweepstakes or Contests. Occasionally, REFORM RX may run sweepstakes and contests. We ask those who enter sweepstakes or contests to provide contact information (e.g., a phone number or an email address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and, to the extent permitted by law, for other promotional, marketing and business purposes. In compliance with the laws of your jurisdiction, as a participant you may have the opportunity to opt-out of any communications that are not related to awarding prizes.

Location Information.

Based on your interaction with the Services, the type of device you use to access the Services, and your device’s connectivity, we may collect location-based information including your Internet protocol (IP) address, GPS location, longitude/latitude, city, county, postcode code and region, and your location and your smart device’s proximity to “beacons,” Bluetooth networks and/or other proximity systems. We may use this type of information to enhance your user experience (such as using location information for the purposes of displaying the geographic distribution of REFORM RX workouts on a heat map), to better understand your interaction with our products and services in our showrooms, or to enable you to track your outdoor fitness activities. Unless you provide us with your consent to do otherwise, this information will only be used by us and our third party service providers to provide you with the Services you request or in an aggregated and anonymised format that does not identify you. If you no longer wish to have this location information collected and used by us, you may opt-out by disabling the location and Bluetooth features in the operating system of your device.

Automatic Data Collection.

We may collect certain information automatically through our Services or other methods of web analysis, such as your IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. Information from Other Sources. We may receive information about you from other sources, including through third party services and organisations, to supplement information provided by you. For example, if you access our Services through a third party application, such as the Apple App Store or Google Play App Store (together with any similar applications, “App Stores”) or social media sites such as Facebook, we may collect information about you from that third party application that you have made public via your privacy settings. Information we collect through App Stores or social media accounts may include your name, your social media site user identification number, your user name, location, gender, birth date, email, profile picture and your social media contacts. This supplemental information allows us to verify information that you have provided to REFORM RX and to enhance our ability to provide you with information about our business, products and Services.

4. Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilised and other similar information.

5. Web browser cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

6. How we use collected information

REFORM RX may collect and use Users personal identification information for a variety of business purposes, including:

To Provide Products, Services, or Information Requested. REFORM RX may use information about you to fulfil requests for products, Services or Information, including Information about potential or future services, including to:

Generally manage personal information and accounts;

Respond to questions, comments, and other requests;

Provide access to certain areas, functionalities, and features of REFORM RX’s Services;

Assist with monitoring your performance, fitness and health related statistics and usage trends;

Personalise exercise and activity goals for you based on your settings and your historical exercise or activity data;

Communicate with you about logistical matters, including product deliveries and product servicing visits;

Provide services to you;

Review and contact you to answer requests for member support or technical support; and

Allow you to register for classes and events.

Administrative Purposes. REFORM RX may use Personal Information about you for its administrative purposes, including to:

Measure interest in REFORM RX’s Services;

Develop new products and Services;

Ensure quality control;

Verify Individual identity;

Communicate about Individual accounts and activities on REFORM RX’s Services and systems, and, in REFORM RX’s discretion, changes to any REFORM RX policy;

Send emails or text messages to the email address or telephone number you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, delivery updates, or system maintenance;

Process payment(s) for products or services purchased;

Process applications and transactions;

Prevent potentially prohibited or illegal activities;

Maintain and administer our Services; and

Enforce our Terms.

Marketing REFORM RX Products and Services. REFORM RX may use Personal Information to provide you with materials about offers, products and Services that may be of interest, including new content or services. REFORM RX may provide you with these materials by phone, postal mail, text or email, as permitted by applicable law. Such uses include:

To tailor content, advertisements and offers;

To notify you about offers, products and services that may be of interest or about which you have previously expressed an interest;

For other purposes disclosed at the time that Individuals provide Personal Information; or

Otherwise with your consent. You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described below.

Research and Development. REFORM RX may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us improve our existing products and Services or develop new products and Services. From time to time, REFORM RX may perform research (online and offline) via surveys.

We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilised to determine the effectiveness of our Services, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may, as permitted by law, receive periodic emails, newsletters, mailings, text messages or phone calls from us with information on REFORM RX’s or our business partners’ products and services or upcoming special offers/events that we believe may be of interest.

Services via Apps and other Devices. From time to time, REFORM RX may provide Services that are specifically designed to be compatible and used on third party devices, such as mobile phones, smart TVs, and tablets. REFORM RX will collect certain information that your device sends when you use such Services, like a device identifier, user settings, location information, carrier and the operating system of your device. These versions of REFORM RX’s Services may require that users log in with an account. In such cases, information about use of these versions of the Services may be associated with accounts. In addition, REFORM RX may enable you to download an application, widget or other tool that can be used on mobile, tablet or other devices. Some of these tools may store information on your devices. These tools may transmit Personal Information to REFORM RX to enable you to access accounts and to enable REFORM RX to track use of these tools. Some of these tools may enable users to export reports and other information from the tool. REFORM RX may use personal or non-identifiable information transmitted to REFORM RX to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices REFORM RX provides.

Anonymous and Aggregated Information Use. REFORM RX may use Personal Information and other information about you to create anonymised and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access REFORM RX’s Services or other analyses we create. Anonymised and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymised or aggregated information is not Personal Information, and REFORM RX may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes.

We may share this information within REFORM RX and with third parties for our or their purposes in an anonymised or aggregated form that is designed to prevent anyone from identifying you.

Other Uses. REFORM RX may use Personal Information for which we have a legitimate interest, such as fraud protection or compliance with legal obligations, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

7. Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

REFORM RX, as well as third parties that provide content, advertising or other functionality on our Services, may use cookies, pixel tags, local storage and other technologies (“Technologies”) to automatically collect information through the Services. We may use Technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices that allow us to record certain pieces of information whenever you visit or interact with our website, services, applications, messaging and tools, and to recognise you across devices.

Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the site may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

Social Media Widgets: The Site includes social media features such as links to Facebook, Instagram, Twitter, YouTube and LinkedIn (that might include widgets, such as, the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on the Site and may set a cookie to enable the feature to function properly.

These social media features are either hosted by a third party or hosted directly on the Site.

Your interactions with these features are governed by the privacy policy of the company providing it.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use Technologies that are necessary to the operation of our Site, Services, applications, and tools. This includes Technologies that allow you access to our

Site, Services, applications, and tools; that are required to identify irregular site behaviour, prevent fraudulent activity and improve security; or that allow you to make use of functions such as shopping carts, saved search or similar functions.

Performance Related. We may use Technologies to assess the performance of our Site, applications, Services and tools, including as part of our analytic practices to help us understand how our visitors use our Site, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services or tools;

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests or past items viewed so that we may enhance the presentation of content on our Sites;

Advertising or Targeting Related. We may use first-party or third party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites.

This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

8. Third-Party Websites, Social Media Platforms, and Software Development Kits

The Site may contain links to other websites and other websites may reference or link to the REFORM RX Site or other Services. These other domains and websites are not controlled by REFORM RX, and we do not endorse or make any representations about third party websites or social media platforms. We encourage you to read the privacy policies of each and every website and application with which you interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting other websites or applications is at your own risk.

REFORM RX’s Services may include publicly accessible blogs, community forums, message boards, private messaging or video chat features. The Services may also contain links and interactive features with various social media or music platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using the Services. You should be aware that Personal Information that you voluntarily include and transmit online in a publicly accessible blog, video chat session, social media platform or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We are unable to control such uses of your information when you interact with a third party platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

We may use third party software development kits (“SDKs”), such as the Fitbit, Apple HealthKit and Strava SDKs, as part of the functionality of our Services, and REFORM RX equipment may contain wireless data transfer capabilities such as near field communication (or NFC) to facilitate pairing to devices usingthese SDKs and other wearable devices. We may also enable you to link your REFORM RX account to certain health-related applications. If you choose to link your REFORM RX account with such applications, you can decide to share the health information we collect about you while you use the Services, including but not limited to your heart rate, calories, cycling, walking and running distances, time spent meditating, and the list of your REFORM RX workouts taken with such applications. If you decide to do so, you may also be able to transfer other personal information, such as your gender, date of birth, heart rate, height, weight and walking and running distances, from the health related applications to REFORM RX. If you make this election, this information may be used by REFORM RX to update your REFORM RX User Profile and track your metrics in REFORM RX classes. You may opt-out of tracking at any time by configuring your privacy settings on such applications. We do not share information that we collect from SDKs or other health-related applications with third parties for their advertising or marketing purposes. Your interactions with SDKs or other health applications are governed by the privacy policy of the company providing the service.

9. Third-Party Payment Processing

When you make purchases through the Services, REFORM RX may process your payments through a third party application, such as an App Store or, in the case of online or in-person purchases via a Third-Party payment processor. In these instances, the third party application may collect certain Financial

Information from you to Process a payment on behalf of REFORM RX, including your name, email address, address and other billing information in which case the use and storage of your Financial Information is governed by the third party app’s terms, conditions and privacy policies. If you apply for or otherwise take part in a financing offer through one of our financing partners, you will be asked to provide information (which may include Financial Information) to that financing partner, either directly or through the Services. The use of that information by the financing partner will be subject to the financing partner’s terms, conditions and privacy policies. Our treatment of any Financial Information that we may Process on your behalf, or that we receive from our financing partners or payment processors, is subject to this Privacy Policy.

10. Information We Share

We may share your information as described in this Privacy Policy (e.g., with our third party service providers; to comply with legal obligations; to enhance the Services, to protect and defend our rights and property) or with your permission.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT, analytics and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities such as deliveries and member support; and (v) in connection with the provision of the

Services. REFORM RX’s policy is to execute appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements, and this Privacy Policy.

Business Partners. REFORM RX may share Personal Information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. REFORM RX may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with REFORM RX.

Displaying to Other Users. The content you post to the Services may be displayed on the Services. Other users of the Services may be able to see some information about you, such as your name if you submit a review or provide a testimonial to our Site. We are not responsible for the privacy practices of the other users who view and use posted information.

Marketing – Interest-Based Advertising and Third-Party Marketing. REFORM RX may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities on our Sites (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third party advertising partners.

These advertising partners may use this information (and similar information collected from other companies) for purposes of delivering targeted advertisements to you when you visit non-REFORM RX related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioural advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.

Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve and disclose your Personal Information, other account information and content if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process, such as, a court order or subpoena; (ii) to respond to your requests; (iii) to protect yours, ours or others’ rights, property or safety; (iv) to enforce REFORM RX policies or contracts; (v) to collect amounts owed to REFORM RX; (vi) to comply with records retention policies; (vii) when we believe access, preservation, or disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (viii) if we, in good faith, believe that access, preservation, or disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorised activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order to allow them to identify users in connection with their investigation of unauthorised activities.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing, reorganisation, bankruptcy, receivership, sale of company assets or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, REFORM RX will endeavour to direct the transferee to use Personal

Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

11. Opting Out

You have the right to object to and opt-out of certain uses and disclosures of your Personal Information.

Where you have consented to REFORM RX’s Processing of your Personal Information or Sensitive Personal

Information, you may withdraw that consent at any time and opt-out to further Processing by contacting REFORM RX as described in Section 18. Even if you opt-out, we may still collect and use non-

Personal Information regarding your activities on our Service and/or information from the advertisements on third party websites for non-interest based advertising purposes, such as, to determine the effectiveness of the advertisements.

You can unsubscribe from email, text and phone communications at any time. To stop receiving our promotional emails, follow the unsubscribe instructions in the email messages you receive from us. To opt-out of receiving text messages, follow the opt-out instructions in the text messages that you receive from us. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding

REFORM RX and our Services and, to the extent permitted by law, you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

12. Rights of Access, Rectification, Erasure, and Restriction

Where permitted by applicable law, you may inquire as to whether REFORM RX is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of your rights under data privacy laws that apply in the country where you live. Where otherwise permitted by applicable law, you may contact REFORM RX as set out in this Privacy Policy to request access to, receive, seek rectification, or request erasure of Personal Information held about you by REFORM RX. Please include your full name, email address associated with your account and a detailed description of your data request. Such requests will be processed in accordance with local laws.

Although REFORM RX makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which REFORM RX is unable to provide access, including but not limited to where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy, in the case in question or where it is commercially proprietary. If REFORM RX determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, REFORM RX will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

13. Data Retention

REFORM RX retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. When we are no longer required to retain your Personal Information as described above, we will destroy, erase, or de-identify it in accordance with our data retention policies and applicable law. Legal requirements, however, may require us to retain some or all of the Personal Information we hold for a period of time that is longer than that for which we might otherwise hold it.

14. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain commercially reasonable administrative, technical and physical safeguards (which vary depending on the sensitivity of the Personal Information) designed to protect against unauthorised use, disclosure or access of Personal Information. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Services. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Services or sending an email to you. You may have a legal right to receive this notice in writing.

15. Privacy Rights

If you would like a copy of our notice describing what categories of personal information we share with third parties or corporate affiliates for their direct marketing purposes and the names and addresses of the third parties and affiliates that received your information in the past year, please submit a written request to the following address: REFORM RX LTD, Attn: Legal Department, PO Box 239 Newry, Down, BT35 5EL, United Kingdom. Please allow up to 30 days for us to process your request. You may submit such a request once per year.

16. By using the Services,

you consent to REFORM RX’s transfer of your data to the United States. By choosing to visit the Site, use the Services, or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will, to the extent permitted by law, be governed by the laws of the State of Colorado, without regard to principles of conflicts of law. Any disputes arising in connection with this Privacy Policy will be handled in accordance with the dispute resolution provisions in the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use,

please note that you are agreeing to the transfer of your information to the United States and to the Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Privacy Policy.

17. Children’s Privacy

Our Services are not directed to children under the age of 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us as set out in this Privacy Policy. If we learn that we have collected Personal Information of a child under the age of 13 (or under the age of 16 in certain jurisdictions, such as EU member countries) we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.

18. Redress/Compliance and Accountability

If you have any questions about our privacy practices, this Privacy Policy, or how to submit a complaint with the appropriate authority, please contact REFORM RX by email at ( by mail at the below address. We or our Data Protection Officer will address your concerns and attempt to resolve any privacy issues in a timely manner.

PO BOX 239, Newry, Down, BT35 5EL, United Kingdom.
Attn: Legal Department

19. Changes to this Privacy Policy

REFORM RX has the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

20. Your acceptance of this Privacy Policy

By using this Site, you accept the terms of this Privacy Policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

21. Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.