McZeely Coterie, LLC Privacy Notice. Effective Date of this Privacy Notice: February 11, 2015.

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1 McZeely Coterie, LLC Privacy Notice Effective Date of this Privacy Notice: February 11, We at McZeely Coterie, LLC, the company that proudly brings you Plan Z by Zola ( Plan Z ), respect your concerns about privacy. This Privacy Notice describes how the information collected when you (i) register for and use Plan Z and (ii) access and use our Websites ( our public website and our client-only website) will be used and how you can control the collection, use, maintenance, protection, disclosure, correction and deletion of information. Further this Privacy Notice explains how we use, process and disclose your personal information, with whom we share it and the measures we take to protect its security. Please read the following carefully to understand our practices regarding your personal information. Information We Collect We collect two types of information, information that you voluntarily provide and information that is automatically provided to use as a result of your access and use of our Websites. When you choose to submit personal information to our Websites, your information is used only for the specific purpose for which it was submitted, unless you consent otherwise or as required by law. In many cases, you choose the amount of information you supply. There may be instances where some of the information that we ask you to provide is identified as mandatory and some as voluntary. In such cases, if you do not provide mandatory personal information with respect to a particular activity, you will not be able to engage in that activity. The types of personal information that Plan Z users may supply include: Personal/Contact Information When you register for Plan Z on our Websites, we collect your name, e- mail address, mailing address, telephone number and limited health information. The personally identifiable information we collect when you register for membership on our Websites may be used for any of the following purposes: (1) to fulfill your requests for products and services; (2) to notify you of order, delivery, and shipment statuses; (3) to provide you with offers from Plan Z; (4) to contact you when necessary; (5) to review Website usage and operations; (6) to address problems with the WHD/

2 Websites, our business or our products and services; and (7) to protect security or integrity of the Websites and our business. Your personal information may be shared with reputable third-party associates of Plan Z that work with us to provide products and services to our customers, that help us with marketing campaigns, or that intend to market products and services to you directly, unless you have expressly asked us not to. We may also disclose your information to third parties if the law requires it or to protect the rights or property of Plan Z. If you do not want us to share your contact information with other companies or organizations or do not want to receive additional promotions from us, please let us know by ing us at or click on the unsubscribe link at the bottom of any recent marketing you have received from us. If you opt-out of promotional or newsletter s from Plan Z, we may continue to send you certain transactional communications, such as service announcements and administrative messages relating to Plan Z, that are necessary to our relationship with you. Please note that if you opt-out of communications from Plan Z you will not receive the educational communications which are a vital part of the Plan Z program. Health and Age Information We may also collect your basic health information. The health and age information we collect allows Plan Z to evaluate your self-reported health status to determine basic program eligibility. You will be notified at registration if your profile excludes you from participation in the plan. You should discuss any diet program with your health care professional. Plan Z will not disclose your health and age information (including selfreported height and weight) to third parties. Credit Card and Payment Information Plan Z utilizes a third party credit card processing service for membership registrations that are processed via the Websites. Please consult PayPal s Privacy Policy for further information about that company s privacy practices. Plan Z does not share payment information with third parties WHD/

3 nor does it collect payment information from payments submitted in PayPal. Occasionally members will call us to place an order, in which case we receive the member s credit card number so that we can process the purchase. We do not retain credit card numbers. Information Provided in Optional Surveys Plan Z periodically asks members to participate in online surveys or fill out online questionnaires concerning topics such as the effectiveness of Plan Z, advertising effectiveness and customer satisfaction. All surveys and questionnaires are optional and the information collected will not be associated with any user's personal information. Information gathered may be shared with third parties in order to improve customer satisfaction and program effectiveness. No personal information of any user will be connected to survey or questionnaire results. Other Information You May Voluntarily Provide From time to time, Plan Z collects third-party addresses or other contact information from our users and customers so that Plan Z may send information to their friends and family on an as-requested basis. The types of aggregate, not personally identifiable information that we may collect from users of the Websites may include: Log Files: Our servers automatically record certain information (e.g., web request, Internet Protocol ( IP ) address, browser type, browser language, URLs, etc.) that your web browser sends whenever you visit our website. Cookies: When you visit our website, we ask your browser to store small text files containing a string of alphanumeric characters known as a cookie. We use both session cookies and persistent cookies. If you have chosen to identify yourself on our website, we use session cookies containing encrypted information to identify you and facilitate your use of the website. Session cookies are required to access much of the content and services offered on the website. After you leave our website and close your browser, a persistent cookie remains. Persistent cookies can be removed by following your help file directions in your web browser. If you refuse our cookies, some features of the website may not function properly. WHD/

4 Web Beacons: We may employ clear GIFs or web beacons to track anonymously how users use the website. We may also use web beacons in our s to track which s are opened. Analytics: When someone visits the website, our web servers automatically gather information that allows the website to communicate with the user s computer during the visit. We also may use any of the following information: the number of visits to the website, which parts of the website users select, IP address (the Internet address assigned to your computer from your Internet Service Provider), domain type, browser type (e.g., Internet Explorer) and date and time of day. We use this information for statistical purposes that help us design and administer the website. Those types of information do not disclose personally identifiable information that would permit us to identify or locate individual visitors. How We Use the Information We Collect We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Notice. Plan Z shares information with third-party intermediaries for shipping and billing purposes and with other third-party intermediaries that provide a service for Plan Z to help us operate our business and the Websites or administer activities on our behalf. These companies do not retain personal information or share it with any other parties. These companies may include United States Postal Service, PayPal, United Parcel Service, Federal Express, Visa, MasterCard, Discover, and American Express and others. Plan Z may also provide aggregate statistics about our customers, sales, traffic patterns, and related site information to reputable third-party vendors. In addition, from time to time, we may make customer addresses and postal addresses available to other reputable business associates whose products or services might be of value to you. If you do not want us to share your information with other companies or organizations, please let us know by ing us at or click on the unsubscribe link at the bottom of any recent marketing you have received from us. WHD/

5 In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, (iv) to protect against misuse or unauthorized use of the Websites, (v) to investigate reports of users sending material using a false address or users sending harassing, threatening, or abusive messages or (vi) to protect our rights and property. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information. Mobile Devices/Third-Party Fees From time to time, we may make mobile device application and mobile marketing campaigns available to you and may allow you to register for services that involve messages and/or s being sent to your mobile device. You are responsible for obtaining access to the mobile device services. Such access may involve third-party fees, including mobile carrier, text messaging, or airtime charges. You are solely responsible for those fees, including any and all fees associated with the use of the applications, delivery of the messages, s or other materials to your mobile device. Please consult your mobile service provider's pricing plan prior to purchasing or downloading any application or registering for any such service to determine the charges for sending and receiving text messages from/to your mobile device. You will be given the opportunity to opt-out of receiving text messages or s to your mobile device at the time you register for the campaign and with each message or you receive. Mobile marketing campaigns may involve your sending an from your mobile device to us or a third-party campaign operator. An or other response will then be sent to your mobile device. Opting to participate in a campaign is 100% your choice. When you engage in these mobile marketing campaigns, we and the third-party campaign operator may collect your cell WHD/

6 phone number, the name of your wireless service provider, images that you send using your cell phone as part of the campaign, and other relevant information. Our Forums and Social Media Pages Plan Z provides support through our forums, through s, social media pages, recipe, blogs pages and telephone. This format gives our members the opportunity to interact with each other. You are offered the opportunity to include your address with your message, but you are not obligated to do so. Please keep in mind that whenever you voluntarily disclose personal information online (whether it is on forums, through , on social media pages or in blogs) your information can be collected and used by others. In short, if you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return. We cannot control the actions of any third parties. We reserve the irrevocable, perpetual and worldwide right to copy and post both within the Websites, and those of our affiliates, subsidiaries, assigns, agents and licensees and any social media outlets and advertising medium through which we are engaged, any comments, pictures or other information you post on the pictures of other information you post in the forums, social media pages, blogs, or elsewhere on the Websites, without any further notice to you or any remuneration therefore. How We Protect Personal Information We will take reasonable measures which we believe are appropriate to protect your information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer your information take comparable steps to protect that security. Although we will use all reasonable efforts to safeguard the confidentiality of any visitor information collected, we shall have no liability for disclosure of any visitor information obtained due to errors in transmission or the unauthorized acts of third parties. is not a secure form of communication. Please do not send us your social security number, credit card number or other personal information via . Unfortunately, the transmission of information via the Internet or over mobile networks is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to and from the Websites or over mobile networks; any transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorized WHD/

7 access. We ask that any third parties to whom we may transfer your personal information take comparable steps to protect that security. We are not subject to the privacy and data security requirements of the Gramm-Leach-Bliley Act ( GLBA ) or Health Insurance Portability and Accountability Act ( HIPAA ). Links to Other Websites Our Websites may provide links to other websites for your convenience and information. These third party websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for the sites content, any use of the sites, or the privacy practices of the sites. Children We are committed to protecting the privacy and rights of children online. The Websites and Plan Z are not intended for use by children under the age of 18, without the consent of the minor s legal guardian. For legal guardians or parents of children ages under the age of 18 years old, please call and please consult a physician. To that end, we do not knowingly collect any personally identifiable information from users under the age of 18. Thus, the Websites are compliant with the Children's Online Privacy Protection Act ( COPPA ). Notice to California Customers - Your California Privacy Rights California's Shine the Light law, Civil Code section , requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above, if you wish to opt-out of our sharing of your information with third parties for the third parties' direct marketing purposes or to find out more about your opt-out rights, please contact us at the address described above. WHD/

8 Updates to Our Privacy Notice This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post a prominent notice on our Website to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. Where required by law, we will seek your explicit consent to specific changes. You agree that we may notify you via of any important changes to this Privacy Notice. How to Contact Us We offer you certain choices in connection with the personal information we collect from you, such as how we use the personal information and how we communicate with you. If you have any questions or comments about this Privacy Notice or if you would like us to update information we have about you or your preferences, please contact us by at You also may write to: McZeely Coterie, LLC 2436 W Bloomingdale Avenue Chicago, IL WHD/

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