Privacy Policy

This privacy policy applies only to the web site controlled by Covalent Medical, LLC and/or its affiliated entities ("we," "us" or "our") located at www.focusvitamins.com (the "Site"). This privacy policy does not pertain to information that is collected offline. BY USING THE SITE, YOU CONSENT TO THE TERMS OF THIS PRIVACY POLICY AND TO OUR PROCESSING OF PERSONAL INFORMATION FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITE.

Information

We Collect

1. Personally Identifiable Information

We collect two types of information about you when you visit our Site: personally identifiable information and non-personally identifiable information, such as aggregate or demographic information, or information regarding the pages on our Site that you have visited and your IP address. Each of these types of information is described below:

"Personally Identifiable Information" is information that identifies you personally, such as your name, mailing address, email address or telephone number, and non-personally identifiable information when directly linked to information that can identify an individual. For instance, if we collect your IP address (which is typically non-personal data) and tie it to your full name, the combination of this data would constitute "personally identifiable information."

We collect and store the personally identifiable information that you have provided to us. Here are some examples of manners in which we may collect your personally identifiable information on the Site:

• We may collect your first and last name, mailing address, email address, telephone number and practice name if you are a doctor who joins our mailing list;

• We may collect your name, mailing address and email address if you create an account on the Site;

• We may collect your name and email address if you contact us with a question; and

• We may collect your first and last name, mailing address and billing address if you make a purchase from the Site.

The above list provides an example of the personally identifiable information that may be collected on the Site. From time to time, we may collect personally identifiable information from you in other ways that are not described above. If you do not want us to collect your personally identifiable information, please do not provide it to us.

2. Non-Personally Identifiable Information

"Non-Personally Identifiable Information" can be technical information, such as your IP address, or it can be demographic information, such as your age, gender or the products that you are interested in. Here are some examples of the non-personally identifiable information that is collected via the Site:

• Internet Protocol (IP) address — Your IP address is a number that lets computers attached to the Internet know where to send you data -- such as the web pages you view. We may use this information to deliver our web pages to you upon request, to tailor our Site to the interests of our users and to measure traffic within our Site.

• Cookie — A "cookie" is a small text file that may be used to collect information about your activity on the Site. For example, when someone visits a page within the Site, a cookie is placed on the user's machine (if the user accepts cookies) or is read if the user has visited the Site previously. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but if you do, you may not be able to take advantage of the personalized features enjoyed by other users to our Site. Some of the cookies we use may be flash cookies or Adobe cookies. These cookies may not be deleted when your cookies are deleted. Please check your browser to determine where these types of cookies are stored and how they may be deleted.

Do Not Track Requests — At this time, our Site does not alter its behavior upon receiving Do Not Track requests and permits tracking and sharing of data across this Site and others.

• Demographic Information — From time to time, we also may collect "Demographic Information" from visitors to our Site. This may be your gender, age, zip code and interests, which you voluntarily provide to us on the Site. We use this information to provide you with personalized services and to analyze trends to ensure the information provided by the Site meets the needs of our visitors.

• Aggregate data — We also may collect non-personal information about a group or category of services or users. This is called "aggregate data" and it helps us understand trends in our users' needs so that we can better consider new features or otherwise tailor our services. For example, we may collect data about the products bought by residents of a particular state, without tying this data to any specific personal information about those residents.

The above list provides an example of the non-personally identifiable information that is collected via the Site. From time to time, we may collect non-personally identifiable information from you in other ways that are not described above.

This Policy in no way restricts or limits our collection and use of non-personally identifiable information and we may share this data with third parties for a variety of purposes, including to help us better understand our customer needs, to improve our Site and services and for advertising and marketing purposes.

Use of Information
Collected Via the Site

1. Personally Identifiable Information

We use your personally identifiable information that is collected on the Site primarily for the following purposes:

• To complete a transaction or service requested by you, or to provide you with information related to any product or purchase that you make on the Site;

• To respond to your questions;

•To confirm your creation of an account on the Site;

• If you are a doctor who joins the Site, to respond to your questions or assist you with your use or enjoyment of the Site;

• To deliver services, such as information, newsletters or other information that you request;

• To alert you to special offers, updated information and other new products from us, or other third parties, or to forward promotional materials;

• To ensure the Site is relevant to your needs;

• To help us create and publish content most relevant to you;

• To fulfill the terms of a promotion;

• To notify you about a material change to this privacy policy or the Terms of Use, if necessary; and

• To allow you access to limited-entry areas of the Site.

2. Non-Personally Identifiable Information

Non-personally identifiable information is used as described above, In Section A(2) and Section B, and in other ways as permitted by applicable laws, including combining non-personally identifiable information with personally identifiable information. As mentioned above, when we combine your personally identifiable information with non-personally identifiable information, the combination of this data would constitute "personally identifiable information."

Sharing and

Disclosure of
Information

1. Personally Identifiable Information

We may share or disclose your personally identifiable information in the following instances:

(i) To complete your purchase. If you choose to make a purchase on the Site, we may collect from you your first and last name, mailing address and other information related to such purchase, and we may use such collected information in order to fulfill your purchase. We may also provide such information, or other personally identifiable information provided by you, to unaffiliated third parties as necessary to complete your purchase. For example, we use a payment processing vendor, PayPal, to process your payment, in which case the vendor may also collect and store your data, including your credit card information. PayPal will maintain that data in order to facilitate the purchase.

(ii) To fulfill a service to you. If you are a doctor who joins the Site, we may use your personally identifiable information in order to provide you with information about our products or services. Similarly, if you create an account on the Site or choose to obtain any information provided by the Site, we may share your personally identifiable information in order to send you that information. In addition, if you email us a question, we may use your email address to process your request and respond to your question. Also, if you are entering a sweepstakes or contest that is advertised on the Site, we may use your personally identifiable information in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes or mail carriers. We also may share your information with the co-sponsor of that promotion.

(iii) To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personally identifiable information for research, administrative and/or internal business purposes. These parties may use your personally identifiable information to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administration or business purposes. If you do not want us to share your personally identifiable information in this manner, please do not provide us with this information.

(iv) To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Site and provide other administrative services to us (including, but not limited to, order processing and fulfillment, providing customer service, maintaining and analyzing data, sending customer communications on our behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions). We seek to ensure that these unaffiliated third parties will not use the personally identifiable information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Site will have access to users' personally identifiable information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personally identifiable information to us.

(v) To comply with the law or in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property or act in urgent circumstances to protect the personal safety of our end users.

(vi) To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

(vii) To track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.

(viii) To protect against potential fraud, we may verify with third parties the information collected from the Site. In the course of such verification, we may receive personally identifiable information about you from such services.

Except as described in this privacy policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personally identifiable information to any third parties.

2. Non-Personally Identifiable Information

We use non-personally identifiable information collected on the Site in the manner disclosed above, in the Section A(2) and Section B. We may share this non-personal information with third parties.

Opt-Out

We communicate with users who subscribe to our services via email. We provide you the opportunity to exercise an opt-out choice if you do not want to receive these communications from us, such as emails or updates from us regarding new services and products offered on the Site. The opt-out choice may be exercised by contacting us via the information contained within section L. We will process your request as soon as possible, but please be aware that in some circumstances you may receive a few more messages until your opt-out request is processed.

Third Party

Web Sites

This statement applies solely to information collected on the Site. The Site may contain links to other web sites. We are not responsible for the privacy practices or the content of these other web sites.

Children

The Site does not knowingly target children under the age of 13 and we do not collect personal information from any child under the age of 13. In the event we learn that such information has been provided to the Site, we will delete or destroy it.

Password

Your account information and access to the protected part of our Site is accessible only through the use of an individual user ID and password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. In addition, always logout and close your browser when you finish your session. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

H. Updating and
Accessing Personal
Information

If your personally identifiable information changes in any way, we invite you to correct or update your information as soon as possible. You can make updates to your profile information by logging into your account on the Site at any time.

Assignment

In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personally identifiable and non-personally identifiable information collected via the Site.

Changes to this

Privacy Policy

We reserve the right to change this privacy policy from time to time. When we do, we will also revise the "last update" date at the bottom of this privacy policy. For changes to this privacy policy that may be materially less restrictive on our use or disclosure of personally identifiable information you have provided to us, we will attempt to notify you.

Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

Once we receive your transmission, we make reasonable efforts to ensure security on our systems. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

Contacting Us

If you have any questions about this privacy policy or our privacy practices, please contact us at:

• By email: Contact Us

• By Phone: (855) 663-6287

All information you provide in any written communication will also be covered by this policy.

Your California

Privacy Rights

Beginning on January 1, 2005, California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please contact us.