Privacy Policy 

Étoile Wellness, LLC


Effective Date: February 14, 2022

Étoile Wellness, LLC (“Étoile Wellness”, "we" or "us") is committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect, use, disclose and protect your Personal Information (as defined in Section 1). It applies to all Personal Information collected and processed by us during your access or use of our website (located at and during your access or use of the products and services that Étoile Wellness may offer from time to time (“Services”).

Unless we define a term in this Policy, all capitalized terms used in this Policy have the meaning provided in our Customer Agreement (“Customer Agreement”), which will be provided to you separately when you register for our Services. You should carefully read and understand the terms of the Customer Agreement before you use our Services. By using our Services, you accept the Customer Agreement and accept our privacy practices described in this Policy. If you do not feel comfortable with any part of this Policy or our Customer Agreement, you must not use or access our Services.

We may modify this Policy from time to time. The date of change will be shown next to “Effective Date” at the top of this page. We encourage you to read this Policy periodically to ensure you have up-to-date knowledge of our privacy practices.

Whenever material changes to this Policy are made, we will provide you with notice before the modifications are effective by sending a message to the email address associated with your account. By continuing to access or use the Services after changes to this Policy become effective, you agree to be bound by the revised Policy. If any changes are unacceptable to you, you may stop using our Services at any time.


We collect Personal Information when you use our Services, create an account with us or submit Personal Information to us. “Personal Information” is any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular individual, including, but not limited to: a first and last name, email address, a home, postal or other physical address, and phone number. The types of Personal Information that we may collect about you are:

         (a) Information You Provide to Us. We collect information you give us when you register with us for a Étoile Wellness account, when you use our Services, when you participate in surveys or promotional activities, or when you otherwise choose to submit your information to us.

                  (i) When you sign up for an Étoile Wellness account, we may collect your name, address, phone number, title, birth date, gender, credit card information, together with other information such as occupation, industry, and personal interests.

                  (ii) When you use our Services, such as logging into your account or speaking with Étoile Wellness staff, we may collect your name, address, birth date, credit card information, etc., to verify your identity and provide Services to you.

                  (iii) From time-to-time, we invite users to volunteer to participate in surveys or promotional activities. When a user participates, we request certain Personal Information such as name and email address. Depending on the nature of the survey or promotional activity, we use this information to facilitate any applicable follow-up communications with the participants.

         (b) Communications from You. When you use our Services (for example on our website), complete electronic forms, or contact us, by online chat, email, phone or text, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request.

         (c) Information Related to Your Use of the Services. We may automatically collect information about your use of the Services ("Usage Data"), including information sent by your mobile devices. For example, we may collect:

                  (i) Device information, such as your hardware model, IP address (the internet address of your computer), unique device identifiers, and other information such as your browser type and operating system.

                  (ii) Website usage information regarding customer traffic patterns and website usage. This may include the web page that you were visiting before accessing our website or mobile application, the pages or features of our website that you browsed to inform us which part of our website and Services you visit and how much time you spend there.

                  (iii) Information about your preferences to make your use of the website more productive through the use of cookies.

         (d) Information Sent by Your Mobile Devices. We collect certain information that your mobile devices send when you use our Services, such as a unique identifier, user settings and the operating system of your device, as well as information about your use of our Services on your mobile device.

         (e) Location Information. When you use our online Services, we may collect and store information about your general location by converting your IP address into a rough geo-location. We may also access your mobile device’s GPS coordinates or course location but only if you have previously agreed that we can collect this information by allowing the sharing of your location information. If you do not want us to have your location information, you may disable the location sharing feature on your device or browser.

         (f) Information From Our Clients and Partners. We may receive your Personal Information from our business clients and partners in connection with one or more business purposes, including making our Services available to you.


We will only use your Personal Information as described in this Policy or otherwise through your informed consent.

         (a) To Provide Our Services to You. We will use your Personal Information to provide information or perform Services that you request. We may use general location information to improve and personalize our Services to you, such as providing location-relevant information and Services to you. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable information to the third party providing the information or performing the applicable Services. Your Personal Information may be available or provided to third-party service providers who are contractually obligated to protect your Personal Information as disclosed in this Policy.

         (b) For Operations and Administration of Our Business. We will use your Personal Information for the purposes of furthering our business, including creating, operating, delivering, maintaining, and improving our content, products, and Services. We may monitor how our users use our Services including, without limitation, time spent using our Services, pages visited and content viewed. Aggregated forms of this data may also be used for research and development purposes to offer new features, functionalities, products and services.

         (c) For Business Analytics Purposes. We analyze, and may engage third parties to analyze, your Personal Information and Usage Data to determine the usefulness of our website and other elements of the Services. Analytics help us determine how effective our navigational structure is in helping users reach the information they seek, completing the task they wish to complete, etc., and to tailor features and functionalities to our users’ needs and preferences.

         (d) For Marketing Purposes. Marketing lets us grow our community and update you about new products and services. We process your contact information or information about your interactions about our Services to: send you marketing communications and keep you updated about our products and Services; provide you with informational content; and deliver targeted marketing materials to you. We may periodically send you free newsletters and emails that directly promote our Services that we believe may be of interest to you. When you receive such promotional communications from us, you will have the opportunity to "opt-out" (either through your account or by following the unsubscribe instructions provided in the email you receive). We do need to send you certain administrative and transactional communications regarding our Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms & Conditions, this Policy, or information about billing and renewals, among others.

         (e) To Provide Customer Support. We collect information that you provide to us when you contact us, such as with questions, concerns, feedback, disputes or issues, so we can address your needs and support your use and enjoyment of the Services.

         (f) For Account and Network Security Purposes. We care about keeping your Personal Information secure and safe while using our Services. Keeping you safe requires us to process your Personal Information, such as your device information, log-in information, activity information and other relevant information to proactively manage privacy and security risks. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.

         (g) For Legal and Regulatory Compliance Purposes. Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we may process your Personal Information to comply with privacy laws, comply with employment laws, or as necessary to manage risk as required under applicable law.

         (h) To Enforce Compliance with Our Terms and Agreements of Policies. When you access or use our Services, you are bound to our Membership Terms and this Policy. To ensure you comply with them, we process your Personal Information to actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services. We also process your Personal Information to investigate, prevent or mitigate violations of our terms, agreements or policies.


Your Personal Information is not shared with third parties without your permission, except as described below.

          (a) Information Shared with Our Employees, Service Providers. We may engage employees and third-party service providers to work with us to administer and provide the Services or to promote our Services. These employees and third-party service providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.

         (b) Information Shared with Our Business Clients. We may share your Personal Information with our business clients for Services provisions and business operations purposes. We may share your Personal Information with our business clients for the purposes of performing Services for these clients in accordance with our contractual obligations, including to make our Services available to you.

         (c) Information Disclosed in Connection with Business Transactions. If we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Policy. Any information you submit or that is collected after a transfer, however, will be subject to a new privacy policy adopted by the successor entity.

         (d) Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials to enforce and comply with the law. We may disclose Personal Information about you to government or law enforcement officials as we, in our sole discretion, believe necessary or appropriate: (i) to enforce our Terms & Conditions; (ii) to respond to claims and legal process (including subpoenas); (iii) to protect the property, rights and safety of a third party, our users, or the public in general; (iv) to protect our property, rights and safety; (v) to stop any activity that we consider fraudulent, illegal, unethical or legally actionable; and (vi) as required by applicable local, state or federal laws.


We safeguard the security of the information you provide to us with physical, electronic, and administrative procedures. For certain features of our Services we use industry-standard SSL-encryption to enhance the security of data transmissions. Your account information is password-protected for your privacy and security. While we strive to protect your Personal Information, we cannot guarantee the security of the internet generally, and cannot ensure the security of the Personal Information that is transmitted through the internet. Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your Personal Information when you are on the internet, or when you communicate with us and with others through the internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Contact Us” section of our website. If your credit information, username, or password is lost, stolen, or used without permission, please promptly notify us and we will assist you in updating your account details. Some portions of the Services (for example our presence on social media) allow users to submit comments, reviews, ratings and other information that may be displayed on the Services and viewed by others. We recommend that you do not post on or through the Services any information that you do not want to make available to other users or the public generally. You assume all responsibility for any loss of privacy or other harm resulting from information you post publicly.


We are committed to protecting the privacy of children in connection with the use of our Services. This section explains our online information collection, disclosure, and parental consent practices with respect to information collection from children under the age of thirteen (13) (Child” or “Children”) in accordance with the U.S. Children’s Online Privacy Protection Act (“COPPA”). Our Services include online Services that may be used to facilitate health care for a Child. Children under the age of eighteen (18) are not eligible to register directly for an account. If your Child directly uses their Étoile Wellness account, either with or without your permission, we may collect information directly from the Child. If you prefer for your Child to not directly interact with Étoile Wellness online, please do not provide account credentials to your Child. Please note certain state patient privacy laws may permit a Child to directly obtain certain types of health care services independent of their parent or guardian.


Our website may contain links to other sites that are owned or operated by third parties. We are not responsible for the content, privacy or security practices of any third parties. To protect your Personal Information, we encourage you to learn about the privacy policies of those third parties.


Étoile Wellness has accounts on social media platforms through which we may post information or conduct promotional activities. If you use social media to follow us or interact with us, we may collect Personal Information you choose to share with us. Please understand that your use of the social media services may result in the collection or sharing of Personal Information about you by those social media services. We have no control over, and decline all responsibility for, the use of your personal data by these third parties. Your use of social media, including your interactions with us on social media, are at your discretion. We encourage you to review the privacy policies and settings on the social media services with which you interact to make sure you understand how your information may be collected, used, and shared by those social media services.


Your Personal Information is stored on controlled servers with limited access and may be stored and processed in the United States or another country where our service providers are located. We offer our Services to individuals located in the United States, and we do not advertise our Services outside the United States. If you are located outside the United States and choose to provide your Personal Information to us, please note that we may transfer your Personal Information to the United States or another country where our service providers are located, and such countries may not provide the same data protection. Those who choose to access and use the Services from outside the United States do so on their own initiative, at their own risk, with this understanding.


We may amend this Policy from time to time and revise the language of the Policy to reflect such changes. If we make a significant or material change in the way we use your personal information, the change will be posted thirty (30) days prior to taking effect.


If you are a California resident, additional California privacy laws may apply to you. and our California Privacy Notice supplement should be read by you. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Law(s)”), California residents have the following rights (“Rights”) listed below. Your Right to Know and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of the business’s systems of networks.

         (a) Right to Know. You have the right to know the Personal Information we collect, use, disclose, and sell about you. You have the right to request in writing from us a copy of the categories of Personal Information we have collected about you, the categories of sources from which we collected that Personal Information, why we collected that Personal Information, the categories of third parties with whom we shared your Personal Information, the categories of Personal Information that we disclosed about you for a business purpose, and the specific pieces of Personal Information we have collected about you. Please note that we are only required to respond twice per calendar year to your Rights to Know.

         (b) Right to Deletion. You have the right to request that we delete any Personal Information we have collected from you or maintain about you. However, we are not required to comply with such requests if it is necessary for us or our partners to maintain the Personal Information in order to:

                  (i) complete the transaction for which the Personal Information was collected; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;

                  (ii) debug to identify and repair errors that impair existing intended functionality; exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

                  (iii) comply with the California Electronic Communications Privacy Act;

                  (iv) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest;

                  (v) comply with a legal obligation; or

                  (vi) use Personal Information internally in a lawful manner that is compatible with the context in which a California resident provided the Personal Information and is reasonably aligned with the expectations of the resident based on the resident’s relationship with the business.

         (c) Right to Opt-Out of the Sale of Your Personal Information. If a business sells your Personal Information, you have the right to opt-out of having your Personal Information sold. We do not sell any of your Personal Information.

         (d) Right to Non-Discrimination. We will not discriminate against those who exercise their Rights. Specifically, if you exercise your Rights, we will not deny you goods or Services, charge you different prices or rates for goods or Services or provide you a different level or quality of goods or Services.

         (e) Asserting Your Rights. You may exercise your right to know by submitting your request by email to [email protected]. If you would like to exercise your right to deletion, please submit your request by email to [email protected]. We may ask you for certain information or require email verification to verify your identity. If we cannot verify your identity from the initial information you provide, we may request additional information from you, which will only be used for the purposes of verifying your identity and for security or fraud- prevention purposes. In some instances, we may ask you to submit a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. We will delete any new Personal Information collected for the purposes of verification as soon as practical after processing your request, subject to legal retention requirements. You may designate an authorized agent to make a request to know or a request to delete. We will respond to your authorized agent’s request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf or submit evidence you have provided them with power of attorney pursuant to the California Probate Code, Section 4000 to 4465.

If you have questions or concerns about this Privacy Policy or our collection, use, or disclosure of your Personal Information, please contact us:

By email: [email protected] 

By mail: Étoile Wellness, LLC, P.O. Box 1232, Sterling, MA 01564

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