Privacy Policy Siberian Wellness LLC

Effective Date: 2026.01.2026

  1. Introduction
    This Privacy Policy describes how Siberian Wellness LLC, a Delaware limited liability company (“Company,” “we,” “us,” or “our”), collects, uses, discloses, and safeguards personal information in connection with the website located at us.siberianwellness.com (the “Website”), including when users create accounts, purchase products, or participate in the Company’s Consultant program.
    By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy.
    This Privacy Policy is intended to serve as a “Notice at Collection” for purposes of applicable privacy laws, including the California Consumer Privacy Act (CCPA) as amended, and describes the categories of personal information collected and the purposes for which such information is used.
    This Privacy Policy is incorporated by reference into, and forms part of, the Company’s Terms of Use, Consultant Agreement, and Refund Policy, where applicable.
    This Privacy Policy is designed to comply with applicable U.S. laws, including those of the State of Delaware, as well as other applicable consumer privacy laws based on user location.
  2. Scope and Application
    This Privacy Policy applies to personal information collected:
    • through the Website;
    • in connection with customer purchases;
    • in connection with Consultant accounts and participation in the Company’s network marketing program; and
    • through communications with the Company.
  3. Categories of Personal Information Collected
    We may collect the following categories of personal information:
    3.1 Contact Information
    • Name
    • Email address
    • Phone number
    • Billing address
    • Shipping address
    3.2 Account Information
    • Username (email)
    • Password (stored securely)
    • Account preferences
    • Sponsor / Mentor / Referral ID
    3.3 Payment Information
    Payment information is processed by third-party payment processors (such as Stripe).
    We may collect:
    • payment tokens;
    • billing history.
    We do not store full credit card numbers on our systems.
    3.4 Transaction Information
    • Purchase history
    • Order details
    • Shipping information
    3.5 Technical and Device Information
    • IP address
    • Device type
    • Browser type
    • Operating system
    3.6 Usage and Marketing Data
    • Website usage activity
    • Pages visited
    • Referral sources
    • Marketing preferences
    3.7 User Research and Feedback Data
    • Responses to surveys and questionnaires (including on-site surveys and surveys conducted via email, SMS, or similar channels)
    • Feedback provided through forms, pop-ups, or other user input tools
    • Participation in interviews or usability testing sessions
    • Where applicable, audio, video, or screen recordings of such sessions (collected with user consent)
  4. Summary of Data Collection and Use
    The table below provides a high-level overview of the categories of personal information we collect, sources, and purposes of use:

    Category of Personal Information
    Sources
    Business or Commercial Purpose
    Identifiers (e.g., name, email, IP address) Directly from users; Website interactions Account creation, order processing, communication
    Customer Records (e.g., billing/shipping info) Provided by users Transaction processing and fulfillment
    Commercial Information (e.g., purchase history) User transactions Order fulfillment, analytics, Consultant compensation
    Internet Activity (e.g., browsing behavior) Cookies, analytics tools Website improvement, analytics, marketing
    Geolocation (approximate) Derived from IP address Security, fraud prevention, localization
    Inferences (preferences, interests) Derived from usage and transactions Personalization, marketing

  5. Categories of Personal Information (California Notice at Collection)
    For purposes of applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), we collect the following categories of personal information:
    • Identifiers (e.g., name, email address, IP address)
    • Customer records information (e.g., billing and shipping address)
    • Commercial information (e.g., purchase history, order details)
    • Internet or network activity information (e.g., browsing activity, interactions with the Website)
    • Geolocation data (approximate location derived from IP address)
    • Professional or employment-related information (if applicable to Consultants)
    • Inferences drawn from the above information (e.g., preferences, interests, or purchasing behavior)
    We collect these categories for the business and commercial purposes described in this Privacy Policy.
  6. Sensitive and Health-Related Information
    The Company sells dietary supplements and related products; however, the Company does not collect or process medical records or health-related personal information.
    For purposes of applicable privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), the Company does not knowingly collect or process “sensitive personal information” (as defined under such laws), except for limited information that may be considered sensitive by inference or technical operation, such as:
    • approximate geolocation data derived from IP address; and
    • account credentials used for authentication.
    Such information is used solely for legitimate business purposes, including security, account access, and Website functionality, and is not used to infer characteristics or for independent profiling purposes.
    The Company does not use or disclose sensitive personal information for purposes that would require offering a “right to limit” under applicable law.
  7. Purposes of Processing
    We collect and process personal information only to the extent reasonably necessary and proportionate to achieve the purposes described in this Privacy Policy.
    We use personal information for the following purposes:
    (a) Transaction Processing and Fulfillment
    To process payments, fulfill orders, manage shipping and delivery, and maintain transaction records.
    (b) Account Management
    To create, maintain, and administer user and Consultant accounts, including authentication and account preferences.
    (c) Consultant Program Administration
    To manage the Company’s Consultant network, including tracking referrals, sponsor relationships, commissions, and performance metrics.
    (d) Customer Support
    To respond to inquiries, provide assistance, and resolve issues.
    (e) Website Operation and Improvement
    To operate, maintain, analyze, and improve the Website and user experience.
    (f) Marketing and Communications
    To send transactional messages, promotional communications, and marketing materials, subject to user preferences and applicable law.
    (g) Legal and Regulatory Compliance
    To comply with applicable laws, regulations, legal processes, and internal policies.
    (h) Security and Fraud Prevention
    To detect, prevent, and respond to fraud, unauthorized activity, or security incidents.
    (i) User Research and Product Improvement
    To conduct surveys, collect feedback, and perform user research activities, including on-site surveys, surveys conducted via email, SMS, or similar channels, and participation in interviews or usability testing sessions. Participation in such activities is voluntary. Where applicable, these activities may involve audio, video, or screen recording, which will only be conducted with the participant’s consent.
    All processing of personal information is limited to what is reasonably necessary and proportionate in relation to the purposes for which it is collected.
  8. Cookies, Tracking Technologies, and Advertising
    We use cookies and similar technologies to operate, improve, and analyze the Website, and to support marketing and advertising activities.
    8.1 Types of Cookies and Technologies
    We may use the following categories of cookies and tracking technologies:
    (a) Essential Cookies
    These cookies are necessary for the Website to function properly, including authentication, security, and session management. These cookies cannot be disabled through our systems.
    (b) Functional Cookies
    These cookies enable the Website to remember user preferences and settings and enhance functionality.
    (c) Analytics Cookies
    These cookies collect information about how users interact with the Website, including pages visited and traffic sources, to improve performance and user experience.
    (d) Advertising and Marketing Cookies
    These cookies may be used to deliver relevant advertising, measure campaign effectiveness, and track interactions across websites or services.
    8.2 Third-Party Tools and Services
    We may use third-party tools and services, which may set cookies or similar technologies, including:
    • analytics and performance monitoring platforms (such as DataGo);
    • website functionality and optimization tools; and
    • other service providers that assist in operating and improving the Website.
    These third parties may collect information about your interactions with the Website and, in some cases, across other websites or services.
    8.3 Targeted Advertising and Profiling
    To the extent that we use advertising or analytics tools that enable cross-context behavioral advertising or profiling:
    • personal information may be used to infer user preferences and interests; and
    • such information may be used to deliver targeted advertising or marketing communications.
    Under certain laws, including the CCPA/CPRA, this activity may be considered “sharing” of personal information.
    8.4 Consent and Control
    Where required by applicable law, we will obtain user consent for the use of non-essential cookies (including analytics and marketing cookies) through a cookie banner or similar mechanism.
    Users may:
    • manage cookie preferences through browser settings;
    • disable or delete cookies; and
    • adjust preferences through any cookie consent tools made available on the Website.
    Disabling certain cookies may affect Website functionality.
    8.5 Opt-Out Rights and Preference Signals
    Users may have the right to opt out of certain tracking or advertising activities, including, where applicable, the “sale” or “sharing” of personal information (as defined under applicable law).
    At this time, users may exercise such rights by:
    • adjusting cookie settings through their browser preferences; and
    • submitting a request to the Company using the contact details provided in this Privacy Policy.
    The Company will process such requests in accordance with applicable law.
    8.6 Do Not Track Signals
    Some browsers transmit “Do Not Track” signals. At this time, there is no universally accepted standard for responding to such signals. The Website does not respond to “Do Not Track” signals or similar browser-based mechanisms.
    8.7 Cookie Banner
    Where required by applicable law, the Website may display a cookie consent banner or similar interface that allows users to accept or reject the use of non-essential cookies.
  9. Disclosure of Personal Information
    We do not sell personal information to data brokers.
    We do not sell personal information for monetary consideration. However, certain disclosures of personal information for advertising or analytics purposes may be considered “sharing” under applicable law.
    We may disclose personal information as follows:
    9.1 Service Providers
    We may share personal information with third-party service providers that perform services on our behalf, including:
    • payment processors;
    • shipping providers;
    • email and marketing platforms;
    • analytics providers;
    • customer support platforms; and
    • survey, feedback, and user research platforms (including tools used for interviews, usability testing, or recordings).
    Such parties are authorized to use personal information only as necessary to provide services to us.
    In the preceding twelve (12) months, we have disclosed the following categories of personal information to service providers and contractors for business purposes:
    • Identifiers (e.g., name, email address, IP address);
    • Customer records information (e.g., billing and shipping information);
    • Commercial information (e.g., purchase history and order details);
    • Internet or network activity information (e.g., browsing activity and interactions with the Website); and
    • Geolocation data (approximate location derived from IP address).
    9.2 Consultant Network (MLM Structure)
    As part of the Company’s network marketing structure, certain personal information may be made available to Consultants within a user’s referral or sponsorship network (“upline”), including:
    • name;
    • limited contact information (where appropriate);
    • order activity and purchase volume; and
    • referral and network relationship data.
    Such information is disclosed solely for legitimate business purposes, including:
    • commission calculation;
    • network structure management; and
    • performance tracking within the Consultant program.
    The Company limits such disclosures to the minimum information reasonably necessary for these purposes and does not provide full access to all customer data.
    Consultants who receive such information are contractually required to:
    • use it only for Company-related business purposes;
    • maintain its confidentiality and security; and
    • comply with this Privacy Policy and all applicable data protection laws.
    The Company reserves the right to monitor, audit, restrict, or revoke access to such information where it determines, in its reasonable discretion, that use of the information is inconsistent with this Privacy Policy, or applicable law.
    For purposes of applicable privacy laws, including the California Consumer Privacy Act (CCPA) as amended, such disclosures are made for business purposes and are not considered a “sale” of personal information.
    9.3 Legal and Compliance
    We may disclose personal information:
    • to comply with applicable law;
    • in response to lawful requests;
    • to protect the rights, property, or safety of the Company, users, or others; and
    • in connection with a corporate transaction (e.g., merger, sale).
  10. Data Retention
    We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide services, maintain accounts, and support the Consultant program.
    We may also retain personal information as necessary to:
    • comply with legal, tax, accounting, and regulatory requirements;
    • resolve disputes;
    • enforce agreements; and
    • maintain appropriate business and financial records.
    Where personal information is no longer required for these purposes, we will take reasonable steps to delete, anonymize, or de-identify such information, unless continued retention is required or permitted by applicable law.
    For example, certain financial and transaction records may be retained for periods required under applicable tax or accounting laws (which may be up to seven (7) years or longer, depending on the jurisdiction), while account-related data may be retained for the duration of the account relationship and a reasonable period thereafter.
  11. Your Rights
    Depending on your jurisdiction, you may have rights regarding your personal information. Depending on your U.S. state of residence, including California, Delaware, Indiana, Kentucky, Rhode Island, and others, you may have additional rights under applicable privacy laws. This section applies to users in the United States, including California, Delaware, and other states with applicable privacy laws.
    Residents of Delaware and other states with comprehensive privacy laws have similar rights to access, correct, delete, and opt out of certain processing (including targeted advertising), which may be exercised through the same mechanisms described above.
    11.1 General Rights
    You may have the right to:
    • request access to personal information;
    • request correction of inaccurate data;
    • request deletion of personal information;
    • object to or restrict certain processing activities.
    11.2 California Privacy Rights (CCPA/CPRA)
    If you are a California resident, you may have the right to:
    • request disclosure of categories and specific pieces of personal information collected;
    • request deletion of personal information;
    • request correction of inaccurate personal information;
    • opt out of the “sale” or “sharing” of personal information (as defined by law); and
    • limit the use of certain sensitive personal information (if applicable).
    The Company does not sell personal information in the traditional sense.
    You have the right to opt out of the “sale” or “sharing” of your personal information, including for cross-context behavioral advertising.
    You may exercise your right to opt out of the “sale” or “sharing” of personal information by submitting a request to the Company using the contact details provided below.
    Requests may be submitted via:
    📧 call-centre@sibvaleo.com
    11.3 Verification
    We may take reasonable steps to verify your identity before fulfilling requests.
    The Company will not discriminate against you for exercising any of your rights under applicable privacy laws, including by denying services, charging different prices, or providing a different level or quality of service, except as permitted by law.
  12. International Data Transfers
    Personal information may be transferred to and processed in jurisdictions outside the United States, including by affiliated entities and service providers involved in:
    • Website operations;
    • customer relationship management (CRM);
    • Consultant network administration; and
    • payment processing and technical infrastructure.
    These jurisdictions may have data protection laws that differ from those in your place of residence.
    Where required by applicable law, the Company implements appropriate safeguards for cross-border data transfers, which may include:
    • entering into contractual protections with service providers;
    • reliance on standard contractual clauses or similar mechanisms; or
    • other legally recognized transfer safeguards.
    By using the Website and providing personal information, you acknowledge that your information may be transferred and processed in accordance with this Privacy Policy.
  13. Data Security
    We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. These safeguards include:
    • encryption (including SSL/TLS);
    • PCI-compliant payment processing;
    • access controls and authentication measures; and
    • secure password storage.
    However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
    In the event of a data breach or unauthorized access to personal information, the Company will take appropriate steps to investigate, mitigate, and remediate the issue.
    Where required by applicable law, including applicable U.S. state data breach notification laws (such as those in Delaware and California), the Company will provide notice to affected individuals and/or regulatory authorities in accordance with such laws.
  14. Children’s Privacy
    The Website is not intended for children under 13 years of age, and we do not knowingly collect personal information from children.
  15. Changes to This Privacy Policy
    We may update this Privacy Policy from time to time. Updated versions will be posted on the Website and will become effective as of the revised effective date.
    Where changes are material, we may provide additional notice, including by email (if an email address is associated with your account) or by a prominent notice on the Website.
    Continued use of the Website following such updates constitutes acknowledgment of the updated Privacy Policy.
  16. Data Protection Assessments
    Where required by applicable law, including state privacy laws that mandate assessments of certain processing activities, the Company conducts data protection assessments for processing activities that present a heightened risk to consumers, such as targeted advertising, profiling, or activities that may constitute the “sale” or “sharing” of personal information.
    Such assessments are performed in accordance with applicable legal requirements and are designed to evaluate and mitigate potential risks to consumers associated with such processing activities.
  17. Financial Incentives
    The Company does not offer financial incentives, price differences, or service differences in exchange for the collection, retention, or use of personal information at this time.
  18. Contact Information
    Siberian Wellness LLC
    16192 Coastal Highway Lewes, Delaware 19958
    Email: call-centre@sibvaleo.com