Last Updated and Effective Date: October 27, 2023

This Privacy Policy describes how Monte Nido & Affiliates Holdings, LLC and its affiliated companies (“we,” or “us”) uses, discloses, and processes your Personal Information (“you” and “your”). For the purposes of this Privacy Policy, unless otherwise noted, all references to Monte Nido & Affiliates website (the “Site”) include www.montenido.com, www.montenidoaffiliates.com, www.clementineprograms.com, www.rosewoodranch.com, www.waldeneatingdisorders.com and any other websites owned or maintained by us. By using our Site, you consent to the data practices described in this statement. We reserve the right to change this Privacy Policy at any time. If we change our Privacy Policy, we will post an updated version on this website. Please check back periodically to see if our Privacy Policy has been updated. Updates to the Privacy Policy will be referenced by the “Last Updated and Effective Date” date shown above.

1. Definitions.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. “Personal Information” does not include: (i) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (ii) information that is deidentified or aggregate information.

“Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of an mail, email, and text messages unless we are the intended recipient of the communication; (f) genetic data; and (g) information about a known child. Sensitive Personal Information includes the processing of biometric information for the purpose of uniquely identifying an individual, Personal Information collected and analyzed concerning an individual’s mental or physical health and Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information.

2. Information We Collect, the Categories of Source of Collection and the Purpose for Collection.

We do not collect any Personal Information about you unless you voluntarily provide it to us, including when you contact us directly, or as discussed below, with regarding to tracking your behavior on our Site. However, you may be required to provide certain Personal Information to us when you elect to use certain products or services available on the Site. These may include: (a) registering for an account on our Site; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Site. For example, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-Personal Information in the future.

Set forth below are the categories of Personal Information we collect and that have collected in the preceding 12 months, the categories of sources from which the Personal Information was collected and the business or commercial purpose for such collection.

Category of Personal Information	What We Collect	Categories of Sources from which Personal Information Collected	Business or Commercial Purposes for Collection
PERSONAL INFORMATION
Identifiers	Real name Internet protocol address Email address Telephone number Zip code	Directly from you Automatically, such as when you visit our website (e.g., cookies and tracking technologies)*	To provide our Site to you To analyze, administer and improving our Site To enable secure use of our Site To provide you with products and services we offer To inform you of other products or services available from us To send information and promotional materials to you To protect our rights or our property To meet legal obligations For other purposes related to the reasons for which you provide Personal Information
Commercial Information	Records of personal property, products or services purchased, obtained, or considered Other purchasing or consuming histories or tendencies	Directly from you	To provide you with products and services we offer To inform you of other products or services available from us To send information and promotional materials to you To meet legal obligations For other purposes related to the reasons for which you provide Personal Information
Internet Information (including Geolocation Data)	Electronic network activity information Browsing history Search history Information regarding interaction with a website, application, or advertisement Internet protocol address	Automatically	To provide our Site to you To analyze, administer and improving our Site To enable secure use of our Site To analyzing the effectiveness of our Site

* You can read more about these technologies below.

For electronic payments, we use a vendor to process credit card transactions. The credit card information is encrypted and we only have access to the last four digits of your card.

We do not collect any health information from you. However, if you visit our Site or provide us with Personal Information, given the nature of our services, this may indicate to us that you or someone in your household may have a health or medical condition of the type for which we offer services.

We are in possession of de-identified data. We commit to maintain and use such data without attempting to re-identify the data.

3. Cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or of the service we provide as some of our features or services may not function properly without cookies.

We use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
Third party cookies. These cookies are placed on your device by a website from a domain other than our website. Please note that various third parties may also use these types of cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies.

If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

In addition, we use web beacons and pixels, which are images that can be placed in web pages and some forms of email. These technologies can be used to deliver cookies and to collect information about your use of the site. Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel. We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our Sites. Other entities may have access to some of this information.

By using your website and services you affirmatively agree to the use of cookies disclosed in this Privacy Policy.

4. Personal Information We Sell, Share for Targeted Advertising or Disclose and the Purpose for It.

We do not sell Personal Information we have collected from you as that term is commonly understood (i.e., sale of data in exchange for money). However, our practices may constitute a sale under the definition of sale under certain laws. As used herein, definition of sale includes situations where another company can use your Personal Information for its own purposes. Moreover, certain individuals in our group of companies, subsidiaries and affiliates may have access to your Personal Information for various purposes because we use a unified database for various purposes, which can be considered a sale.

Except for the unified data for our group of companies, the chart below shows the categories of Personal Information we sell (as defined above) or share for cross-context behavioral advertising (targeted advertising) or that we have sold (as defined above) or shared for cross-context behavioral advertising (targeted advertising) in the past 12 months, the categories of third parties to whom we have sold shared for cross-context behavioral advertising (targeted advertising) Personal Information and the business purpose for the foregoing.

Categories of Personal Information that We Have Sold or Shared in the Past 12 Months

Categories of Third Parties to Whom We Have Sold or Shared Personal Information

Business Purposes for Sale or Sharing of Personal Information

PERSONAL INFORMATION

Internet Information (Including Geolocation Data)

Data analytics providers like Google Analytics

Third party advertising partners

Third parties for marketing purposes

To Track of the pages you visit

To help us better understand the features of the Site that you and other users are most interested

To determine the popularity of our services

To deliver customized content and advertising

To assist with analyzing our website traffic

To enhance your experience through personalization

To do marketing

Third Party Advertising. We use third party advertising companies to place ads on other sites. We do this by allowing our advertising and social media partners to place their cookies on a browser of an individual who visits our sites and accepts the use of cookies. The data received by our third party advertising and social media partners allows them to measure the effectiveness of such advertising and to provide advertisements on other websites about our services which are tailored to your interests. This too may be considered a sale.

Tracking Technologies.

We may keep track of the websites and pages our users visit in order to determine what our services are the most popular. This data is used to deliver customized content and advertising within our companies to customers whose behavior indicates that they are interested in a particular subject area. To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services, including Google Analytics. For more information on Google Analytics’ processing of your information, please see “How Google uses data when you use our partners’ sites or apps” here: https://policies.google.com/technologies/partner-sites?hl=en-US. You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here: https://tools.google.com/dlpage/gaoptout.

When you use or access the Site, we and our partners use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Site. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.

Some browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

Some of our partners may use cookies or other methods to gather information regarding your use of the Site, and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy policy of that third party.

When you use our Site, our servers automatically record information, including your Internet.

Under California law, the disclosure of data received by our third-party partners, including the foregoing practices, may be considered a sale of Personal Information.

In addition, we disclose and have disclosed in the preceding 12 months Personal Information to our service providers and contractors for the following business purposes.

Auditing of Ad Impression: We disclose Personal Information for auditing purposes related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Services on Our Behalf: We disclose Personal Information in order to receive services performed on our behalf, including maintaining or servicing accounts, providing customer service, verifying customer information, processing payments through a third-party billing provider, providing analytic services, providing storage, or providing similar services on our behalf.

Moreover, starting on or about January 2024, we may disclose Personal Information to our service providers for the following purposes.

Security and Fraud Detection: We disclose Personal Information for our security and fraud detection services including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
Functionality & Debugging: We disclose Personal Information to engage in debugging to identify and repair errors that impair existing intended functionality.

The following chart sets forth the categories of Personal Information we have disclosed to our service providers for a business purpose over the past 12 months.

Categories of Personal Information that We Disclose	Business Purposes for the Disclosure of Personal Information
PERSONAL INFORMATION
Identifiers	Auditing of Ad Impression Services on Our Behalf Security and Fraud Detection (starting on or about January 2024) Functionality & Debugging (starting on or about January 2024)
Commercial Information	Auditing of Ad Impression Services on Our Behalf Security and Fraud Detection (starting on or about January 2024) Functionality & Debugging (starting on or about January 2024)
Internet Information (Including Geolocation Data)	Auditing of Ad Impression Services on Our Behalf Security and Fraud Detection (starting on or about January 2024) Functionality & Debugging (starting on or about January 2024)

As Necessary: We may also disclose Personal Information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We only use Sensitive Personal Information for purposes disclosed herein. We do not use or disclose Sensitive Personal Information for purposes other than those specified herein.

5. Security of Your Personal Information.

We protect the confidentiality and security of information we obtain in the course of business. We use commercially reasonable safeguards, such as industry-standard encryption technology, to help keep the information collected through the Site secure. When Personal Information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your Personal Information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed. We do not represent or warrant that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

6. Our Retention Policy – How Long We Keep Your Personal Information.

We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Children.

We do not direct our websites or applications to children under thirteen (13) years of age. We do not knowingly collect information from persons under 13 years of age or provide any Personal Information from such persons to any third party for any reason whatsoever. No information should be submitted to our websites or applications by persons under 13 years of age. When appropriate, we may ask you to indicate your date of birth to verify compliance with the age requirements set forth herein.

8. E-mail Communications.

From time to time, we may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our services, we may receive a notification when you open an email from us or click on a link therein. If you would like to stop receiving marketing or promotional communications via email from us, you may opt out of such communications by clicking the unsubscribe button on emails.

9. Other Websites, Including Social Media

We are not responsible for the practices employed by any websites or services linked to or from our Site, including the information or content contained within them. A link to a third party’s website should not be construed as an endorsement. We encourage you to investigate and ask questions before disclosing Personal Information to third parties.

10. Your Rights if You Are a Resident of California.

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2023, and related regulations. Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting, selling, or sharing Personal Information; (4) the categories of third parties to whom we disclose Personal Information; and (5) the specific pieces of Personal Information we have collected about you. You also have the right to know the list of all third parties to whom we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes. You may submit a request by calling us at 855-204-5509 or emailing us at privacy@montenidoaffiliates.com.
Right to Know Personal Information Disclosed, Sold or Shared and to Whom. You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; (2) the categories of Personal Information that we sold or shared about you and the categories of third parties to whom the Personal Information was sold or shared, by category or categories of Personal Information for each category of third parties to whom the Personal Information was sold or shared; and (3) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. You may submit a request by calling us at 855-204-5509 or emailing us at privacy@montenidoaffiliates.com.
Right to Request Deletion of Your Personal Information. You have the right to request that we delete your Personal Information, subject to a number of exceptions. Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records. If we cannot delete all of your Personal Information, we will let you know the reason. You may submit a request by calling us at 855-204-5509 or emailing us at privacy@montenidoaffiliates.com.
Right to Correct Inaccurate Information. If you believe that any of the Personal Information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct. You may submit a request by calling us at 855-204-5509 or emailing us at privacy@montenidoaffiliates.com.
Right to Opt-Out of the Sale and Sharing of Your Personal Information. You may opt-out of the sale or sharing of your Personal Information, to the extent appliable, by clicking here: https://clementineprograms.com/privacy-opt-out/. Please note that if you use different devices, and you exercise this right on one device, we may not have the ability to track you amongst other devices. As such, if you want to exercise this right, please do it on all of your devices.
Right to Limit the Use of Your Sensitive Personal Information. You have the right to limit the use of Sensitive Personal Information under circumstances. However, since we don’t collect any Sensitive Personal Information, this right does not apply to you.
Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.

When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:

Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
- For requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
- For requests to know specific pieces of Personal Information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records.
- For requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.

If there is no reasonable method by which we can verify your identity, we will state so in response to a request to know or delete Personal Information, including an explanation of why we have no reasonable method to verify your identity.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.

We will respond to requests to know, requests to delete and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

Regarding your rights to opt-out of the sale and sharing of Personal Information and to limit the use of your Personal Information, in addition to the links above, you can also exercise your right to opt-out by using a browser that supports an opt-out preference signal (also known as a Global Privacy Control (GPC)). If you choose to use this signal, you will need to turn it on for each browser you use.

11. Your Rights If You Are a Resident of Any State Other than California.

If you are a resident of any state other than California you may have the rights set forth below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

The Right to Know. You have the right to know whether we are processing your personal information.
The Right of Access. You have the right to access your Personal Information, and to obtain a copy of it in a readily usable format, if feasible.
The Right to Correct Inaccuracies. You may request that inaccuracies in your Personal Information be corrected.
The Right to Delete. You have the right to request that your Personal Information be deleted, except in cases where retention is required by law or contractual obligation.
The Right to Data Portability. You have the right to obtain a copy of your Personal Information in a portable and, if feasible, readily usable format.
The Right to Opt-Out. You may elect to prevent your Personal Information from being:
1. Used in targeted advertising;
2. Sold; or
3. Used for profiling purposes that may produce legal or similarly significant effects.
The Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.
Rights Regarding Sensitive Personal Information. Since we don’t collect any Sensitive Personal Information, this right does not apply to you.

Furthermore, if we have actual knowledge that you are 13 years of age and not older than 16 years of age, we will not without your consent process your Personal Information for the purposes of targeted advertising, profiling in furtherance of decisions that produce legal effects or effects of similar significance or selling your Personal Information.

You may submit a request via email to privacy@montenidoaffiliates.com or by calling us at 855-204-5509. When you make a request, to help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:

Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.
Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity to a reasonable degree of certainty by matching at two or three data points provided by you with reliable data points maintained by us. For valid requests to delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.

We may also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records.

If there is no reasonable method by which we can verify your identity, we will state so in response, including an explanation of why we have no reasonable method to verify your identity.

There may be situations where we cannot grant your request. For example, if you ask us to delete Personal Information that we are obligated to keep to comply with applicable law we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your Personal Information serves a legitimate purpose such as for security purposes. Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.

Information requests under “Right of Access” and “Right to Data Portability” will be transmitted securely. If we cannot fulfill your request, we will notify you of that decision and the reasons why within 45 days. At that point if you believe our decision was in error, you may have the right to submit an appeal using the method(s) above. If the result is the same, you can also seek assistance and/or redress from your state attorney general.

12. Nevada Privacy Notice.

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your Personal Information are not sales under Nevada law, so no opt-out is required.

13. Changes to this Privacy Policy.

We reserve the right to change this Privacy Policy from time to time. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

14. How to Contact Us.

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us as follows:

Monte Nido & Affiliates Holdings, LLC
6100 SW 76th Street
Miami, Florida 33143
Email: privacy@montenidoaffiliates.com
Telephone: 855-204-5509