Privacy Policy: Revised 01/12/2025

Dr. Lé Santha and Avyanna Wellness Institute values your trust, and protecting your information is a high priority. We are committed to your privacy. This Privacy Policy explains what information Dr. Naidoo and Avyanna Wellness Institute (collectively, “100 Club" or “we”) collect, how information that identifies or may reasonably identify you (“Personal Information”) is collected, how we use that Personal Information, what Personal Information is shared with whom, and how Dr. Naidoo and Avyanna Wellness institute protects your Personal Information when you use our non-clinical products and services, including our website and certain uses of any related health platform, independent of receiving clinical healthcare services (collectively, the “Services”).

This Privacy Policy applies to our services, websites and mobile applications that are separate or independent of any healthcare clinical services our partners provide to you, including through your purchase of Avyanna Wellness or 100 club care. For clarity, this Privacy Policy will apply to your purchase of the Avyanna wellness and 100 club concierge plans, and your general use of our website.
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This Privacy Policy does not apply to: (1) our collection, use, or disclosure of HIPAA protected health information from the Avyanna Wellness institute service or any other healthcare clinical service, (2) other services that have separate privacy policies that do not incorporate this Privacy Policy, and (3) to services offered by other companies
or individuals, including products or sites that may be displayed to you in search results, sites that may include Services, or other sites linked from our Services.
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Additionally, our Services is only intended for use within the United States. This includes your enrollment in the Avyanna Wellness Institute Memberships. Our Privacy Policy also does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
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Once you register to receive clinical healthcare services with us, any individually-identifiable health information will be governed by the healthcare providers’ Notice of Privacy Practices for protected health information or “PHI.” If you are registered to receive such services, including through Avyanna Wellness Institute, you acknowledge that
you have read and understood the Notice of Privacy Practices.
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By using our Services, you affirm that you have read this Privacy Policy and our Website Terms of Use and that you understand, agree to be bound by, and acknowledge all the terms contained herein. If you do not agree to be bound by the terms of this Privacy Policy, our Website Terms of Use, our affiliated providers’ Notice of Privacy Practices, and the applicable Terms of Service, you should discontinue your use of the Services.

This Privacy Policy does not apply to our collection and use of your PHI.
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For your information only, as part of providing certain healthcare services, we may collect certain PHI from patients, which is governed by the Health Insurance Portability and Accountability Act or “HIPAA”. Specifically, we may act as a business associate (as defined by HIPAA) when we (1) provide certain management services to a healthcare provider, and the healthcare provider is a covered entity as defined by HIPAA, and (2) receive PHI about a patient on behalf of a healthcare provider. The collection, use, and disclosure of such PHI is done in accordance with the healthcare provider’s Notice of Privacy Practices. A copy of such notices for the healthcare providers that we manage is available here.

However, this Privacy Policy applies to only certain Personal Information that we collect about you as a user when we are not acting as a business associate under HIPAA. As described in more detail below, this might include Personal Information such as your device ID or IP address, collected as a result of your use of the Services.

We collect the following Personal Information about you:

• Information You Submit. When you fill out our online contact form to schedule a call about our Services, you provide to us your name and email address. You may also sign up to our email alerts by providing your email address. We also collect the visible Personal Information about you when you interact with
  our social media pages or participate in our promotion campaigns. If you have signed up for the Avyanna Wellness Institute Programs we may collect information you submit about yourself, including your
  enrollment information.
• Information from Third Parties. We may receive personal information, including contact information, about you from third party partners if you've signed up through a third party.
• Geolocation. We automatically collect your geolocation when you use the Services. This is information that identifies your specific location.
• Technological Information. We automatically collect your IP address, unique online identifier, device ID and/or hardware model, mobile operating system, and Wi-Fi or mobile network. We use this for a number of reasons, including tracking how you engage with our Services, including the Avyanna Wellness Institute programs, and monitoring user traffic on our Services to ensure the security and integrity of our systems.
• Internet Activity.  This includes browsing history, search history, and information regarding your interactions with other applications, advertisements, or websites (including the websites you came from before you visited our website and the website you visit when you leave our website). This information is collected via cookies and pixels. We use this information to serve you with tailored advertising content.For more information about our advertising practices, which includes targeted advertising, please see the sections below.

We use your Personal Information that we collect through the Services, including from Avyanna Wellness Institute, in the following circumstances:
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• To Operate and Maintain the Services. This includes fulfilling your requests. For the Avyanna Wellness Institute Programs, this includes providing feedback and instruction.
• To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Privacy Policy. This also includes responding to your feedback, requests for quotes, or requests for more information. For the Avyanna Wellness Institute Programs, this includes our general interaction with you on the program and your progress.
• To Improve Our Services. We may use your Personal Information to make our Services better. We may also use your Personal Information to customize your experience with us.
• To Understand Your Interests. For example, we may use your Personal Information to better understand what features in our Services interest you.
• For Online Marketing Purposes, including Targeted Advertising. We might use your Personal Information to serve you ads, emails, or other content about our products and Services, including new features or Services that we develop in the future. These might be third party offers for tools, products, or services
  that we think you might find interesting. We and our partners may engage in interest-based advertising, or targeted advertising, using data and Personal Information gathered across multiple websites, devices, or other platforms. These practices may be considered a “sale” of Personal Information under some state laws. For more information about your choices related to these communications, see Choices Regarding Your Information below.
• To Send Promotional Communications to You. This includes surveys, promotions, and marketing emails.
• For Security Purposes. This includes protecting us and the consumers who use our Services. It may also include protecting our Services, including this website and the Avyanna Wellness Institute Programs
• As Otherwise Permitted By Law or As We May Notify You.

We may share your Personal Information in the following ways:
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• On our Website, Platform or Social Media Pages. For example, we may display or repost Personal Information that you post in our social media forums.
• With Our Service Providers. We may share your Personal Information with third parties who perform services on our behalf. For example, this may include payment processors and companies that send emails on our behalf or other operating systems or platforms that help us run our Services. For the Avyanna Wellness Institute Programs, this would include the platform you use to interact with us.
• With Data Analytics Providers for Targeted Advertising. Third-party data analytics providers may collect Personal Information about users over time and across different websites, applications, and devices for the purposes of targeted advertising. Third-party data analytics providers may also collect Personal
  Information in this way on our website. These practices may be considered a “sale” of Personal Information under some state laws. For more information about your choices related to these communications, see Choices Regarding Your Information.
• With Our Business Partners. For example, this may include a company that co-sponsors a promotion. For the Avyanna Wellness Institute Programs, this may include our accreditation agency.
• With Any Successors to All or Part of Our Business or One of Our Brands. For example, if we assess or actually merge with, acquire or are acquired by, or sell a brand or part of its business to another business entity. This may include an asset sale, corporate reorganization, or other change of control, potentially
  involving the bankruptcy process. We may transfer our customer information, which may include your Personal Information, as part of such a transaction or as a stand-alone asset. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy
  Policy, under the circumstances described in this paragraph.
• To Comply with the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing Personal Information if requested by a government agency or investigatory body. We might share Personal Information within the context of protecting or assessing our own legal rights, such as with third-party accountants or outside legal counsel. We might share Personal Information in order to protect the rights, privacy, safety, or property of ourselves, our employees and personnel associated with us, our business partners, or you.

You have certain choices about how we use your Personal Information. Certain choices you make are specific to your browser and/or device.
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Marketing Communications:
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You can opt-out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries. To opt-out of receiving our marketing communications, you can follow the instructions included with the communication.
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Cookies & Other Tracking Technologies:
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Cookies are small text files that websites place on your device as you are browsing, which are stored by your web browser. By storing data, cookies serve crucial functions for websites. If you prefer not to share data, you can disable them. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
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Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. If you do not want information, which may include Personal Information, collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a website. To learn more about cookies and how to manage them, you may find the following link helpful: aboutcookies.org/how-to-control-cookies.

You may have the following rights (“Data Subject Rights”) in relation to the Personal Information that we collect or process about you, including as it relates to your enrollment in the Avyanna Wellness Institute Programs. These rights differ depending on where you live, but we will endeavor to respect these rights regardless of your country or state of residence. Please note that we reserve the right to honor your Data Subject Rights as required by applicable law.

• Right to Access and Obtain a Copy: If you ask us, we may confirm whether we are processing your Personal Information and, if so, provide you with a copy of all Personal Information you are lawfully entitled to receive along with certain other details. In addition, you may request to know the types of third parties with whom we share your Personal Information, and the categories of Personal Information
  we share with them.
• Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you may request that we correct or complete it. If you ask us, and where possible and lawful to do so, we may tell you with whom we shared your Personal Information so you can contact them directly.
  
• Right to Delete: You may request that we delete or remove your Personal Information. If we shared your Personal Information with others, we will tell them about the erasure as required by law.
• Right to Restrict Processing: You may ask us to restrict or “block” the processing of your Personal Information in certain circumstances, such if we process Personal Information that is considered “sensitive” under applicable state laws or engage in automated decision-making.
• Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored advertisements based your Personal Information gathered across other businesses, websites, applications, or services. You may request that we opt out of this practice.
• Right to Non-discrimination: We will not discriminate against you for exercising these rights, but we may charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copiesof your Personal Information.

If you or your authorized agent wish to exercise any of these Data Subject Rights, including for your enrollment in the Avyanna Wellness Institute Programs, please contact us using the information provided in How To Contact Us.

Before responding to your request to exercise Data Subject Rights, we may require additional information (potentially including Personal Information) from you to verify your identity or clarify your specific request. We will try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where appropriate, we will work with third parties in order to fulfill your request.

We have enabled reasonable administrative, physical, and technical safeguards for the protection of the Personal Information in our custody or control. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. 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 has been compromised), please immediately notify us in accordance with How To Contact Us.
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As our operations are conducted from the United States, all Personal Information that we collect is used and stored in the US, is subject to US laws, and may be subject to disclosure to US governments, courts, law enforcement, or regulatory agencies pursuant to those laws. If you are using our Services, including accessing this website, from or in another country, please note that your Personal Information will be transmitted to our servers
in the US as necessary to provide you with the information that you requested, administer our Services to you, or as otherwise disclosed in this Privacy Policy.

This Privacy Policy does not address, and we are not responsible for, the privacy or other information practices of any third parties, including any third party operating any site or service to which the Service links. The inclusion of a link on the Service does not imply endorsement of the linked site or service by us. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Services.

If you have any questions, comments, or concerns with respect to our privacy practices or this Policy, wish to update your information, or would like to exercise your Data Subject Rights, please feel free to contact us at dr@lesantha.com
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You may also write to us at the following address:
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Avyanna Wellness Institute PLLC

4255 Bryant Irvin Rd, Suite 108

Fort Worth TX 76109
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If you disagree with our determination regarding your Data Subject Rights, you may appeal the decision by contacting us at dr@lesantha.com . Please include confirmation of your original decision in the email.

From time to time, we may change our Privacy Policy and your continued use of the Services indicates your consent to the changes. In any case we will endeavor to notify you of any material changes to our Privacy Policy, as required by law. This Privacy Policy is current as of the “last revised” date which appears at the top of this page.