Privacy Policy

IO — IT'S OLIVIA ("IO", "we", "us", or "our") is a global wellness and lifestyle brand offering premium functional coffees, collagen products, essential oils, and signature fragrances through itsolivia.life and our community of independent Members and Distributors.

For the purposes of applicable data-protection law — including the EU and UK General Data Protection Regulation (GDPR/UK GDPR) and the California Consumer Privacy Act (CCPA/CPRA) — IO is the data controller responsible for processing your personal information.

If you have any privacy-related questions, you can reach our Privacy Team using the contact details in Section 15.

We collect personal information in several categories depending on how you interact with us. Not every category applies to every user.

Identity & Contact Information

Information you provide directly when creating an account, placing an order, or contacting us:

Account & Transaction Information

Information generated when you use the site or make a purchase:

• Account login credentials and saved preferences;
• Order history, including products purchased and order value;
• Membership type and enrolment date;
• Distributor genealogy and downline information (for Distributors);
• Commission and compensation records (for qualifying Distributors);
• Loyalty program participation and points balance;
• Product preferences and saved wish-lists.

Payment Information

When you make a purchase, our third-party payment processors (such as Shopify Payments and Stripe) collect and process your payment-card information directly. IO does not store your full payment-card number on its servers. We retain only a tokenised reference and the last four digits to identify the transaction. Payment processing is governed by the processor's own privacy practices in addition to this Privacy Notice.

Communications & Interactions

When you contact us or engage with IO, we may collect:

• Customer-service messages and the contents of our exchanges;
• Survey responses and feedback you choose to provide;
• Social-media interactions where you engage with our official accounts;
• Product reviews and testimonials you submit to our community platforms.

We may call you for marketing communications as set out in our marketing policies.

Device & Usage Information

When you visit the Site, we automatically collect certain technical information:

• Internet Protocol (IP) address;
• Device type, operating system, and browser type and version;
• Pages visited, time spent, and navigation paths;
• Referring website or search term that brought you to our site;
• Date and time of your visit;
• Crash reports and performance data;
• Unique device identifiers and advertising identifiers.

Location Information

We may collect general location information based on your IP address (city-level only) to deliver region-appropriate content, ensure language and currency preferences, and comply with regional legal requirements. We do not collect precise GPS-level location information unless you explicitly grant permission through a mobile application.

Health & Wellness Information (Limited)

Our products include functional wellness items such as IO Coffee and IO Collagen Fiber Jelly. You may voluntarily provide health or wellness information when seeking product recommendations, contacting customer support regarding a product's suitability, or participating in community discussions. We treat any health-related information you voluntarily provide with extra care and do not use it for purposes beyond the context in which you provide it.

Information from Third Parties

We may receive information about you from third parties in certain circumstances, including:

• Payment processors confirming successful or failed transactions;
• Shipping and logistics partners providing delivery-status information;
• Social-media platforms when you connect your account or share our content;
• Community members who refer you, as part of your distributor network;
• Analytics and advertising partners who provide aggregated or pseudonymised insights.

Primarily, To:

Most of the personal information we hold about you comes directly from you. This includes information you provide when you:

• Create an account on itsolivia.life;
• Place an order for IO products;
• Enrol as an IO community member or distributor;
• Subscribe to our email communications;
• Contact our customer-support team;
• Participate in surveys, promotions, or giveaways;
• Submit a product review or testimonial;
• Register for an event or webinar.

Automatically Through Technology

When you visit our site, our servers and third-party service providers automatically collect certain technical information through cookies, web beacons, pixel tags, and similar tracking technologies. This collection occurs whether or not you are logged into an account. See Section 5 for details on our use of cookies and how to manage your preferences.

From the IO Community

When you participate in the IO community by enrolling under a Distributor, that person may provide us with your contact information for the purpose of confirming your enrolment and describing how your information will be used.

From Third-Party Service Providers

We work with trusted third parties who may provide us with information about you in the course of delivering their services to us, on our behalf. For example, payment processors may share transaction-confirmation data, and shipping providers may share delivery-status updates.

How We Use Your Information

If your personal information is specific, legitimate purposes aligned with operating our business and serving our community. We do not use your information for purposes that exceed what is described in this Privacy Notice.

To Fulfil Orders and Deliver Products

We use your contact, payment, and shipping information to process orders, charge for purchases, arrange delivery, and communicate with you about your order status.

To Operate and Maintain Your Account

We use your account information to authenticate your login, maintain your order history and preferences, manage your membership status, and provide you access to the IO community features associated with your account level.

To Administer the IO Community and Compensation Programs

For IO community members and distributors, we use your information to calculate and process commissions and bonuses, maintain your genealogy position within the IO network, provide performance reporting, and administer the IO loyalty and rewards program. This includes sharing relevant account activity with others in your upline as described to support the IO compensation plan.

To Communicate With You

We use your contact information to communicate with you about:

• Order confirmations, shipping notifications, and delivery updates;
• Customer-service responses to your inquiries;
• Important account notifications and security alerts;
• Product information, launches, and updates relevant to your account;
• Promotional offers, discounts, and loyalty rewards (where you have consented to marketing communications);
• Community updates, event invitations, and educational content from IO.

For Personalisation

We may use information about your past purchases, browsing behaviour, and stated preferences to deliver personalised product recommendations, improve your experience on the Site, and tailor the content you see when interacting with our community platforms.

To Improve Our Products, Sites, and Services

We use technical data such as device information to detect and prevent fraudulent transactions, unauthorised account access, and other harmful activity affecting our Site, our community, or our customers.

To Comply With Legal Obligations

We use your information where required by applicable law, including but not limited to reporting obligations and responses to lawful requests from government authorities.

To Personalise Your Experience

If your personal information is used in ways that contribute to a personalised experience — for example, to personalise recommendations and educational materials from IO Coffee, IO Collagen Fiber Jelly, or essential-oils content based on your interests and preferences.

With IO Service Providers

We share personal information with carefully selected third-party service providers who perform functions on our behalf, including:

• Payment processors and credit-card processing and fraud-prevention partners;
• Shipping and logistics companies who fulfil and deliver your orders;
• Email and communications platforms who deliver our messages to you;
• Website hosting and cloud-infrastructure providers;
• Customer-support platforms and tools;
• Analytics providers who help us understand site usage in aggregated form;
• IT security providers who protect against fraud and abuse.

We require all service providers to maintain the confidentiality of your information, to use it only for the purposes for which we share it, and to maintain appropriate security standards.

Within the IO Community Network

If you are an IO community member or distributor, certain account information is shared within the IO distribution network for the purpose of administering sales, calculating compensation, and providing activity reporting. Specifically:

• Your enrolment date, membership status, and general activity level may be visible to your direct upline;
• If you sponsor a member, your downline member information may be accessible to you for the purpose of supporting and growing your team;
• Commission and compensation amounts are visible to you and to IO administrators but not shared broadly within the community.

This sharing is necessary and inherent part of the IO direct-sales community model. If you do not wish for your information to be shared in this way, please consider whether IO community membership is appropriate for your privacy preferences before enrolling.

With Affiliates and Subsidiaries

We may share your information with IO's affiliated entities and subsidiaries where necessary to operate our global business, fulfil your orders across international markets, or provide you with consistent customer service.

For Legal Compliance and Protection

We may disclose your personal information when we believe in good faith that disclosure is necessary to:

• Comply with applicable law, regulation, or legal process;
• Respond to lawful requests from government or regulatory authorities;
• Protect the rights, property, or safety of IO, our customers, or the public;
• Detect, prevent, or address fraud, security, or technical issues.

In Connection With a Business Transaction

If IO is involved in a merger, acquisition, sale of assets, or similar business transaction, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information, as well as any choices you may have regarding your information.

With Your Consent

Outside of the circumstances described above, we will share your personal information with third parties only with your express consent.

What Cookies Do

Cookies are small text files that websites place on your device when you visit them. They allow the website to remember your preferences, keep you logged in across sessions, and collect information about how you use the site. We may also use similar technologies such as web beacons, pixel tags, and local storage to operate certain functions.

How IO Uses Cookies

We use the following categories of cookies and similar technologies on our site:

Strictly Necessary

Essential to the operation of the site. These cookies enable core functionality such as authentication, shopping cart, and checkout. The site cannot function properly without them.

Performance & Analytics

Help us understand how visitors interact with our site by collecting aggregated, anonymous information about page views, navigation paths, and any errors that occur. We use this information to improve site performance.

Functional Cookies

Remember your preferences such as language preference and region, allowing the site to deliver a more personalised experience aligned with how you have previously chosen to interact with us.

Marketing & Targeting

May be set by us or by approved partners to deliver relevant content and advertising tailored to your interests across other websites you visit. These cookies are subject to your consent in regions where required by law (such as the EU/UK).

Managing Your Cookie Preferences

Most web browsers allow you to control cookies through their settings. You can typically refuse cookies, delete existing cookies, or be notified when a cookie is set. Please note that blocking or refusing cookies — particularly Strictly Necessary cookies — may affect the functionality of the site and prevent you from using certain features.

Some jurisdictions do not allow the exclusion of certain warranties, so some of these exclusions may not apply to you. For users in regions with applicable cookie consent laws (such as the EU/UK), we display a cookie consent banner allowing you to manage your cookie preferences upon your first visit.

Do-Not-Track

Some browsers transmit a Do-Not-Track signal to websites. Our Site does not currently respond to Do-Not-Track signals as no industry-standard mechanism for honouring this signal has been established. We will update this practice as standards develop.

Depending on where you live, you may have specific legal rights regarding your personal information. IO is committed to honouring these rights in a transparent and timely manner.

Right to Access

You have the right to request a copy of the personal information IO holds about you. We will provide this information in a clear, accessible format within thirty (30) days, except in unusual cases where applicable law allows us to extend the timeframe.

Right to Correction

If any personal information we hold about you is inaccurate or incomplete, you have the right to request correction. You can update most basic profile information directly in your account at any time, or contact us for assistance with corrections we cannot make directly.

Right to Deletion

You may ask us to delete the personal information we hold about you. We will honour deletion requests except where we are required by law to retain certain information (such as transaction records for tax purposes), where the information is necessary to fulfil a contract you have with us, or where retention is necessary to protect IO's legal interests.

Right to Opt Out of Marketing Communications

You may opt out of receiving marketing emails from IO at any time by clicking the "unsubscribe" link in any marketing email or by contacting us directly. Opting out of marketing communications will not prevent us from sending you transactional and account messages, such as order confirmations and shipping notifications, which are necessary to provide our services.

Right to Restrict or Object to Processing

In certain circumstances, you may have the right to restrict or object to how we process your personal information. This right is particularly relevant where we rely on legitimate interests as the legal basis for our processing.

Right to Data Portability

Where we hold your personal information based on your consent or for the performance of a contract, you have the right to receive that personal information in a structured, commonly used, and machine-readable format, and to request that we transmit that information to another controller where technically feasible.

Right to Withdraw Consent

Where we rely on your consent to process your personal information, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing we conducted based on your consent before its withdrawal.

Right to Lodge a Complaint With a Supervisory Authority

If you are located in the EU, UK, or another region with a data-protection authority, you have the right to lodge a complaint with that authority if you believe IO's processing of your personal information violates applicable law. We encourage you to contact us first so we can address your concerns directly.

How to Exercise Your Rights

To exercise any of the rights described above, please contact us using the contact details in Section 15. We may need to verify your identity before fulfilling your request to protect against fraudulent or unauthorised requests. There is no fee to exercise your privacy rights, except in the case of unfounded or excessive requests as permitted by applicable law.

We retain personal information only as long as necessary to fulfil the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

Account Data

Retained for as long as your account is active. Inactive accounts may be deleted after 36 months of inactivity, with prior notice where required.

Transaction Records

Retained for at least 7 years to comply with tax, accounting, and financial reporting obligations.

Marketing Preferences

Retained until you withdraw consent. Records of your withdrawal are kept indefinitely to honour your choice.

Customer Service Records

Retained for up to 5 years from your last interaction, to maintain a complete service history.

Distributor Records

Retained for up to 7 years following termination of your Distributor agreement, in accordance with regulatory and tax obligations.

Site Analytics

Aggregated and anonymised analytics data may be retained indefinitely as it no longer identifies individuals.

When we no longer need your personal information for the purposes described above, we will delete it or anonymise it so that it can no longer be associated with you.

IO implements reasonable and appropriate administrative, technical, and physical safeguards designed to protect your personal information from unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Encryption of personal data in transit using Transport Layer Security (TLS) protocols;
• Encryption of sensitive data at rest using industry-standard encryption algorithms;
• Access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments, vulnerability testing, and penetration testing;
• Employee training in data privacy and security requirements;
• Incident-response procedures to detect, contain, and notify of any security incident.

You also have a role in protecting your personal information. Please use a strong, unique password for your IO account, do not share your credentials with others, and notify us immediately if you suspect unauthorised access to your account.

The IO Site and our products are not intended for or directed at children under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without verifiable parental consent, we will promptly delete that information.

If you are a parent or guardian and believe your child has provided personal information to us without your consent, please contact us using the details in Section 15 so we can take appropriate action.

IO operates globally, and your personal information may be transferred to, stored, and processed in countries other than the country in which you are located. These countries may have data-protection laws that differ from those in your home jurisdiction.

Where we transfer personal information from the European Economic Area (EEA), United Kingdom, or Switzerland to a country that has not received an adequacy decision from the relevant authority, we rely on appropriate safeguards as required by applicable law, including:

• Standard Contractual Clauses approved by the European Commission;
• UK International Data Transfer Agreement or UK Addendum, where applicable;
• Other lawful transfer mechanisms that provide an essentially equivalent level of protection.

You may request a copy of the safeguards we have put in place for international transfers by contacting us using the details in Section 15.

The IO Site may contain links to third-party websites, applications, or services that are not owned or operated by IO. This Privacy Notice applies only to information collected by IO on the Site and does not apply to information collected by third-party sites or services, even when accessed through a link on our Site.

We encourage you to review the privacy policies of any third-party sites or services you visit. IO is not responsible for the privacy practices of third parties or for any information you choose to share with them.

As an IO Member or Distributor, you may have access to personal information about other community members — including downline information, customer contact details, and performance data — for the purpose of supporting your IO business. When you access this information, you become responsible for handling it in accordance with applicable privacy law and IO's distributor data-handling policies.

You agree to:

• Use community information only for legitimate IO business purposes;
• Maintain the confidentiality of any personal information you access;
• Not disclose, sell, or share community personal information with any party outside the IO network without explicit consent from the individual concerned;
• Not use community contact information for any unauthorised marketing, solicitation, or communication;
• Comply with all applicable data-protection laws in your jurisdiction;
• Notify IO immediately of any suspected or actual breach of personal information you access.

Failure to comply with these responsibilities may result in termination of your membership or distributor agreement and potential legal liability.

If you are a resident of California, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with additional rights regarding your personal information. This section supplements the rest of this Privacy Notice and applies specifically to California residents.

Categories of Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information about California residents:

• Identifiers — name, email address, postal address, phone number, account credentials;
• Customer record information — billing address, payment information;
• Commercial information — purchase history, products viewed, preferences;
• Internet or electronic network activity — browsing history, site interactions, device identifiers;
• Geolocation data — general (city-level) location based on IP address;
• Inferences drawn from the above to create a profile reflecting your preferences.

Your California Privacy Rights

As a California resident, you have the right to:

• Know what personal information we have collected, used, disclosed, or sold about you in the prior 12 months;
• Access the specific pieces of personal information we have collected;
• Request deletion of personal information, subject to certain exceptions in law;
• Correct inaccurate personal information we maintain about you;
• Limit use of sensitive personal information to specific business purposes;
• Opt out of "sale" or "sharing" of personal information for cross-context behavioural advertising;
• Non-discrimination — we will not discriminate against you for exercising any of your rights.

We Do Not Sell Personal Information

"Shine the Light" Disclosure

California residents may request information regarding our disclosure of personal information to third parties for their direct-marketing purposes. To make such a request, contact us using the details in Section 15 and identify your request as a "Shine the Light" inquiry.

How to Exercise California Rights

To exercise your California privacy rights, contact us using the details in Section 15. We will verify your identity before fulfilling your request, and you may designate an authorised agent to make a request on your behalf in accordance with applicable law.

IO may update this Privacy Notice from time to time to reflect changes in our practices, our products, applicable law, or other operational reasons. When we make material changes, we will post the updated Notice on this page with a revised "Last Reviewed" date.

For material changes that significantly affect how we handle your personal information, we will provide additional notice — such as by email or through a prominent notice on the Site — at our discretion and as required by applicable law.

Your continued use of the Site after the date on which the updated Privacy Notice takes effect constitutes your acceptance of the changes. We encourage you to review this Privacy Notice periodically to stay informed of how we handle your personal information.

If you have questions, concerns, or requests related to this Privacy Notice or your personal information, please contact our Privacy Team using the details below. We are committed to responding promptly and transparently to every inquiry.

Privacy Inquiries

privacy@itsolivia.life

Data Subject Requests

dsar@itsolivia.life

General Support

hello@itsolivia.life

Website

itsolivia.life

When contacting us, please include enough detail for us to understand and respond to your request — such as your full name, the email address associated with your IO account, and a clear description of your inquiry.