PRIVACY POLICY

 

Last Updated: August 30, 2026

MitoSynergy, LLC ("Company," "we," "our," or "us") respects your privacy and is committed to protecting it through our compliance with this policy. This privacy policy (this "Policy") describes how we collect, use, retain, and disclose personal data about you when you visit our website at mitosynergy.com, purchase our products, register for or participate in our Color Reset Guarantee program (our hair color restoration money-back guarantee program, the "Color Reset Guarantee"), or otherwise interact with us (collectively, our "Services"), and our practices for using, maintaining, protecting, and disclosing that information.

This Policy sets forth MitoSynergy's baseline privacy and data practices. Where you have entered into additional agreements or provided separate consents in connection with your use of the Color Reset Guarantee App (the "App") or participation in any MitoSynergy program or study, those agreements and consents supplement this Policy and are not diminished or superseded by it. In the event of any conflict between this Policy and a more protective consent or agreement, the terms affording greater privacy protection to you shall govern.

This Policy applies to information we collect:

•            Through our website at mitosynergy.com, including any registration or enrollment forms.

•            Through the App, if and when made available, including when you download, create an account on, or use the App to submit monthly progress photographs, acknowledge program terms, and submit refund claims in connection with the Color Reset Guarantee.

•            In email, text, and other electronic communications between you and us in connection with your use of the Services or participation in the Color Reset Guarantee.

•            When you purchase our products through mitosynergy.com, through an authorized purchase channel (including Amazon), or are directed to our website or the App via a QR code or promotional link included with your product purchase.

 

This Policy does not apply to information collected by third parties related to or accessible as a result of our Services, including through any third-party platform or marketplace such as Amazon, Apple, or Microsoft. Third parties have their own privacy policies that govern the information they collect, and we are not responsible for the data collection or privacy practices of any such third party.

Please read this Policy carefully. By using the Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this Policy. This Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of the Services after we make changes is deemed acceptance of those changes.

Changes to This Privacy Policy

We may update this Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Policy on our website, update the "Last Updated" date, and take any other steps required by applicable law.

Personal Data We Collect

"Personal data" means information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, mailing address, or purchase history. This definition includes, but is not limited to, the information provided via the following methods:

Information You Provide to Us Directly

Information you directly submit to us through our Services may include, but is not limited to:

•            Basic contact details, including your name, address, phone number, and email address.

•            Order information, including recipient name, billing address, shipping address, payment confirmation, email address, and phone number.

•            Account information, including your username, password, and security questions.

•            Participation data for any program you are participating in as part of our Services, including information submitted in connection with the Color Reset Guarantee, such as confirmation of protocol compliance and progress updates.

•            Images and photographs you submit through the App or through such other submission method made available through the Services in connection with any program offered through our Services, including photographs required as part of a program’s completion protocol. Such images and photographs will be used internally for purposes of program administration and compliance verification, and are not used for marketing, advertising, or any external purpose absent your separate consent.

•            Customer support information, including the information you choose to include in communications with us.

Information We Collect Automatically

We automatically collect certain information about your interaction with the Services. Our website may use cookies, pixels, and similar technologies to collect usage data, including device information, browser information, network connection information, your IP address, and other information about your interaction with our website.

Further, the App will automatically collect certain information when you download, install, or use the App, including:

•            Device information, including your device type, model, manufacturer, and operating system version.

•            Camera access to capture progress photographs as required by the program protocol.

•            App usage and log data, including information about how and when you use the App, session activity, features accessed, crash reports, and error logs.

•            Photograph metadata, including the date and time of each submission.

 

We may use cookies, web beacons, pixels, and similar tracking technologies to collect information about your interaction with our website, including browsing behavior and usage patterns. Most browsers accept cookies by default; you may set your browser to remove or reject them, though doing so may affect your experience or the availability of certain features.

Information We Obtain from Third Parties

We may obtain information about you from third parties, including from vendors and service providers who collect information on our behalf, such as:

•            Platform providers, such as Amazon, which support our website and store operations.

•            Payment processors, who collect payment information (such as bank account or credit card information and billing address) to process your payment and fulfill your orders.

•            Analytics and advertising partners, who may collect information when you visit our website or interact with our emails or advertisements.

 

Any information we obtain from third parties will be treated in accordance with this Policy. We are not responsible for the accuracy of information provided to us by third parties or for any third party’s policies or practices.

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), we are required to describe the categories of personal information we collect, the sources from which we collect it, and the purposes for which we use it. We collect the following:

•            Identifiers, such as name, email address, phone number, and account credentials, gathered directly from you to create and manage your account, process orders, and communicate with you about the Services and the Color Reset Guarantee;

•            Commercial information, including purchase and order information collected directly from you and through third-party e-commerce platforms, payment processors, and other service providers involved in facilitating your transaction and administering refund claims;

•            Internet or electronic network activity information, including App usage data and browsing activity, collected automatically through your use of our Services to improve functionality, analyze usage patterns, and deliver relevant content; and

•            Visual information, including photographs and images you submit in connection with our Services, collected directly from you for purposes related to the specific Service you are using, such as to document program participation and verify compliance with program requirements. Photographs submitted through the Color Reset Guarantee App are subject to additional program-specific requirements, including that submissions depict only the crown and scalp of the participant’s head; the App’s submission guidelines prohibit inclusion of facial features.

 

MitoSynergy does not sell your personal information for monetary consideration. We share personal information with service providers for the business purposes described in this Policy. Specifically, identifiers and commercial information are shared with third-party e-commerce platforms and our payment processors to facilitate transactions and order fulfillment; internet or electronic network activity information may be shared with analytics and advertising providers to support platform performance and marketing; and visual information (progress photographs) is shared only with service providers involved in program administration and claim review; photographs are not shared with advertising or marketing vendors. Some sharing of identifiers and internet activity information with advertising providers may constitute "sharing" for cross-context behavioral advertising under the CCPA. California residents may opt out of this sharing at any time by enabling a Global Privacy Control (GPC) signal through a compatible browser or device; we will treat a verified GPC signal as a valid opt-out request for cross-context behavioral advertising.

How We Use Your Information

We use the information we collect about you or that you provide to us, including personal data, to:

•            Provide our Services, fulfill and manage your product orders, process payments, and arrange shipping and deliveries.

•            Communicate with you, including sending you notifications related to your account, purchases, and orders, and sending program-related communications such as monthly reminder notifications to upload progress photographs.

•            Marketing and advertising, unless otherwise stated in this Policy. Such use includes sending marketing, advertising, and promotional communications by email, text message, or postal mail, and showing you advertisements for products or services. This may include using your information to better tailor our Services and advertising on our website and other websites.

•            Internally evaluate photographs and other data submitted through the App for purposes of program administration, claim verification, and any other purpose for which you have separately provided consent within the App. Such data is not used for marketing, advertising, or any external purpose absent your separate consent.

•            Security and fraud prevention. We use your information to detect, investigate, or take action regarding possible fraudulent, illegal, or malicious activity.

•            Enforce our agreements and rights arising from any contracts with you, including for billing and collection purposes.

•            Comply with applicable law, respond to legal process, and protect our rights, property, or safety and that of our customers or others.

How We Disclose Your Information

We may disclose aggregated or de-identified information about our users without restriction. We may also disclose personal data that we collect or you provide in the following circumstances:

•            To service providers and contractors used by us to support our operations, such as IT management, order fulfillment, shipping, payment processing, data analytics, customer support, and cloud storage. Such vendors operate subject to confidentiality and data use obligations and, for purposes of this Policy, are treated as extensions of MitoSynergy with respect to the data they process on our behalf.

•            To business and marketing partners to provide services and advertise to you.

•            To a buyer or other successor in the event of a merger, acquisition, reorganization, dissolution, or sale of all or substantially all of our assets.

•            When you direct us or consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets.

•            To comply with any applicable law, court order, or legal process, including to respond to any government or regulatory request.

•            To enforce or apply the Terms of the Color Reset Guarantee and other applicable agreements.

•            If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others.

Your Rights and Choices

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

•            Access / Know. You may request access to the personal data we hold about you, including details about how we use and share it.

•            Correction. You may request that we correct inaccurate personal data we maintain about you.

•            Deletion. You may request that we delete personal data we maintain about you, subject to certain exceptions under applicable law. Because your progress photographs are the record we use to verify your eligibility for a refund under the Color Reset Guarantee, we retain those photographs through the end of the claim validation period. You may request deletion of your photographs at any time; however, if you do so before your refund claim has been validated, we will be unable to verify your eligibility and your claim cannot be completed. We will not discriminate against you for exercising your deletion right, but we are permitted under applicable law to explain the consequences of deletion in the context of a financial incentive program.

•            Portability. You may have the right to receive a copy of the personal data we hold about you and, in certain circumstances, to request that we transfer it to a third party.

•            Opt Out of Sale, Sharing, or Targeted Advertising. You may have the right to direct us not to "sell" or "share" your personal data or to opt out of the processing of your personal data for purposes considered to be "targeted advertising" as defined in applicable privacy laws. To exercise this right, please contact us using the information below. If you visit our website with the Global Privacy Control (GPC) opt-out preference signal enabled, we will treat this as a request to opt out of the sale or sharing of your information for the device and browser you use to visit our website, to the extent required by applicable law.

•            Restriction of Processing. You may have the right to ask us to stop or restrict our processing of your personal data.

•            Withdrawal of Consent. Where we rely on your consent to process your personal data, you may withdraw that consent at any time.

•            Marketing Communications. You may opt out of receiving promotional emails at any time by using the unsubscribe link in any such email. If you opt out, we may still send you non-promotional communications, such as those related to your account, orders, or participation in the Color Reset Guarantee.

•            Appeal. You may have the right to appeal our decision if we decline to process your request by contacting us using the details below.

 

To exercise any of these rights, please contact us using the information provided in the Contact section below. We will not discriminate against you for exercising any of these rights. We may need to verify your identity before responding to your request. You may designate an authorized agent to make requests on your behalf; we will require proof of authorization before acting on such a request.

MitoSynergy will respond to verifiable consumer requests within 45 days of receipt. If additional time is needed, we will notify you in writing of the reason for any extension before the initial 45-day period expires. We may extend our response by up to an additional 45 days if reasonably necessary.

California residents have the right to direct MitoSynergy to limit our use and disclosure of sensitive personal information to uses that are necessary to provide the services you request, or as otherwise permitted by applicable law. Because MitoSynergy does not use or disclose sensitive personal information for purposes that would require a right-to-limit mechanism under applicable law, a request to limit such processing may not result in any change to our current practices. To exercise this right, please contact us using the information in the Contact section below.

MitoSynergy does not collect sensitive personal information except as may be incidentally included in your communications with us, or as necessary to administer your account, process transactions, and fulfill program obligations. Progress photographs collected through the Color Reset Guarantee are used for program administration and are not processed to infer personal characteristics or used for any purpose beyond those disclosed in this Policy or separately consented to by you.

Security and Retention of Your Information

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the security of your personal data. Any transmission of personal data is at your own risk.

How long we retain your personal data depends on different factors, such as whether we need the information to maintain your account, to provide the Services, to comply with legal obligations, to resolve disputes, or to enforce our agreements.

For progress photographs submitted through the App, we retain photographs for the duration of your enrollment in the Color Reset Guarantee and through the close of the claim validation period. Photographs are deleted upon the earliest of the following: (a) 30 days following the close of the claim validation window if no refund claim has been submitted; (b) upon resolution of any pending refund claim (and in no event more than 90 days following the close of the claim validation window); (c) upon your written request for deletion, subject to any active refund claim; or (d) upon account cancellation. MitoSynergy does not retain photographs beyond these periods absent a legal hold or unresolved dispute.

For all other categories of personal information we collect, including account identifiers, transaction records, communications, and internet activity data, we retain information only as long as reasonably necessary for the purposes for which it was collected. Those purposes include providing and improving the Services, maintaining accurate business records, complying with legal obligations, resolving disputes, enforcing our agreements, and protecting against fraud and unauthorized activity.

Notice of Financial Incentive

The Color Reset Guarantee conditions eligibility for a refund on participants’ agreement to provide and retain progress photographs through the claim validation period. Under the California Consumer Privacy Act (CCPA) and analogous state laws, this arrangement constitutes a financial incentive program requiring disclosure at or before the point of enrollment. The following describes the material terms of this program.

1.        Financial Benefit. The financial benefit offered under the Color Reset Guarantee is the refund available to participants who complete the program and satisfy all applicable claim requirements described in the Terms of the Color Reset Guarantee.

2.        Personal Data Collected. Participation in the Color Reset Guarantee requires submission of standardized monthly progress photographs through the App. MitoSynergy retains these photographs through the close of the claim validation period and deletes them in accordance with the retention schedule described above.

MitoSynergy has determined in good faith that the value of the personal information collected in connection with the Color Reset Guarantee is reasonably related to the cost of administering the program. That value is calculated based on the costs associated with maintaining required participant records, processing refund claims, and preventing fraudulent claims. No personal information is collected or retained beyond what is necessary for those purposes.

3.        Non-Discrimination. Participants who choose not to submit photographs, or who request deletion of their photographs prior to the close of the claim validation window, remain free to do so; however, eligibility for the refund is conditioned on completion of all photograph submission requirements under the Terms of the Color Reset Guarantee. This differential treatment reflects the material terms of the program and does not constitute discrimination within the meaning of the CCPA.

4.        How to Withdraw. You may withdraw from the Color Reset Guarantee program at any time by contacting us using the information in the Contact section below. Withdrawal may affect your eligibility for the refund under the program Terms.

Biometric Privacy

Photographs collected through the Color Reset Guarantee are required to depict only the crown and scalp of the participant’s head. The App’s submission guidelines prohibit the inclusion of facial features, and the App’s quality-review function verifies that submissions conform to this requirement. Photographs are used to document participant progress, verify compliance with program requirements, and for any other purpose for which you have separately provided consent. MitoSynergy does not use facial recognition technology, generate biometric identifiers or templates, or analyze photographs to identify individuals through any biometric processing. Photographs are reviewed to confirm that required submissions were received, that submissions fall within the applicable timeframe, and that photographs meet minimum quality standards They are not analyzed for any purpose beyond program administration or as otherwise separately consented to by you.

Photographs submitted through the App will not be publicly displayed, sold, licensed, or otherwise commercialized without your separate express written consent. Certain photographs submitted through the App may reflect information concerning physical appearance or characteristics voluntarily provided by participants; any such information is used for program administration, claim verification, and any other purpose for which you have separately provided consent, and is not used to make medical diagnoses or treatment decisions.

Children’s Data

The Services are not intended for use by children under 18 years of age, and we do not knowingly collect personal data from children. If you are the parent or guardian of a child who has provided us with personal information, please contact us using the details below to request that it be deleted. As of the date of this Policy, we do not knowingly sell or share the personal information of individuals under 16 years of age.

Third-Party Websites and Links

Our website may provide links to websites or other online platforms operated by third parties. We are not responsible for the privacy or security of such sites and do not guarantee the accuracy, completeness, or reliability of information found on them. Information you share on third-party platforms, including social media, may be viewable by other users without limitation as to its use by us or by third parties.

International Users

We are based in the United States and our Services are directed to users in the United States. If you access our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate.

Washington State Residents

If you are a Washington State resident who participates in the Color Reset Guarantee, you may have additional rights under the Washington My Health My Data Act (RCW 19.373.005 to 19.373.900) with respect to consumer health data, as that term is defined in the Act, collected through the App. Our Consumer Health Data Privacy Policy for Washington Residents, available at [URL], describes our practices with respect to such data and your rights under the Act, including your rights to confirm and access, withdraw consent from, and request deletion of your consumer health data. The Consumer Health Data Privacy Policy is a separate document that supplements this Policy and governs only consumer health data collected from Washington State residents through the App.

Contact Us

If you have questions about this Policy or our privacy practices, or to exercise any of the rights described above, please contact us at:

MitoSynergy, LLC
2942 N 24th St, Ste 115
Phoenix, AZ 85016-7849
Email: info@mitosynergy.com