Privacy Policy

Your privacy and the security of your personal information are very important to
us. We want you to be as comfortable as possible visiting our Website and using
our Application. We are dedicated to protecting the privacy of those who visit our
Website and use our Online Products. This Privacy Policy governs our website (collectively
our “Website”) and our Applications, and explains how we collect your personal information,
how we protect such information, and the choices you have concerning the use of
such information. Please read this Privacy Policy carefully. Except as The Ornish
SPECTRUM specifically disclose in this Privacy Policy, we will not sell, share,
license, trade, or rent your personal information to others.

We may amend this Privacy Policy from time to time. We will post any changes to
this Privacy Policy here so that you will always know what information we gather,
how we might use that information, and whether we will disclose that information
to anyone. Please refer back to this Privacy Policy on a regular basis. By using
our Website or any of our products, offerings, features, tools or resources that
we provide on our Website (collectively, our “Online Products”), including our products
or offerings for personal digital assistants or other handheld or mobile devices
(collectively, our “Handheld Products”), you agree to the terms of this Privacy
Policy.

Please remember that this Privacy Policy applies only to information collected by
our Website or through our Online Products. We are not responsible for the privacy
of any information you reveal or post in any public forum (e.g., message board,
blog, personal page, etc.) or through the “Public Profile” feature available on
our Website, or for the privacy practices of websites that are operated or owned
by third parties.

WHAT INFORMATION ABOUT YOU IS COLLECTED ON OUR WEBSITE OR THROUGH OUR ONLINE PRODUCTS?

We collect two types of information: personally identifiable information and non-personally
identifiable information.

Personally Identifiable Information.

Personally identifiable information is information that identifies you or can be
used to identify or contact you (“Personally Identifiable Information”). Such Personally
Identifiable Information may include your name, address, email address, telephone
number, birth date (primarily for eligibility purposes) and billing and payment
information. We may request Personally Identifiable Information from you when you
register on our Website, subscribe to our Online Products, or in connection with
other Online Products we may make available on our Website from time to time. In
all of these cases, we will collect Personally Identifiable Information from you
only if you voluntarily submit such information to us. Unless you give us permission
to do so, we will not sell, share, license, trade or rent your Personally Identifiable
Information other than as specified in this Privacy Policy.

You do not have to provide us with any Personally Identifiable Information to visit
our Website. However, if you choose to withhold requested information, you may not
be able to visit all sections of our Website or use all of our Application, such
as subscribing to our community or using the tools available to members.

Non-Personally Identifiable Information.

When you become a registered user of our Website, and become a member of The Ornish
SPECTRUM community, we also may collect information that by itself cannot be used
to identify or contact you, such as demographic information (like age, profession
or gender) and health information (“Non-Personally Identifiable Information”). Non-Personally
Identifiable Information may also include user IP addresses, browser types, domain
names, and other anonymous statistical data involving the use of our Website. Non-Personally
Identifiable Information is used to help us understand who uses our Website and
to improve and market our Website and Application.

Information from Other Sources.

We may also supplement the information we collect with information from other sources
to assist us in evaluating and improving our Website and Application, to determine
your preferences so that we can tailor our Website and Application to your needs.

WHERE AND WHEN IS INFORMATION COLLECTED ON OUR WEBSITE OR THROUGH OUR ONLINE PRODUCTS
(INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We may collect information (including information that is Personally Identifiable
Information) from you in different manners and at different places and times on
our Website, such as when you become a member of The Ornish SPECTRUM community.
We also may collect information from you in connection with, or through, our Website
and Application. The following is a description of the areas and/or manners in which
we primarily collect information about you.

Becoming a Subscriber

In order to access certain sections of our Website, you must first complete certain
steps to become a subscriber. During these steps, you may be required to provide
us with information (including Personally Identifiable Information) such as name,
zip code and email address, and, payment and billing information. This information
is used to help us understand who uses our Website, to improve our Website and our
Online Products, to contact users about requested Applications and/or for subscription
billing purposes.

Cookies and Action Tags.

We also collect Non-Personally Identifiable Information passively using “cookies”
and “action tags.”

“Cookies” are small text files that are placed on your computer or mobile device
in order to identify (i) your Web browser, (ii) the activities of your computer
on our Website and (iii) your activity in connection with our advertisements and
other marketing and promotional efforts. Cookies may be used to:

• assist you in using our Website and Application (e.g., to save you time by not having
  to reenter your name upon each visit to our Website), and
• allow us to statistically monitor how you are using our Website for purposes of
  improving our online offerings.

We also may use cookies to conduct marketing and promotional efforts, or to determine
the popularity of certain content.

You do not have to accept cookies to use our Website, however, you may not be able
to use certain products, offerings, features, or resources of our Website (such
as “remember me”) if you do not accept cookies. Although most browsers are initially
set to accept cookies, you may reset your browser to notify you when you receive
a cookie or to reject cookies generally. Most browsers offer instructions on how
to do so in the “Help” section of the toolbar.

Online Products.

We collect information, some of which may be Personally Identifiable Information,
that you voluntarily provide to us when you choose to use some of our Online Tools
(available on a subscription basis) such as the tracking tools, calendar and reminders,
and love and support feed. Some of these Online Tools may ask you for health related
information. We collect this information in order to help you track your progress
against your health related goals.

Handheld Products.

Information is also collected when you use our Handheld Products, including the
software application needed to utilize the Handheld Products on your handheld device
(the “Application”). During the installation of the Application and subsequent synchronizations,
we collect Non-Personally Identifiable Information concerning your device (such
as the specific type of operating system and hardware you have, and the amount of
free and total memory) and the Application’s files on your device.

Our Handheld Products also collect information about your usage of the Application
(such as the dates you last synced with the Internet or the dates you last used
certain features). When you sync your device with the Website, we store some of
this information.

Log Files.

We also collect Non-Personally Identifiable Information through our Internet log
files, which record data such as user IP addresses, browser types, domain names,
and other anonymous statistical data involving the use of our Website. This information
may be used to analyze trends, to administer the Website, to monitor our Website’s
use, and to gather general demographic information. We may link this information
to Personally Identifiable Information for these and other purposes such as personalizing
your experience on our Website and evaluating our Online Products in general.

Email or Refer a Friend.

Through our referral tools for informing a friend about our Website, or our Application,
we will automatically send your friend a one-time email containing the information
you request to be sent. If you elect to use these referral tools, we will collect
from you certain Personally Identifiable Information about your friend which you
have provided, such as your friend’s name and email address. We do not store your
friend’s information or use it for any other purpose.

DO WE COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. Our Website and Online Products
are not designed for or directed to children under the age of 13. We do not collect
Personally Identifiable Information from any person we actually know is under the
age of 13. We urge all parents or guardians to participate in their children’s exploration
of the Internet, and to teach their children about protecting their personal information
while online.

WHAT DO WE DO WITH THE INFORMATION WE COLLECT?

In general, we use the information collected on our Website and through our Application
to help us understand who uses our Website and Application and how they are used,
, to assist you in using our , to improve our Website and Application, and for subscription
billing purposes, if applicable. With respect to our Handheld Products, for example,
we may use such information, among other things, to ensure that your handheld device
is supported and that it has enough room for the Application, and to confirm which
versions of the Application’s files are installed on your device.

If you become a member of our Website, we may use your information to send you a
welcoming email that may confirm your username. If you “opt-in” (for example, if
you check a box, or if the box is pre-checked, you do not opt out by unchecking
the box) we may send you electronic newsletters, contact you about products, services,
information and news that may be of interest to you, and provide you with targeted
feedback. If you no longer desire to receive these communications, we will provide
you with an option to change your preferences. In addition, if you identify yourself
to us by sending us an email with questions or comments, we may use your information
(including Personally Identifiable Information) to respond to your questions or
comments, and we may file your questions or comments for future reference. We may
also use the information collected to contact you about important service announcements
and updates regarding our Website or Application or, if you are a subscriber, about
your billing account status. You will not be able to opt-out of these service announcements
and updates as they contain important information relevant to your use of our Website
and/or our Application and are not promotional in nature. (If you do not wish to
receive these service announcements, you may cancel your account with us and delete
the Personally Identifiable Information maintained about you on our systems by contacting
our Privacy Coordinator at the address set out below.)

We may also use the information gathered on our Website and through our Application
to perform statistical analysis of user behavior, to analyze and evaluate issues
relating to health and lifestyle, or to evaluate and improve our Website and Application.

WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

Except as set forth in this Privacy Policy or as specifically agreed to by you,
we will not disclose any information we gather from you on our Website.

Research Affiliates

We may disclose information (including Personally Identifiable Information) about
you to our Research Affiliate, PMRI. PMRI is a non-profit organization that reviews
the data collected on our site and application to help us improve our site and application
and to determine the effectiveness of The Ornish SPECTRUM in supporting sustainable
lifestyle changes.

Laws and Legal Rights.

We may also disclose your information (including Personally Identifiable Information)
if we believe in good faith that we are required to do so in order to comply with
an applicable statute, regulation, rule or law, a subpoena, a search warrant, a
court or regulatory order, or other valid legal process. We may disclose Personally
Identifiable Information in special circumstances when we have reason to believe
that disclosing this information is necessary to identify, contact or bring legal
action against someone who may be violating our Terms & Conditions or our Subscription
Agreement, or to protect the safety and/or security of our users, our Website or
the general public.

Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, “Outside
Contractors”) to provide specific services and products related to our Website or
Applications, such as providing payment processing and fraud screening, and developing
applications for our Website and e-mail services. These Outside Contractors may
sometimes have limited access to information collected on our Website, including
your Personally Identifiable Information, in the course of providing products or
services to us. Access to your Personally Identifiable Information by these contractors
is limited to the information reasonably necessary in order for the Outside Contractors
to perform their limited function for us. We also require that these Outside Contractors
(i) protect the privacy of your Personally Identifiable Information consistent with
this Privacy Policy, and (ii) not use or disclose your Personally Identifiable Information
for any purpose other than providing us with products or services for which we contracted.

Sale of Business.

We reserve the right to transfer information to a third party in the event of a
sale, merger or other transfer of all or substantially all of the assets of The
Ornish SPECTRUM Inc. provided that the third party agrees to adhere to the terms
of this Privacy Policy. We will notify users of any such transfer through notice
on our site and through email.

DOES THIS PRIVACY POLICY APPLY WHEN YOU LINK TO OTHER WEBSITES?

Our Website does not currently contain links to third party websites.

IS THE INFORMATION WE COLLECT SECURE?

We want your information (including Personally Identifiable Information) to remain
as secure as possible. We strive to provide secure transmission of your information
from your computer to our servers through industry-standard techniques. To help
ensure the integrity and privacy of the Personally Identifiable Information you
provide to us via the Internet at the time you elect to become a registered user
or subscribe to our Online Products, we use Secured Socket Layer (SSL) encryption
technology in transmitting such Personally Identifiable Information over the Internet
to our servers. We secure the Personally Identifiable Information you provide on
servers located in controlled, secure environments, protected from unauthorized
access, use, or alteration. Only employees who need access to your information to
perform a specific task or function are granted access to such information. In addition,
all employees must abide by this Privacy Policy and are kept up-to-date on security
practices. Any employee who violates this Privacy Policy is subject to disciplinary
action, up to and including termination.

Notwithstanding the above commitments to protect your information (including Personally
Identifiable Information) from loss, misuse or alteration by third parties, you
should be aware that there is always some risk involved in transmitting information
over the Internet. There is also some risk that others could find a way to thwart
our security systems. As a result, while we strive to protect your information,
we cannot ensure or warrant the security and privacy of any information you transmit
to us, and you do so at your own risk.

WHAT CHOICES DO YOU HAVE REGARDING THE COLLECTION, DISCLOSURE AND DISTRIBUTION OF
PERSONALLY IDENTIFIABLE INFORMATION?

Except as otherwise described in this Privacy Policy, we will only use Personally
Identifiable Information for the purposes described above or as otherwise disclosed
at the time we request such information from you. You must “opt-in” and give us
permission to use your Personally Identifiable Information for any other purpose.
You may change your preference and “opt-out” of receiving other communications by
changing that option in the My Profile feature of our Website, following the directions
provided in association with the communication.

Users of our Website are notified when Personally Identifiable Information is being
collected by third parties on our Website. We do this so you can make an informed
choice as to whether you should disclose information to a third party.

CAN YOU UPDATE OR CORRECT YOUR PERSONALLY IDENTIFIABLE INFORMATION?

You can always contact us in order to (1) update or correct your Personally Identifiable
Information, (2) change your preferences with respect to communications and other
information you receive from us, or (3) delete the Personally Identifiable Information
maintained about you on our systems, by accessing My. Such updates, corrections,
changes and deletions will not have an effect on other information that we maintain,
or information that we have provided to third parties in accordance with this Privacy
Policy prior to such update, correction, change or deletion.

You should be aware that it is not technologically possible to remove each and every
record of the information you have provided to us from our systems. The need to
back-up our systems to protect information from inadvertent loss means that a copy
of your Personally Identifiable Information may exist in a non-erasable form that
will be difficult or impossible for us to locate. We promise that promptly after
receiving your request, all Personally Identifiable Information stored in databases
we actively use and other readily searchable media will be updated, corrected, changed
or deleted, as appropriate, as soon as reasonably practicable.

HOW WILL YOU KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

If we decide to change this Privacy Policy, we will post those changes on our Website
so you are always aware of what information we collect, how we use it, and under
what circumstances, if any, we disclose it. If at any point we decide to use Personally
Identifiable Information in a manner significantly different from that stated in
this Privacy Policy, or otherwise disclosed to you, at the time it was collected,
we will notify you by email or otherwise, and you will have a choice as to whether
or not we use your Personally Identifiable Information in the new manner. We may
also make non-significant changes to our Privacy Policy that generally will not
affect our use of your Personally Identifiable Information. If you do not agree
to the terms of this Privacy Policy, you should not use our Website.

WHOM DO YOU CONTACT IF YOU HAVE ANY PRIVACY QUESTIONS?

If you have any questions about our Privacy Policy or feel that we are not abiding
by the terms of our posted Privacy Policy, please contact our Privacy Coordinator
in any of the following ways:

Email our Privacy Coordinator at:

info@ornishspectrum.com

If you do not receive acknowledgment of your inquiry or your inquiry has not been
satisfactorily addressed, you should then contact
TRUSTe at http://www.truste.org/consumers/watchdog_complaint.php,
by postal mail at Watchdog Complaints, TRUSTe, 55 Second Street, 2d Floor, San Francisco,
CA 94105, or by fax at (415) 520-3420. TRUSTe will then serve as a liaison with
us to resolve your concerns.

BY USING OUR WEBSITE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU
DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR WEBSITE. YOUR CONTINUED
USE OF OUR WEBSITE FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL
MEAN THAT YOU ACCEPT THOSE CHANGES.

Last modified as of August 17, 2010