Privacy Policy

Last updated: July 29, 2025

Outliers has recently updated its privacy policy to clarify our personal information practices in the US. Residents of certain states, such as California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia, may have additional personal information rights and notices. Please see the “U.S. State Privacy Notice” section below for more information.

INTRODUCTION AND SCOPE OF THIS PRIVACY POLICY

This Privacy Policy (“Policy”) describes how Outliers, Inc. ("Outliers" or "we", "us", or "our") collects, uses, and discloses personal information. This Policy applies to those Outliers websites and applications that display or link to this Policy (referred to in this Policy as the “Website”). This Policy also applies to other services that display or link to these terms. This Policy outlines the following:

Information We Collect & Process
How We Collect Personal Information
How We Use Personal Information
Use Of Cookies and Other Tracking Technologies
How We Share Your Personal Information
Privacy Rights and Choices
Contact Us
Other Privacy, Security and Legal Information
Changes to this Policy
U.S. State Privacy Notice
EU and UK Data Subject Notice
FDA Notice

1. INFORMATION WE COLLECT & PROCESS

We may collect or process the following types of personal information about you. The specific personal information we collect about you will vary depending on how you interact with us.

Basic Identifiers: Contact and account data, such as your full name, login credentials, email address, shipping and billing address, phone number, social media identifiers and handles.

Payment and Purchase Information. Information related to your purchases, such as your credit card information, bank account details, shopping cart details, order ID, purchase history, delivery details, and other payment information.

Usage Information. Information on your browsing and Website behavior and interactions with our marketing emails, such as browser name, IP address, timing of site visits, pages visited, clicked links in our marketing emails, the referral URL that brought you to our Website and information about traffic patterns and Website usage, such as clickstream data comprised of mouse movements, clicks, page scrolls and keystrokes.

Demographic Information. Characteristics such as your age, sex, gender, and ethnicity.

Geolocation Data. Information that permits us to determine your general location (e.g., your city or state), such as your IP address.

Inferences, Interests and Preferences. Information that indicates your preferences and opinions, whether that information is provided directly by you or inferred by us, such as, your product preferences, shopping history, and feedback you provide through product reviews, testimonials, surveys, and product testing.

Device Interactions. Information related to the device you use to access our website, such as your device ID, device fingerprint and operating system.

Social Media Interactions. Information about you we obtain through different social media channels such as Facebook, Instagram, Google, etc., when we use these channels for consumer engagement, advertising, sales, or analytics purposes or to enrich your customer profile with Outliers. For example, publicly available social media information, and photos and posts you send to us by mentioning us or following our social media posts by using “handles” or “hashtags.”

Communication data. Information related to your interactions with our customer service chat function on the Website, customer service teams, and/or our employees and personnel, such as written correspondence with us (such as emails or messages to the chat function) and phone calls.

Images and Recordings. Image, voice, and video recordings we have captured or obtained where you may be identified, such as audio in customer service call recordings, and images you share with us via social media.

Health-Related Information (Optional Quiz). Information regarding prescription medications or health conditions that you voluntarily provide if you choose to participate in our optional assessment quiz.

Other information that we may collect which is not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.

2. HOW WE COLLECT PERSONAL INFORMATION

We may collect personal information about you from various sources.

From You. We collect personal information you provide to us, for example:

If you make a purchase.
If you contact our customer service team, including through chat or by phone.
If you participate in a contest or sweepstakes, respond to a survey or register for our marketing lists or voluntarily complete our optional assessment quiz, including any health-related information you choose to share.

From Third Parties. We receive information about you from third parties, for example:

Our affiliate companies.
Our service providers, contractors and vendors (such as advertising networks, fraud prevention companies and analytics companies).
Online platforms and social media networks you use to interact with our ads, to interact with our influencers,
Business partners who have your permission to share your data with us, such as companies that have entered into joint marketing relationships with us.

Automatically. We automatically collect personal information about you when you interact with us, such as when you use visit or interact with our Website, open emails or view advertisements from us, or communicate with us. This automatically collected information often includes data categorized in Section 1 as Usage Information (e.g., IP address, browser type, pages visited, clickstream data) and Device Interactions (e.g., device ID, operating system). We may collect some of this personal information by using Cookies and other tracking technologies, and we recommend you review the “Use Of Cookies and Other Tracking Technologies” section.

3. HOW WE USE PERSONAL INFORMATION

We use each category of personal information we collect for the following purposes:

To Sell and Deliver Products.

Process orders, provide payment options, deliver and track orders, provide exchanges and refunds.

To Operate the Website.

Improve the functionality of the Website, and debug, identify and repair errors that impair the intended functionality of the Website.
Monitor compliance with our terms and conditions.
Detect and prevent security threats to our domain.

To Improve Your Shopping Experience.

Display items of interest based on prior interactions.
Encourage and enable purchases.

To Enhance the Safety and Security of The Website.

Detect and investigate fraud, illegal and unauthorized activities.
Detect and investigate security incidents.

To Provide Customer Service.

Answer your questions through various communication channels (including chat and phone).
Use recorded customer service phone conversations and stored chat transcripts for quality assurance, training, trouble shooting and other business purposes.
Evaluate our customer service and customer service channels to improve their quality and functionality.

To Display Targeted Ads and For Marketing and Advertising Purposes.

Send you general and personalized marketing messages via email based on our information about you, your interests and your interactions with us. You can unsubscribe from marketing emails. For instructions on how to do this, refer to the section "Privacy Rights and Choices"
Show you targeted ads on third-party websites and advertising platforms such as Facebook, Google, YouTube, Instagram, etc.
Notify you when an item is back in stock.

To Create Profiles.

We may combine the information we collect about you from different sources to create a profile about you and to infer your interests, preferences, shopping habits and other behaviors.
We may also use your information to create a profile for fraud-prevention and investigation purposes.

To Improve Our Products and Services.

Collect and review analytics about the Website, from social media platforms and our business to understand how our products are selling, identify popular product features, analyze our marketing and advertising campaigns, our product designs and distribution strategy, our Website design and overall user experience.
We also analyze survey, product testing and focus group results, videos and feedback to help us improve our products, services and marketing efforts.
We may ask our service providers to conduct market and product research for us.

To Comply with Legal and Safety Obligations

Access and use your personal information, including the content of your communications, in order to:

Comply with the law or respond to lawful requests or legal processes.
Protect the rights or property of Outliers or our customers, including the enforcement of our agreements or policies governing your use of our Websites and services.
Protect the personal safety of our employees, customers or the public.

We may keep some personal information as evidence in case of a dispute, complaint, or audit.

For Other Business Purposes

We use Usage Information to detect and investigate fraud and to provide statistical information to our partners and other third parties about how our users collectively use the Website.

4. USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

As is common with many websites, we use cookies, tags, pixels, beacons, and other tracking technologies (collectively referred to as “Cookies”). Cookies are small files placed on your computer’s hard drive by your browser, allowing the Website to recognize you, as well as remember your actions and preferences (such as language settings, font size, and other display preferences) over time. This allows us to optimize the shopping experience, hold selections in a shopping cart when a user leaves the Website without checking out, and send you a reminder e-mail or SMS campaigns about your shopping orders and other shopping opportunities. We also use Cookies to gather statistical information about use of the Website in order to improve its design and functionality, understand how the Website is used, and assist us with resolving questions.

We use third party analytics service providers, including Google Analytics and Google AdWords on the Website to collect Usage Information, to analyze how users use the Website—such as time spent on the website, pages visited, cart details, mouse clicks, keystrokes, purchases, and other interactions—and to provide advertisements to you on other websites. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout/.

Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Website. We may also use Cookies or other technologies in online advertising to track responses to our ads. We use third-party companies to measure and target ads on our behalf about products and services tailored to your interests. Most browsers accept Cookies automatically but allow you to disable them or be given the choice of declining or accepting a particular Cookie (or Cookies) from a particular website. You may also visit www.aboutads.info/choices/ and http://optout.networkadvertising.org/#/.

We disclose personal information to certain third parties in the following circumstances:

Service Providers. We may share your personal information with third party companies and individuals that provide services to us or on our behalf, for example entities that process credit card payments, fulfill orders, and that provide website and application functionality, hosting, analytics, customer support, email delivery, marketing, advertising measurement, and database management services.
Advertising Partners. We may share your personal data with third party advertising companies, including for the targeted advertising described above. For details on the third parties that may place Cookies through our Sites, and information on your choices regarding Cookies, please see the “Use Of Cookies and Other Tracking Technologies” section.
Business Partners. We disclose personal information to select business partners with your consent or at your direction (for example, if you allow them to contact you about their products, services or offers).
Professional Advisors. Our legal, financial, insurance, and other advisors in connection with the kinds of corporate transactions described below or in connection with the management of all or part of our business or operations.
Authorities and Others. We may share your information to comply with legal processes (including to comply with the law, to enforce our Terms of Service, or to respond to subpoenas, discovery requests, or similar legal processes or proceedings), cooperate with law enforcement or when we believe it is prudent to share information with legal authorities, and investigate and prevent fraud or imminent harm to you, our users, or to us. We may also share your information to ensure the security of our network and services.
Business Transferees. Another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy or we go out of business. User information is generally considered an asset that is transferred in one of these types of corporate transactions.
Content You Post. Any information you decide to post to public areas of the Website, such as message boards and feedback sections, becomes publicly available.
SMS Subscription Status. We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

6. PRIVACY RIGHTS AND CHOICES

Personal Information Rights. Depending on applicable laws, you may have rights with respect to your personal information. For example, you may be able to request access to the personal information we maintain about you, update and correct inaccuracies in your personal information, and have the personal information deleted or transmitted to a third party. You may request to access, change, or delete your personal information by contacting [email protected].

Depending upon the applicable law, access to your rights may be denied, such as: (a) when denial is required or permitted by law; (b) when granting access would have a negative impact on another’s privacy; or (c) to protect our rights and properties.

We may take reasonable steps to verify your identity when you make a request. You may also have the right to lodge a complaint with a data protection authority.

If you are a California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Nevada, Oregon, Texas, Utah, Virginia or Washington resident, the law may provide you with additional rights regarding our use of your personal information. Please review the “U.S. State Privacy Notice” section to learn more about these rights.

Marketing Communications. We provide you with several newsletters, including:

When you get a marketing email, click the “unsubscribe” button at the bottom of the email; or

For any other promotional communications, use the opt-out instructions contained in that communication.

If you opt out, we may still send you non-promotional messages, such as those about your purchases or our ongoing business relations.

Opting Out of Targeted Advertising, "Selling" and "Sharing". As described in the “Use Of Cookies and Other Tracking Technologies” section, Outliers engages third-party advertisers to provide interest-based advertising on our website, as well as other third-party websites in order to display advertising that is relevant to you. These third parties may collect information about your use of our services over time and that information may be combined with information collected on different websites and online services. These third-party advertisers may be participants in the Network Advertising Initiative and/or the Self-Regulatory Program for Online Behavioral Advertising, which allow users to opt out of ad targeting from participating companies. To learn more about interest-based advertising, or to opt out of having your web browsing information used by certain third-party advertisers for behavioral advertising purposes, go to: www.aboutads.info/choices or https://www.networkadvertising.org/choices/.

If you “opt out” of receiving targeted advertising, you may still see ads for Outliers on third-party websites and services, but they may be less relevant because they aren't based on your interests.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com/. If you wish to disable cookies on our Platform, you should not rely on any “Do Not Track” feature your browser might have.

Limits on Your Rights and Choices

In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a feature of our Website or services you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may contact us as provided in the “Contact Us” section below.

Non-Discrimination

We will not discriminate against you if you choose to exercise your privacy rights.

7. CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at [email protected] or by mail using the details provided below:

Outliers, Inc.

Attention: Thesis

30 W 24th Street

Floor 11

New York, NY 10010

(646) 647-3599

8. OTHER PRIVACY, SECURITY AND LEGAL INFORMATION

Children.

Our Website is not directed at children, and we do not knowingly collect or solicit personal information from children under 18. If you are a parent or guardian and believe that we have information about your child, please contact us as described in the Contact Us section above.

Security

We use reasonable security procedures to protect your information. However, no data transferred over the Internet is guaranteed to be 100% secure. Personal information collected at our Website is stored in reasonably secure operating environments that are not available to the public.

Consent to Data Processing in the United States

The Website that links to this Policy is intended for users in the United States. If you choose to provide Outliers with your information, you consent to the transfer and storage of that information on our servers located in the United States and around the world. The information collected by Outliers may be subject to international and U.S. state and federal law. If you are accessing our Website from outside the U.S., please be advised that you are transferring your personal information to us in the United States where data protection and privacy laws may be different than the laws of your country. By using our Website, you consent to the transfer and use of your personal information in accordance with this Policy.

Other Sites and Services

Our Website may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions

9. CHANGES TO THIS POLICY

We may change this Policy at any time. If we post changes to this Policy, we will revise the “last updated” date at the top. Policy and posting it on our Website. If there are material changes to this Policy or to how Outliers will use your personal information, we will provide you with additional notice, such as by adding a statement to the Website or sending you a notification. We encourage you to review this Policy regularly to remain informed about our information practices and the choices available to you.

10. U.S. STATE PRIVACY NOTICE

California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). If you are a resident of one of these states, this section applies to you.

Additional Disclosures

Our Policy explains how we collect, use, and disclose information about you, as well as our targeted advertising and analytics practices. However, certain State Laws require we restate some of this information for specific categories. The type of personal information we collect and how we handle that personal information, including if we share or sell that personal information, depends on how you are specifically interacting with us, our Website, and products. In general, we have collected, disclosed for a business purpose, and sold or shared the following categories of personal information and sensitive personal information from consumers within the last 12 months:

Categories of Personal Information Collected, Disclosed for a Business Purpose, and “Sold” or “Shared”

Categories of Personal Information	Examples as defined in certain State Law	Collected	Disclosed	“Sold” or “Shared”
A. Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	✓	✓	✓
B. Personal information categories listed in the California Customer Records statute, Cal. Civ. Code § 1798.80(e)	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	✓	✓	✓
C. Protected classification characteristics under California or federal law	Age, 40 years or older; race; color; ancestry; national origin; citizenship; religion or creed; marital status; medical condition; physical or mental disability; sex, including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions; sexual orientation; veteran or military status; or genetic information, including familial genetic information.	✓	✓	✓
D. Commercial information	Records of personal property; products or services purchased, obtained, or considered; or other purchasing or consuming histories or tendencies.	✓	✓	✓
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints; iris or retina scans; keystroke, gait, or other physical patterns; and sleep, health, or exercise data.	✓	✓	✓
F. Internet or other similar network activity	Browsing history, search history, or information on a consumer's interaction with a website, application, or advertisement.	✓	✓	✓
G. Geolocation data	Physical location or movements.	✓	✓	✓
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	✓	✓	✓
J. Non-public education information, per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	✓	✓	✓
K. Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	✓	✓	✓
L. Sensitive personal information	Social security, driver’s license, state identification card, or passport number; user name, 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; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; contents of consumer’s mail, email, and text messages unless Outliers is the intended recipient of the communication; processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation; or citizenship and immigration status.	✓	✓	✓

Table Key (Activities in the Past 12 Months)

Collected: ✓ indicates we collected this category of personal information. Collection methods are described in the "How We Collect Personal Information" section.

Disclosed: ✓ indicates we disclosed this category for the business and commercial purposes outlined in the "How We Use Personal Information" section.

Sold or Shared: ✓ indicates we disclosed this category for cross-context behavioral advertising purposes, mainly to advertising partners, analytics providers, operating systems/platforms, and social networks.

Other Information About our Information Practices

We process personal information that is considered “sensitive” under certain State Laws. For example, we collect health-related information (such as prescription medication usage) if you voluntarily provide it through our optional assessment quiz. You may also self-disclose sensitive demographic information, such as sexual orientation and ethnicity, if you choose to participate in customer surveys and focus groups that help us provide and improve our products and services for a diverse range of individuals. We only collect this information with your consent or at your direction and for purposes permitted under the State Laws.

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

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 personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Additional Privacy Rights

If you are a California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia resident, you may have certain rights regarding your personal information pursuant to specific state law, including:

Right to Know and Access. You may have the right to know and access what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, the categories of personal information disclosed to third parties, and the specific pieces of personal information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of personal information more than twice in any 12-month period.

Right to Request List of Third Parties. You may have the right to request a list of the specific third parties with whom we have shared or sold any personal information.

Right to Request a List of Categories of Third Parties. You may have the right to request a list of the categories of third parties to which we have disclosed personal information.

Right to Data Portability. You may have the right to request your information in a portable, readily usable format.

Right to Delete. You may have the right to request we delete personal information that we have collected from or about you, subject to certain exceptions.

Right to Correct. You may have the right to request we correct inaccuracies in the personal information we maintain about you, subject to certain exceptions.

Right to Opt-Out. We use and disclose to third parties personal information for analytics and advertising purposes. Accordingly, you may have the right to opt out of the “sale” and "sharing” of your personal information, or the use and disclosure of your personal information for “targeted advertising” (as these terms are defined under applicable law).

Right to Withdraw Consent. Where our processing of your personal information is based solely on your consent (such as consent obtained for sharing sensitive health information from our quiz, if applicable, or for certain marketing communications), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing based on consent before its withdrawal.

Right to Appeal. You may have the right to appeal our refusal to act or a decision we made in relation to your request.

Exercising Your Rights. You can exercise privacy rights described in this section by submitting your data privacy request using one of the following designated methods:

Through the following links:

To submit a sale or targeted advertising opt out, or to exercise another Consumer Right, email us at [email protected]

Write to us at the physical address listed above in the “Contact Us” section.

We will not discriminate against you if you decide to exercise your privacy rights.

Please note that, where permitted under applicable law, we may decline a request (other than for opt outs) if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the personal information we maintain relates to you.

Verification. In order to protect your personal information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete personal information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional personal information for verification. If we cannot verify your identity, we will not be able to honor your request (other than for opt outs).

Authorized Agents. Only you, or someone legally authorized to act on your behalf, may submit a request related to your personal information.

Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.

Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights. To appeal a decision, please contact us at [email protected].

California Shine the Light Law. California law permits residents of California to request certain details about how their information is disclosed to third parties for direct marketing purposes. Under the law, a business must either provide this information or permit California residents to opt in to, or opt out of, this type of disclosure. We qualify for this alternative option. To opt out of having information about you disclosed to third parties for direct marketing purposes, please email us at [email protected].

Supplemental Notice for Nevada Residents: We generally do not disclose or share personal information for profit. If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. To exercise this right, if applicable, you or your authorized representative may submit a request to [email protected]. If you have any questions, please contact us at [email protected]. We will respond to your verified request as soon as reasonably practicable, but no later than sixty (60) days after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response. The following health data disclosures are provided to Nevada residents: We collect health data about you when you directly engage with us by answering an optional question about your medication usage as part of the quiz offered on our website. We use this information to suggest products and services to you. We do not sell this information or share it with third parties for their independent use. We may disclose it to trusted service providers who process the data solely on our behalf to operate the quiz functionality and provide related services, subject to strict confidentiality agreements. You have a right to submit a request for access, deletion, and appeal regarding this information. To exercise these rights, please send an email to [email protected]. Notification of material changes will be provided as outlined in the “Changes to this Supplemental Notice” section below.

Supplemental Notice for Washington State Residents: If you are a Washington resident, the following disclosures are provided to you pursuant to the Washington MY Health MY Data Act: We collect health data about you when you directly engage with us by answering an optional question about your medication usage as part of the quiz offered on our website. We use this information to suggest products and services to you. We do not sell this information or share it with third parties for their independent use. We may disclose it to trusted service providers who process the data solely on our behalf to operate the quiz functionality and provide related services, subject to strict confidentiality agreements. You have a right to submit a request for access, deletion, and appeal regarding this information. To exercise these rights, please send an email to [email protected].

11. EU AND UK DATA SUBJECT NOTICE

You can exercise the following rights by contacting Outliers at : (i) the right to be informed; (ii) the right of access; (iii) the right to rectification and correction; (iv) the right to erasure; (v) the right to restrict processing and sharing; and (vi) the right to object.

Before processing the request, we may need to ensure the identity of the person making the request to avoid sharing data with an unauthorized person and may request additional information from you. As a European or United Kingdom Citizen, you have the right to file a complaint with a European Union supervisory authority, (or the Information Commissioner’s Office (ICO) if you are a resident of the United Kingdom), in the event you have reasonable doubt that we are not processing your personal information in compliance with applicable law and GDPR, or UK-GDPR. In such a case, we are asking you to contact us first by sending to [email protected] and we will make our best efforts to reply promptly.

12. FDA NOTICE

FDA Inspections of Website Content

FDA investigations are limited to informing the soundness of agency decision making. See FDA Investigations Operations Manual, Chapter 8, available at https://www.fda.gov/media/75268/download#page=4. Pursuant to Chapter 4 of the FDA Investigations Operations Manual, the FDA can conduct investigations using publicly-accessible information without needing to supply a Form 482, notice of inspection. See e.g. https://www.fda.gov/media/96838/download.

However, under the Investigations Operations Manual, “if during a sample collection, [the FDA investigators] begin to conduct an inspection (examining storage conditions, reviewing records for compliance with laws and regulations, etc.), issue an FDA 482 and continue your activities.” FDA Investigations Operations Manual, Subchapter 4.1.1.1 (2021), available at https://www.fda.gov/media/75243/download#page=4. Pursuant to subchapter 4.1.4.2 of the FDA Investigations Operations Manual, the FDA’s collection of a documentary (“DOC”) sample from an Internet website of a regulated article constitutes an inspection for which a Form 482 must be issued. Id., available at https://www.fda.gov/media/75243/download#page=5.

Notice to the Food and Drug Administration

The FDA is permitted to collect information from this site for the limited purpose of informing the soundness of its decision making. FDA, Investigations Operations Manual (2022), https://www.fda.gov/media/75268/download#page=4. If, however, the FDA decides to collect information from this site for the purpose of reviewing information for compliance with laws and regulations, the FDA must issue the company a Form 482 notice of inspection. Id. at https://www.fda.gov/media/75243/download#page=5.