Spa Technologies respects our customers’ privacy needs and concerns. Any personal information, such as your name, address, email address or phone number that you provide to us is important to us. To earn your on-going trust, we respect your privacy in handling Personal Information, whether at our Call Center, through theharmonycompany.com, or one of our related Internet websites. This Privacy Statement provides information regarding the Personal Information we collect, what we do with it, the safeguards we have put in place to protect it, and how you can control our use of it. By using our website, the user agrees, without limitation or qualification, to be bound by this Privacy Statement.

When you provide Personal Information at our Call Center, or on our website, you are consenting to the manner in which Spa Technologies will collect, use, disclose and otherwise manage your Personal Information, as set out below.

Who May Use the Website: The website is not intended or designed to attract users under the age of 18. We do not collect Personal Information from any person we know to be under the age of 18. If you are under 18, do not send us any Personal Information.

The website is intended for users from the United States and those not governed by privacy policies of other countries. Users from the European Union are advised not to disclose Personal Information to Spa Technologies. Information sent to us will be housed on servers located in the United States. Do not send us information unless you consent to the application of U.S. law and to the use and disclosure of your information consistent with this Privacy Statement.

Collection and Use of Personal Information: We may collect Personal Information that you provide to us when you:

• Purchase, order, return, exchange or request certain information about our products and services;

• Contact a Call Center or customer service desk;

• Visit or register with our website or participate in another feature of our website;

• Enter into a contest or sweepstakes or respond to one of our surveys; or

• Provide us with comments or suggestions.

• We may also collect Personal Information about you from our Service Providers who provide us with e-commerce related services related to the website.

Shopping at Spa Technologies: If you use a credit or debit card for any of your purchases, we will collect your credit or debit card information and keep a history of your purchases. We use this information to process your orders and to better assist you when you call us. We may also ask for your zip code as well, to help us improve our product and service offerings to your area.

When you return previously purchased merchandise or request a refund or exchange, you may be asked to give your name, address, phone number and show information that identifies you. We collect this information to help prevent fraud.

Call Center: When you call our Call Center about a product, delivery, billing question or for customer service, you may be asked for Personal Information that identifies you along with additional information we need to help us promptly answer your question, such as your name and address and a phone number where we might contact you. We may retain this information to assist you in the future.

Website Registration: Registration is an optional service provided by our website. You do not have to register to browse on our website, but you do have to register to purchase products on our website. When you register, you are asked for information such as your name, address, phone number, e-mail address, a password that you select, and your interests, if you choose to register them. Your registration information may be used to help make your online shopping quicker and easier, by pre-filling certain parts of your shopping information.

Contests, Questions or Surveys: When you ask a question, participate in a survey or enter a contest or sweepstakes at a Company sponsored event or through our website, we may collect your name, address, phone number and e-mail address. We use this information to administer your participation in a contest or sweepstakes. At the time you are entering a contest or sweepstakes, we may ask your permission to send you future marketing information from Company.

Other Uses of Personal Information: Company also uses Personal Information, including information provided to us from our Service Providers, to continually assess and improve the products and services we offer. To serve you better, we may combine the Personal Information that you give us with publicly available information and information we receive from or cross-reference with our marketing partners and others. We use that combined information to enhance and personalize your shopping experience with us, to communicate with you about our products and events that may be of interest to you, and for other promotional purposes.

Promotional Information and Marketing Materials: We would like to inform you of products and services, sales and special offers that might benefit you. When you register online or participate in a survey, you will have the opportunity to sign up for e-mails about our products, services, sales, and special offers.

We may also send you mail, email or call you with information about our product and service offerings if you have provided us with your name and address, e-mail address or phone numbers.

Disclosure of Personal Information: We enter into marketing relationships with advertisers or other companies that provide products or services that we believe may be of interest to Company customers. We will share your Personal Information with those marketing partners in order to help them send you information that we believe will be of interest to you. We may share non-identifiable aggregated information with these companies. We will not disclose your telephone number, credit card account information or e-mail address for these purposes. We may also provide Personal Information to any of our affiliated businesses.

Access to Personal Information by Companies that Work with or on Behalf of Company: Some of our operations, such as our electronic commerce, may be managed by Service Providers who are unaffiliated companies. These companies may share Personal Information with their affiliates and with service providers whom they engage to perform services related to our website or the operation of our business. Examples of these services include payment processing and authorization, fraud protection and credit risk reduction, product customization, order fulfillment and shipping, marketing and promotional material distribution, website evaluation, data analysis and, where applicable, data cleansing. These companies may have access to your Personal Information on a confidential basis only to the extent necessary to perform their functions. In no event will we authorize these companies to use your Personal Information for any reason other than to provide you with those specific services.

If your purchases are being shipped to you, your shipping information will be shared with our delivery service providers (U.S. Postal Service, UPS, or other delivery companies we or you select). Our delivery service providers are asked not to use your Personal Information for any purpose other than making the delivery.

Sale of Business: In the event that Company or some of our assets are sold or transferred or used as security, your Personal Information may be transferred to third parties as part of that transaction.

Disclosures of Personal Information in Legal Proceedings: If Company or any of our Service Providers is requested by law enforcement officials or judicial authorities to provide Personal Information on individual users, Company or the applicable Service Provider may, without your consent, provide such information. In matters involving claims of personal or public safety, Company or the applicable Service Provider may provide your Personal Information to appropriate authorities without your consent or court process. Company or our Service Providers also will provide your Personal Information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or in litigation involving Company, the applicable Service Provider, or otherwise as required by law. We may also disclose Personal Information to assist in debt collection where you owe a debt to us.

Additional Information about Our Website

Visiting Our Website: In general, you can visit our website without telling us who you are or providing us with any information. However, we collect the IP (Internet protocol) addresses of all visitors to our website and other related information such as page requests, browser type, operating system and average time spent on our website. We use this information to monitor and improve our website.

Cookies and Tracer Tags: Our website use a technology called “cookies.” A cookie is a tiny element of data that our website can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. All pages on our website where you are prompted to log in or that are customizable require that you accept cookies. If you have registered with our website, these cookies (1) may let us know who you are, (2) are necessary to access your account information (stored on our computers) in order to deliver products and personalized services, and (3) will provide us and our Service Providers with information that we will use to personalize our website in accordance with your preferences. Cookies are also required to optimize your shopping experience in that they allow you to add multiple items to your shopping basket before checking out. You may set your web browser to notify you when you receive a cookie. However, should you decide not to accept cookies from our website, you will limit the functionality we can provide when you visit our website. Tracer Tags: Our website may also use a technology called “tracer tags”. These may also be referred to as “Clear GIFs” or “Web Beacons”. This technology allows us to understand which pages you visit on our website. These tracer tags are used to help us optimize and tailor our website for you and other future website visitors.

Security of Personal Information: We maintain administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control. We also are committed to employing reasonable technology in order to protect the security of our website. However, even with the best technology, no website is 100% secure. We will take reasonable measures which we believe are appropriate to protect your Personal Information from loss, misuse, alteration or destruction, and, where possible, will ask that any third parties to whom we may transfer such information to take comparable steps to protect that security.

Secure Shopping: When you place orders on our website, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our website from capturing and viewing your Personal Information. Since any order information you provide to us on our website will be transmitted using a secure connection, if your web browser cannot support this level of security, you will not be able to order products through our website. The most recent versions of Firefox, Safari and Internet Explorer can support a secure connection.

Passwords: To provide you with an increased level of security, online access to your Personal Information is protected with a password you select. We strongly recommend that you do not disclose your password to anyone. Company will never ask you for your password in any unsolicited communication (including unsolicited correspondence such as letters, phone calls or e-mail messages).

Our Privacy Statement and Outside Links: Our website may include links to the websites of our business partners, vendors and advertisers. These other sites are outside of our control. Please be aware that these websites may collect information about you, and operate according to their own privacy practices which may differ from those contained in our Privacy Statement. Remember to consult that website’s own privacy policy, as once you are outside any of the website, any information you submit is no longer in our control.

Privacy Statement Modifications: From time to time we may modify, amend, or update this Privacy Statement in order to comply with new laws or regulations, or to reflect future changes in our business practices. Any changes to our policies will be placed on this web page, so please check this web page on occasion. We also may post a notice on our website.