Effective as of August 23, 2024

At DTI GmbH (“Dr. Tobias”, “we”, or “us”), we take your privacy very seriously. We know you care how your information is used, and we appreciate your trust, so we treat your information carefully, sensibly, and responsibly. Dr. Tobias values the importance of privacy and security for our web site visitors. Please take a moment to read this Privacy Policy, which describes our data collection and usage policies and practices, including how we collect, use and share information about you, including in person, by phone, through mail or email or through our website drtobias.com, and any other Dr. Tobias-owned and/or operated website, mobile sites, mobile applications or social media accounts (collectively, our "Sites”). By accessing or using our Sites or otherwise disclosing information to Dr. Tobias, you agree that you are providing freely-given, specific, informed, and unambiguous consent to our collection, use, and sharing of your information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you must discontinue using our Sites.

If we decide to change our Privacy Policy, we will post those changes on our web site so that you can always find out what information we gather, and how we might use that information. We encourage you to periodically review our Privacy Policy to stay informed about how we are using the personal information we collect.

1. What Information Do We Collect?

Information You Provide Directly to Us

We collect information you provide directly to us in order to provide the best service possible. For example, we collect information when you: interact with Dr. Tobias in person, by phone, through mail or email, or through any website chat feature; request or purchase a product or service; register for an account; participate in any interactive features of the Sites; subscribe to a newsletter or email list; participate in a survey, contest, promotion or event; request customer support; or otherwise communicate with us. Categories of information we may collect from you include:

·   Account Information.  When you register for an account on the Sites, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include identifiers such as your name, email address, mailing address, username, and phone number. We also collect other information you provide as part of registration process and the administration and personalization of your user experience. We may combine this information with the personal information we collect from you.

·   Transaction Information.  If you choose to order products or services from us you will have to provide us with certain information, including personal information such as: your name, mailing and/or e-mail address, credit or debit card information.

·   Content You Submit.  We collect the content you submit to the Sites. This includes all comments, feedback or materials submitted by you to us, for example, feedback, testimonials, images, reviews, questions, comments, suggestions or ideas (“Feedback”). You acknowledge and agree that Dr. Tobias will be free to use, display, perform, distribute, copy, adapt, and promote, without compensation to you, the Feedback for any purpose whatsoever.

·   Surveys and Promotions. We may request information from you via surveys or promotions. Participation in these surveys or promotions, which might include contests or sweepstakes, is voluntary. Examples of requested information may include contact and demographic information.

Information We Collect Automatically

We and our third-party service providers or affiliates may use a variety of online tracking technologies, such as cookies, embedded scripts and web beacons, that automatically (or passively) collect certain information whenever you visit or interact with our Sites.

·   Usage Information. We collect information about your usage of, and interaction with the Sites. For example, we may track the number of people who view each page and all of the areas within our Sites you visit. We may also collect and store statistics and other information about the online activities of our users on an aggregated (collective) basis.

·   Log Information. When you access or use the Sites, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Site.

·   Information Collected by Cookies, Web Beacons and Embedded Scripts. We and our service providers use various tracking technologies, including cookies, web beacons and embedded scripts, to collect information about you when you interact with our Sites, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular, and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites. Web beacons are small pieces of data that are embedded in images on the pages of web sites. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy practices. We may use web beacons to bring together information we collect about you and to help us optimize and tailor our Sites for you and other future visitors to our Sites. An embedded script is programming code that is designed to collect information about your interactions with our Sites, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Sites, and is deactivated or deleted thereafter.

Information We Collect From Third Parties

We may receive information that third parties provide us, which may include information about you. For example, we may collect information about you when you engage third parties to assist in ordering our products or services, when we use third parties to validate or update your information or other third parties who offer services that integrate with the Sites. Additionally, we may collect information about you when you post content to our pages or feeds on third party sites. This Privacy Policy does not apply to information collected through or by any third party. If you have any questions about such third parties’ privacy practices, you should review their privacy policies.  

2. How Do We Use Your Information?

We may use your information for various purposes related to our operations and your use of the Sites. For example, we may use your information:

·   To personalize the user content and experience.

·   To provide, maintain and improve our Sites and provide you with relevant information and content.

·   To facilitate and administer the provision of the products and services you purchase or request from us, including the verification of your identity or location, processing payment, to respond to any communications from you, or to administer a survey, promotion, sweepstakes or contest you participate in.

·   To contact you in connection with your account, a particular activity, purchase, or product or service, in person or by recorded message, by e-mail, telephone and/or mobile telephone number, text (SMS) message, or any other means of available communication.

·   To notify you in connection with a survey, promotion, sweepstakes or contest.

·   To provide you with information and offers on our products and services, that we believe may be of interest to you.

·   To send you technical notices, updates, security alerts and support and administrative messages.

·   To respond to your comments, questions and requests and provide customer service, including through any website chat function, whether automated or not.

·   To monitor and analyze trends, usage and activities in connection with our Sites.

·   To protect our rights and property and the rights and properties of others.

·   To maintain appropriate records for internal administrative purposes.

·   To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites and identifying usage trends.

·   To link or combine with information we get from others to help understand your needs and provide you with a better experience.

·   To carry out any other purpose described to you at the time the information was collected.

·   To comply with legal and regulatory requirements (including fraud prevention and anti-money laundering), required disclosures and choices and controls that may be available.

·   To comply with our obligations to third parties in accordance with the terms and conditions of their services being provided on our behalf or directly to you.

·   Detect, investigate or prevent activity that may be illegal, violate our policies, cause harm to our operations or compromise our security.

·   To carry out debt-recovery functions.

·   For any purpose that, under the circumstances, would be reasonably expected by a consumer to be employed.

·   To train our staff.

·   For any other purpose with your consent.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you. Once de-identified and aggregated so that data does not personally identify you, it is no longer personal information. Such de-identified and/or aggregated information which does not identify individuals is not subject to this Privacy Policy.

Electronic Promotional Messages. We may send you promotional emails regarding special offers about our or our affiliates’ products and services or products and services on behalf of third party marketing partners who we think can offer products, services or content of interest to you. If you do not wish to receive information from us regarding special promotions or offers you can opt out of receipt of such promotional mailings (please see “Your Choices” below).  Even if you opt out of receiving promotional emails we may continue to send you transactional notifications that are related to your account, orders, or other products or services you have requested.

Direct Mail Promotional Offers.  We may use your name and mailing address which we obtain from you for us, our affiliates or third party marketing partners to provide marketing offers to you through direct mail. If you prefer not to have your name and mailing address shared with a third party in connection with direct mail promotional messages please see “Your Choices” below. Please note that even if you opt out of receiving promotional mail we may continue to send you transactional notifications in the mail that are related to your account, orders, or other products or services you have requested.

Third Party Analytics Services. We may work with certain third party service providers to collect, analyze, and use some of the information collected from you. For example, we may allow our service providers to set cookies or use web beacons on the Sites or in email communications from us, including Google, Inc.’s Google Analytics and AdWords services, Commission Junction LLC, and other similar third-party vendor services. These services use cookies to transmit your IP address and other website navigation and Internet usage and network activity data and device and browser-generated data, including regarding your browsing history and your interaction with our and other websites, applications, and advertisements. These service providers may provide this data to us or store and/or aggregate this data to analyze such usage and create reports for us. These service providers may also display our ads on sites across the Internet, and they may use this data to later display ads or other information to you based on your website usage or other information collected as described above. You may be able to set your browser to remove or reject browser cookies.

We do not control these third party service providers’ tracking technologies or how they may be used.

3. Who Do We Share Information With?

We may share information about you as follows or as otherwise described in this Privacy Policy:

·   With vendors, consultants, business partners, our related entities, contractors, or service providers to help us operate our business and the Sites and to administer activities on our behalf, and to assist with services such as data processing and matching, data analysis, data monetization services, information broking, business consulting, and marketing/research.

·   With strategic partners who provide additional features on the Sites. These strategic relationships may include business partners, sponsors and co-branded Site features. The use of your information by these third parties is subject to their own privacy practices and you should check their website for information regarding their privacy policies.

·   By participating in any survey, promotion, sweepstakes or contest, you agree to the official rules that govern that survey, promotion, sweepstakes or contest, including disclosure of your information to third parties or the public in connection with the administration of such survey, promotion, sweepstakes or contest, or as required by law.

·   As may be permitted or required by law (including, but not limited to, court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms of Use, or activity that appears to us to be illegal or may expose us to legal liability.

·   In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process.

·   As determined necessary to protect the rights, safety, or property of any person or as otherwise appropriate when we believe your conduct on the Sites is inappropriate, is detrimental to us, or is inconsistent with generally accepted norms of behavior.

·   In the event that we, or any of our businesses, are being sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership.

·   In connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding.

·   To enforce any agreement we may have with you.

·   Between and among us and any current or future parent, subsidiary and/or affiliated company.

·   To fulfill the purpose for which you provided such information.

·   For any other purpose disclosed by us when such information was collected.

·   With your consent or at your direction.

·   As otherwise would, under the circumstances, be reasonably expected by a consumer.

4. Protection of Information

We maintain reasonable physical, operational and electronic security measures to protect your information. However, the transmission of information via the Internet, the Sites or email is not completely secure and we cannot guarantee the security of information transmitted to or from us. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Dr. Tobias encourages you to learn as much as you can about your privacy on the Internet.

We will maintain your information for only as long as reasonably necessary to fulfil the purpose for which it was collected, and as long as legally necessary, in accordance with applicable law.  In some circumstances we may retain your personal data for extended periods of time, for instance, where we are required to do so in accordance with legal, regulator, tax or accounting requirements.

5. Links to Third Party Sites

Our Sites may link to other websites whose privacy practices may differ from ours. If you submit information to any of those websites, your information is governed by their privacy statements. We do not exercise control over third-party websites and are not responsible for the privacy practices or the content of any such third-party websites. We encourage you to carefully read their privacy statement. The fact that we may link to a third-party website or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third party, nor is it an endorsement of their privacy or information security policies or practices.

6. Notice to International Users

The Sites are hosted in the United States and are subject to U.S. law. If you are accessing the Sites from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites, you agree that you are providing freely-given, specific, informed, and unambiguous consent to the transfer to and processing of your personal information in the U.S.

7. Children's Privacy

The Sites are intended for general adult audiences and you represent that you are over the age of majority in your jurisdiction of residence. If we have any reason to believe you are not the age of majority or older we may terminate your access to the Sites. In the event that we collect personal information from children under the age of 13 in connection with providing our products or services, we require such personal information to be provided from a parent, guardian or other person with legal authority to provide us with such information. For example, if you purchase a product from us that includes coverage for a child under the age of 13, we may require the child’s name and data of birth.  We do not share, sell, rent or transfer children’s personal information other than as set forth in this Privacy Policy.

8. Disputes

If you choose to visit or access the Sites or any of our services, any dispute concerning or related to your privacy is subject to this Privacy Policy and our Terms of Use.

9. Consumer Privacy Rights

The law of your jurisdiction may provide you with certain rights regarding our use of your personal information. Subject to any exceptions under applicable law, you may have the following rights with respect to your personal information collected by Dr. Tobias:

·   The right to know and access. You may have the right to request Dr. Tobias provide you with (i) a copy of the personal information that we have collected or maintained about you during any specific period of time; (ii) the categories of personal information that we have collected or maintained about you during any specific period of time; (iii) the categories of purposes for which such personal information was disclosed during any specific period of time; (iv) the categories of sources of such personal information that was collected during any specific period of time; and (v) the categories of third parties that such personal information may have been shared with during any specific period of time. If you exercise your right to know or access, we will endeavor to provide you with the information requested for the specific time period requested. If you choose to exercise your right to know or access and do not specify a time period, we will endeavor to provide all of the requested information collected or maintained after January 1, 2022, unless doing so would be impossible or involve a disproportionate effort. In the case that fulfilling a request to know or access proves impossible or involves a disproportionate effort, we will endeavor to provide you the requested categories of information collected or maintained by Dr. Tobias in the immediately preceding 12 months from the date of your request. All information provided to you under this right to know and access will be provided in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format that will allow you to transmit the relevant information to another entity without hindrance or impediment.

·   The right to deletion. You may have the right to request that Dr. Tobias delete the personal information that we or our vendors collected about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations, complete a transaction for which your personal information was collected, or if such deletion would be impossible or require a disproportionate effort. If we are unable to comply with your request for deletion, we will let you know the reason why.

·   The right to correct inaccurate personal information. You may have the right to request that any of your inaccurate personal information that is maintained by us to be corrected, taking into account the nature of the personal information and the purposes of the processing of the personal information.

·   The right to portability. You may have the right to request that Dr. Tobias transmit your personal information to another entity in a portable, easily understandable, and to the extent technically feasible, in a structured, commonly used, machine-readable, and readily usable format.

·   The right to appeal. If you submit a request to exercise one of the above rights and we deny such request, you may have the right to appeal our decision.

·   The right to file a complaint. You may have the right to file a complaint with a relevant supervisory authority or your state’s Attorney General. You may contact us, the relevant supervisory authority, or your state’s Attorney General for more information.

If you choose to exercise any of these foregoing rights, we will not discriminate against you in any way. However, if you exercise certain rights, you may be unable to use or access certain features of the Sites or receive certain services.

9(a). Exercising Consumer Rights

To exercise any of these rights, contact us at contact page or 402-991-5618.  In connection with submitting a request, you must provide the following information, as applicable: name, email address, phone number, state of residence, and you must state what type of request you are making.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to his or her personal information. In general, we have the right to require you to provide written permission granting authority to your representative and for your agent to verify its identity directly with us, and we may deny a request from your representative who does not submit proof of authorization as we request.

The verifiable consumer request must provide sufficient information that allows us to reasonably verify the requestor is the person about whom we collected personal information or an authorized representative and describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to a request or provide personal information if we cannot verify the identity or authority to make the request.

We will endeavor to confirm receipt of a request within 10 days following submission and provide information about how we will process the request. We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to an additional 45 days), we will provide notice in writing explaining the reason for the extended time period.

Making a verifiable consumer request does not require you to create an account with us. We may deliver our written response by mail or electronically, at your option.

If we deny a request, we will provide a response explaining the reasons we cannot comply with a request, if applicable. We may deny your request to exercise any of the rights listed herein if we have a good-faith, reasonable, and documented belief that such request is fraudulent.

9(b). Disclosure of Personal Information

We may have collected and disclosed the following categories of personal information from a consumer for a business purpose in the preceding 12 months:

·   Various identifiers, including, name, address, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers.

·   Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, telephone number or financial information.

·   Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

·   Biometric information, including, behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information.            

·   Internet or other similar network activity, including, browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, including internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data in order to analyze trends in the aggregate and administer our Site.

·   Geolocation data, including, physical location or movements.

·   Sensory data, including, audio, electronic, visual, or similar information.

·   Professional or employment-related information, including, current or past job history or performance evaluations.

·   Educational information, including, transcript, student records, grades and performance, activities, school name or school ID.

·   Inferences drawn from other personal information, including, profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.   

·   Protected classification characteristics, including, race, color, national origin, marital status, sex, veteran or military status.

·   Personal records, such as, power of attorney, family history or power of attorney.

·   Information received from a government entity or other third party.

·   Sensitive personal information, including: (a) a consumer’s Social Security or other state identification number; (b) a consumer’s account log-in, 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; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communication; and (f) consumer’s genetic data.

We may collect the above categories of personal information directly from you, indirectly as you interact with our Sites, from or through other third party sources, including our customers, through email or other electronic messages between you and our Sites, or as otherwise set forth in this Privacy Policy.

In the prior 12 months, we may have disclosed the categories of personal information set forth above for one or more of the purposes set forth in this Privacy Policy, including disclosure to a service provider or other third party of Dr. Tobias for a business purpose.

9(c). Sale and Sharing of Personal Information and Use of Sensitive Personal Information

Dr. Tobias has not, in the preceding 12 months, and does not currently, sell or share your personal data for money or other valuable consideration.

We do not use your sensitive personal information for the purpose of inferring characteristics about you.

9(d).  “Shine the Light” Law

California’s "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California consumers asking about the business' practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. To make such a request, please send an email through our contact page.

How We Respond to “Do Not Track” Signals

Our Sites do not respond to DO NOT Track signals.  Third parties cannot collect any other personally identifiable information from our Sites unless you provide it to them directly.

10. Nevada Resident Privacy Rights

Nevada residents may have certain rights to opt-out of sales of their personal information under Nevada Revised Statutes Chapter 603A. However, please know Dr. Tobias does not currently sell data triggering this Nevada statute's opt-out requirements. If you have questions with respect to this right, please contact us through our contact page.

11. Your Choices

·   Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.

·   Push Notifications. With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile applications.

·   Direct Mail Marketing.  To request to opt out of receiving unsolicited commercial direct mail please contact us through our contact page.

·   Email Marketing.  You can choose to opt out of receiving promotional emails from Dr. Tobias at any time. Emails will include an unsubscribe link that will remove you from future emails. You may also submit a request through our contact page.

12.Changes To This Privacy Policy

We may change this Privacy Policy from time to time. The most recent version of the Privacy Policy will always be posted on our Sites, with a posted "Effective Date". By using our Sites or otherwise providing Dr. Tobias with your information after the Effective Date you agree that you consent to our then-current privacy policy.

13. Contact Us

If, at any time, you would like to access, change, or request deletion of your data (please specify the kind of information you are seeking and provide your name, email address, phone number, and state of residence), or if you have questions, concerns, complaints, or comments about our Privacy Policy, please feel free to email us through our contact page or write to us at:

Dr. Tobias Customer Care

610 Chartwell Road Oakville,
Ontario, Canada

If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible.

14. Accessibility

We are committed to facilitating the accessibility of our Sites for all people with disabilities. To access this Privacy Policy in an alternative format, please contact us at contact page or 402-991-5618.