This Statement of Privacy applies to dm-free.com, and Deutsch  Holdings LLC and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Deutsch  Holdings LLC include the dm-free.com website, all communications with DH, and all DH technologies such as the DH forum and help desk software. The DH website is a healthy lifestyle web site focused on natural management of diabetes type II. By using the DH website and communicating with DH staff or systems in any way, you hereby consent to the data practices described in this statement.  This privacy policy only applies to those people residing in the USA and subject to USA laws.  Otherwise, you are not authorized to use this site.  If  you use this site with or without authorization, then you, not DH, assume all liability for your actions and hereby agree that you not will participate in any civil or criminal action against DH and you agree that DH has your explicit consent to perform any activities described herein with your data. If any aspect of this policy is not found to be enforceable, then this policy shall hereby considered to be amended with the unenforceable text removed.  If this policy is not consistent with applicable law, then you are not allowed to interact with DH people or technologies in any manner.

Privacy Compliance Certification

The DH help desk system (ZenDesk) claims HIPAA compliance and is the only method used by DH to communicate clinical data.

DH will take reasonable steps to secure your information, but we cannot eliminate all risks of data breaches or other cybersecurity incidents due to human error, misconfigurations, third party risks, software, firmware, interface standards, hardware defects, process problems, etc. Most, if not all, software has defects that can be leveraged by determined attackers to breach our systems, and we offer no assurance that your data will not be breached due to the issues mentioned herein. Again, DH will attempt to prevent cybersecurity incidents but cannot guarantee no incident will occur.

Collection of your Personal Information

In order to better provide you with products and services offered, DH may collect, store, analyze, and share your personally identifiable information, such as your:

–        First and Last Name

–        Mailing Address

–        E-mail Address

–        Phone Number

–        Employer

–        Job Title

–        IP address, other internet-technology based information,

–        Health data,

–        Biometrics,

–        Clinical data,

–        Protected health information, and

–        other individually identifiable information

If you purchase DH’s products and services, we collect billing and credit card information. This information is used to complete the purchase transaction(s).

DH may also collect, store, analyze, and share your anonymous demographic information, which is not unique to you, such as your:

 –          Age

  –         Gender

 –          Race

 –          Religion

–           and more

Informed Consent for Research

Your data may be used for medical research purposes, for creating academic and industry articles and presentations.  Such research could include, without limitation, comparisons, studies, outcomes research, ethnographic studies, and more, with the general topic of improving diabetes health. You consent to such use of your data by voluntary submission of such data to DH.  You will be reminded periodically about the use of your data for research purposes.

Biometrics

As defined by https://www.merriam-webster.com/dictionary/biometrics DH collects, stores, and analyzes and may share certain biometrics that you voluntarily submit to us via forms, uploads, and other communications.  If such biometric data collection is not permitted by applicable law, then it is your responsibility to know about any such limitations and it is your responsibility to not submit your biometrics to DH. 

A limited number of biometric data, are voluntary collected during the optional DM-Free.com web site initial intake form.  Additional biometrics will be collected, stored, analyzed and shared throughout your interactions with DH technologies and staff.  Biometrics collected include, without limitation:

–        Blood chemical analysis,

–        Urine chemical analysis,

–        Age,

–        Birth sex and gender identity,

–        Weight,

–        BMI,

–        Height,

–        Other physical measurements,

–        Etc.

DH cannot perform its core diabetes health coaching services without your biometric data.  Hence, if you are unable to provide DH with a certain minimal set of biometric data, then you are not eligible to participate in the DH program.

Please keep in mind that if you directly and voluntarily disclose you personally identifiable information or personally sensitive data through DH’s public message boards, this information may be collected and used by others.

In order to utilize DH products, services, and technologies, you may be required to provide certain personal information to us when you elect to use certain products or services. These may include: (a) registering for an account; (b) entering a sweepstakes or contest sponsored by us or one of our partners; (c) signing up for special offers from selected third parties; (d) sending us an email message; (e) submitting your credit card or other payment information when ordering and purchasing products and services. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.  Use of these DH services is voluntary and your use of these services serves as your consent to share such personal information with DH as specified in this notice.

Use of your Personal Information

DH collects and uses your personal information to operate and deliver the services you have requested.

DH may also use your personally identifiable information to inform you of other products or services available from DH and its affiliates.

Sharing Information with Third Parties

DH may sell, rent, or lease customer information to third parties for the following reasons:

Marketing and other purposes

DH may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number, etc.) is transferred to the third party. DH may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries, etc.

DH may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on DH or the site; (b) protect and defend the rights or property of DH; and/or (c) act under exigent circumstances to protect the personal safety of users of DH, or the public.

Opt-Out of Sale or Disclosure of Personal Information to Third Parties

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling or disclosing your personal information, unless you subsequently provide express authorization for the sale or disclosure of your personal information. To opt-out of the sale or disclosure of your personal information, send an email to help@dm-free.com.

Tracking User Behavior

DH generally tracks your use of the DH the website for various reasons such as determining your interest in various items. These data are used to deliver customized content and advertising within DH to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by DH. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the DH website, etc.

Use of Cookies

DH generally uses website “cookies” or similar technologies to help personalize your online experience, to log in, and for other purposes. A cookie is a text file that is placed on your computer storage by a web server.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize DH pages, or register with DH site or services, a cookie helps DH to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same DH website, the information you previously provided can be retrieved, so you can easily use the DH features that you customized.

You may have the ability to accept or decline cookies, depending on your computer software. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the DH services or websites you visit.

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

Security of your Personal Information

DH secures your personal information from unauthorized access, use, or disclosure. DH uses the following methods for this purpose:

 –          TLS

 –          encryption

 –          various other security mechanisms

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as TLS.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission at rest or in transit can be guaranteed to be secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site and DHH cannot be guaranteed.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Children Under Thirteen

DH does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

Children Under Eighteen

DH does not knowingly collect personally identifiable information from children under the age of eighteen. If you are under the age of eighteen, you must ask your parent or guardian for permission to use this website.

Opt-Out & Unsubscribe from Third Party Communications

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from third-party partners of DH by contacting us here:

– Email: help@dm-free.com

E-mail Communications

From time to time, DH may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, DH embeds tracking technologies in our emails to you, and DH attempts to determine when you open an email from DH or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from DH, you may opt out of such communications by sending an email to help@dm-free.com.

External Data Storage Sites

We may store your data on servers provided by third party vendors with whom we have contracted. While DH attempts to use third party sites that are secure, DH cannot guarantee such.

Changes to this Statement

DH reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your account, or by placing a prominent notice on our website, and/or by updating any privacy information. Your continued use of the website and/or Services available after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

DH welcomes your questions or comments regarding this Statement of Privacy. If you believe that DH has not adhered to this Statement, please contact DHH at:

Deutsch Holdings LLC

150 Cork Ln

Austin, Texas 78737

Email Address:

help@dm-free.com

Effective as of April 19, 2025