Privacy Statement

Last Updated: 04/17/26

This Privacy Notice describes how Avadim Holdings, Inc, makers of Theraworx® and Theraworx Protect® (“we,” or “us”) collects, uses, discloses, and processes your personal information (“you” and “your”), as well as rights that you may have regarding that information. We reserve the right to change this Privacy Notice at any time. If we change our Privacy Notice, we will post an updated version on this website. Please check back periodically to see if our Privacy Policy has been updated. Updates to the Privacy Notice will be referenced by the “Last Updated ” date shown above. By visiting this website, you acknowledge and consent to the privacy practices described in this Privacy Notice, including any revisions to this Privacy Notice that we post.

1. Purpose and categories of data

We may collect or receive personal information for a number of purposes connected with our business operations which may include the following: (click to expand)

  • Personal Identifiers: first and last name; home or other physical address, email address, telephone number
  • Internet or other electronic network activity information: IP address
  • Personal Identifiers: first and last name, and email address
  • Internet or other electronic network activity information: IP address
  • Personal Identifiers: first and last name, account name or alias, home or other physical address, email address, telephone number
  • Internet or other electronic network activity information: IP address
  • Personal Identifiers: first and last name, account name or alias, home or other physical address, email address, telephone number
  • Internet or other electronic network activity information: IP address
  • Internet or other electronic network activity information: IP address, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
  • Personal Identifiers: first and last name, account name or alias, home or other physical address, email address, telephone number
  • Internet or other electronic network activity information: IP address

2. Retention period

We will retain each category of your personal information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of personal information pursuant to any applicable contract, law, or regulation. 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 your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

3. Disclosure practices

We disclose personal information if we are required by law or by a court order, in response to a law enforcement agency or other government authority, to enforce our terms and conditions and protect our rights, to the extent permitted under other provisions of law, to provide information, or for an investigation on a matter related to public safety.

We may also use and disclose your personal information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). You acknowledge that such transfers may occur and that any acquirer of or successor to us may continue to use your personal information as set forth in this Privacy Notice.

3.1 Disclosure of Personal Information for a Business or Commercial Purpose

In the preceding 12 months, we have disclosed the following information for the business or commercial purpose provided herein:

  • We disclose your Personal Identifiers and Commercial Information with our customer relationship management provider and marketing partners to track, analyze, and optimize the provision of products and services to you.
  • We disclose your Personal Identifiers and Internet or other electronic network activity information with our email marketing and online survey providers to send you marketing communications that may be of interest to you and process your survey responses, respectively.
  • We disclose your Personal Identifiers and Internet or other electronic network activity information with our IT service providers to provide technical and data security support.

3.2 Sale/Sharing of Personal Information

We do not sell your personal information as that term is commonly understood (i.e., disclosure of your personal information in exchange for money). However, applicable privacy laws define “sale” to include situations where another company can use your personal information that we disclose to it for its own purposes. Also, applicable privacy laws define “sharing” as cross-context behavioral advertising (targeted advertising).

Therefore, our disclosure of your Personal Identifiers and Internet or other electronic network activity information to providers of third party cookies, pixel, and other online tracking technology used on our website or in our emails may be considered a “sale” or “sharing” under applicable privacy laws. To opt out of these types of disclosures, click Do Not Sell or Share My Personal Information  or turn on Global Privacy Control (or other opt out preference signal/universal opt out mechanism) in your internet browser or device.

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.

4. How we respond to Do Not Track signals

Our website responds to and supports the Do Not Track (DNT) header request field. If you turn DNT on in your browser, those preferences are communicated to us in the HTTP request header, and we will not track your browsing behavior.

5. Cookies

A cookie is a small file of letters and numbers that is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. We and our service providers and partners use cookies or similar technologies, such as web beacons and tracking pixels to analyze trends, administer our website, personalize content and ads, track users’ movements around our website to provide you with the most relevant browsing experience, to gather demographic information about our user base as a whole and to provide marketing. To opt out of the “sale” or “sharing” of your personal information, click Do Not Sell or Share My Personal Information or turn on Global Privacy Control (or other opt out preference signal/universal opt out mechanism) in your internet browser or device.

We use several types of cookies and other tracking technologies on our website, as described below.

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Functionality/preference cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Statistical, analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Marketing/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it and on third-party websites more relevant to your interests.
  • Third-party cookies. These cookies are placed on your device by a website from a domain other than our website. These parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies include analytical cookies, performance cookies and targeting cookies.

In addition, we use web beacons and pixels, which are images that can be placed in web pages and some forms of email. These technologies can be used to deliver cookies and to collect information about your use of the site. Finally, we may also collect information through tracking pixels. A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel or Javascript tag) that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the page of the site that contains the tracking pixel. We may use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our site. Other entities may have access to some of this information.

Emails that we and our service providers send may include similar technologies that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email. To unsubscribe from our marketing emails, click the “Unsubscribe” link in any of the emails, or contact us using the information provided at the end of this Privacy Notice.

If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. Please bear in mind that deleting and blocking cookies may have an impact on your user experience as parts of the site may no longer work. Unless you have adjusted your browser settings to block cookies, our system may issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

For more information about the cookies we use on our website, please refer to our Cookie Policy on our Cookie Policy (US) webpage.

We have concluded a data processing agreement with Google. The inclusion of full IP addresses is blocked by us.

6. Security

We take appropriate security measures to limit abuse of and unauthorized access to personal information. This helps to ensure that only the necessary persons have access to your data, that access to the data is protected, and that our security measures are regularly reviewed.

7. Third-party websites

This Privacy Notice does not apply to third-party websites connected by links on our website. We cannot guarantee that these third parties handle your personal information in a reliable or secure manner. We recommend you read the privacy statements of these websites prior to making use of these websites.

8. Privacy Rights

8.1 Shine the Light Law

If applicable, you have the right to know the list of all third parties to whom we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding year for third-party direct marketing purposes.

8.2 State-Specific Supplements

This section, which supplements the rest of this Privacy Notice, applies to residents of California, Texas, and Nebraska.

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act, as amended, and related regulations (CCPA). Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

  • Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of personal information we have collected about you; (2) the categories of sources from which the personal information is collected; (3) the business or commercial purpose for collecting, selling, or sharing personal information; (4) the categories of parties to whom we disclose personal information; and (5) the specific pieces of personal information we have collected about you.
  • Right to Know Personal Information Disclosed, Sold or Shared and to Whom.You have the right to request that we disclose to you: (1) the categories of personal information that we collected about you; (2) the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared; and (3) the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
  • Right to Request Deletion of Your Personal Information. You have the right to request that we delete your personal information. However, there a are number of situations where you do not have the right to request that we delete your personal information. For example, you cannot request that we delete your personal information if it is reasonably necessary for us to comply with a legal obligation, complete the transaction for which the personal information is collected or provide the services that you have requested or reasonably anticipated by you within the context of our ongoing business relationship, or to otherwise perform a contract between us. We also will not delete your personal information from our backup systems to the extent permitted by the CCPA. Following receipt of a request, we will let you know what, if any, personal information we can delete. If we cannot delete all of your personal information, we will let you know the reason.
  • Right to Correct Inaccurate Information. If you believe that any of the personal information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct.
  • Right to Opt-Out of the Sale and Sharing of Your Personal Information. You may opt-out of the sale or sharing of your personal information, to the extent applicable, by clicking here:
  • Right to Limit the Use of Your Sensitive Personal Information. You have the right to limit the use of sensitive personal information under certain circumstances. However, because we do not collect sensitive personal information, this right does not apply to you.
  • Right to Not Be Retaliated Against. If you choose to exercise any of your rights, you have the right to not be retaliated against.

Nebraska and Texas residents may exercise certain privacy rights pursuant to the Nebraska Data Privacy Act (NDPA) and Texas Consumer Data Protection Act (TCDPA), respectively. Your right to submit certain requests as a Nebraska or Texas resident are described below. With respect to the processing of personal information belonging to a known child, a parent or legal guardian of the child may exercise the consumer rights on behalf of the known child. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

Right to Know. Confirm whether we are processing your personal information and to access your personal information;

Right to Correct. Correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information;

Right to Delete. Delete personal information provided by or obtained about you;

Right to Data Portability. If the information is available in a digital format and the processing is completed by automated means, obtain a copy of your personal information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance; or

Right to Opt out. Opt out of the processing of your personal information for the purposes of:

  • Targeted advertising;The sale of personal information; or
  • Profiling in furtherance of a decision that produces a legal or similarly significant effect concerning the consumer. “Profiling” means any form of solely automated processing performed on personal information to evaluate, analyze, or predict personal aspects related to an identified or identifiable individual’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

9. How to Submit a Privacy Right Request

For residents of states listed above: (a) you can exercise your rights to opt-out of the selling and/or sharing of your personal information (to the extent applicable to you) by: (i) clicking the link provided above or (ii) enabling the setting in a browser that supports an opt-out preference signal (also known as universal opt-out mechanisms); and (b) for all other requests (to the extent applicable to you), you can make a request by calling us at 877-677-2723 or submitting a request through our online webform.

When you make certain requests (e.g., a request to know, delete and/or correct; or a request for access or data portability), to help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:

  • Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with the request.
  • Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
    • For valid requests to know categories of personal information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
    • For valid requests to know specific pieces of personal information right of access and right to data portability, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us.
    • For valid requests to correct or delete personal information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the personal information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.

We may also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative.

If there is no reasonable method by which we can verify your identity, we will state so in response, including an explanation of why we have no reasonable method to verify your identity.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request.

There may be situations where we cannot grant your request. For example, if you ask us to delete personal information that we are obligated to keep to comply with applicable law we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your personal information serves a legitimate purpose such as for security purposes. Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.

We will respond to valid requests to know, requests to correct and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

Valid requests under “Right of Access” and “Right to Data Portability” will be transmitted securely. If we cannot fulfill your request, we will notify you of that decision and the reasons why within 45 days.

If you believe our decision was in error, you may have the right to submit an appeal using the method(s) above. If the result is the same, you can also seek assistance and/or redress from your state attorney general using the forms listed below:

California: https://oag.ca.gov/contact/consumer-complaint-against-business-or-company

Nebraska: https://ne.accessgov.com/ago/Forms/Page/ago/2efd1471-06a7-4cd1-9bd2-cc8fe4e37c02/eaa18f8a-30e7-48c7-b97b-eaabb1ab6ce8/1

Texas: https://consumerprotection.texasattorneygeneral.gov/consumercomplaintportal/s/

10. Nevada Privacy Notice

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your personal information are not sales under Nevada law, so no opt-out right applies.

11. Children

We do not direct our website to children under eighteen (18) years of age. We do not knowingly collect information from persons under 18 years of age or provide any personal information from such persons to any third party for any reason whatsoever. We therefore request that children under the age of consent do not submit any personal information to us.

12. Contact details

Avadim Holdings, Inc.
2311 US Highway 70, Unit 457
Swannanoa NC, 28778
United States

Email: [email protected]

Phone number: 877-677-2723