iGottaBuddy.com offers hand-crafted bar soap as part of our product line. From customers’ browsing and purchase history on our site, we may collect personal information regarding these items, such as product choices, online behaviors, and interests.

This notice supplements the iGottaBuddy.com Privacy Policy and governs the collection, use, disclosure, and retention of personal information defined as “consumer health data” under the Washington State My Health My Data Act (MHMDA). Pursuant to the requirements of the MHMDA, this notice provides information regarding the following:

• How the FDA defines "soap";
• Types of consumer health data collected by iGottaBuddy.com;
• Purposes for processing consumer health data;
• Parties with whom consumer health data is shared; and
• Methods for withdrawing consent to future data collection or sharing.

How the FDA Defines "Soap"

Soap is a category that needs special explanation. That's because the regulatory definition of "soap" is different from the way in which people commonly use the word. Products that meet the definition of "soap" are exempt from the provisions of the FD&C Act because-even though Section 201(i)(1) of the act includes "articles... for cleansing" in the definition of a cosmetic, Section 201(i)(2) excludes soap from the definition of a cosmetic.

Not every product marketed as soap meets FDA's definition of the term. FDA interprets the term "soap" to apply only when:

• the bulk of the nonvolatile matter in the product consists of an alkali salt of fatty acids and the product's detergent properties are due to the alkali-fatty acid compounds, and
• the product is labeled, sold, and represented solely as soap [21 CFR 701.20].

Products that meet this definition of soap are regulated by the Consumer Product Safety Commission (CPSC), not by the FDA. An overview on if a product is a cosmetic, a drug, or both? (Or is it soap?) can be found here.

Types of Consumer Health Data Collected

Should a consumer experience an adverse reaction related to any of these particular products, we will collect pertinent information, including sensitive health data, as necessary to comply with applicable laws.

Health-related information may be voluntarily provided by users when contacting us via email, phone, or chat. For further details on our use of such technologies, please refer to our Privacy Policy.

Purposes of Processing Consumer Health Data

We process consumer health data to meet legal and regulatory obligations, including the documentation and reporting of adverse events in accordance with applicable laws and regulations.

In addition, consumer health data may be utilized in a de-identified and anonymized form for legitimate business purposes, including but not limited to data analytics, research and development, and potential commercialization initiatives.

Parties With Whom Consumer Health Data is Shared

We may disclose your personal information under the following circumstances:

• Affiliates: We may share data with affiliated entities, including our parent company, I GOTTA BUDDY, LLC, as needed to provide our services.

• Business Transfers: In the event of a merger, acquisition, or sale of all or part of our business, personal information may be transferred as part of that transaction.

• Service Providers: We may share information with third-party vendors who perform services on our behalf, such as website operations, analytics, order processing, payment handling, and customer support. We may also share aggregated or de-identified data with third parties for business purposes.

• With Your Consent: We may share your information with third parties, including social media platforms, if you opt in or otherwise consent. In such cases, your data will be governed by the third party’s privacy policy.

• Legal Compliance and Protection: We may disclose information as required by law, regulation, legal process, or government request; to enforce our terms or policies; to respond to emergencies; or to protect the rights, safety, or property of iGottaBuddy.com, our users, or the public.

• Chat Support: Our chat feature is optional. Chat sessions may be recorded and shared with our service provider. Chat tools may include AI or natural language processing to facilitate automated responses. If you do not consent, please contact us via email instead.

• Adverse Reactions: Information regarding product-related adverse reactions may be shared with regulatory authorities, including the U.S. Food and Drug Administration, as required under any such laws if applicable to the product.

Methods for Withdrawing Consent to Future Data Collection or Sharing

You have specific rights under applicable law regarding your consumer health data:

• Right to Know and Access: You may request confirmation of whether we collect, use, or disclose your consumer health data. You may also request access to that data, along with a list of our affiliates and the categories of third parties with whom it has been shared.

• Right to Withdraw Consent: If we process your consumer health data based on your consent, you may withdraw that consent at any time.

• Right to Deletion: You may request that we delete your consumer health data.

We are committed to honoring your requests to the fullest extent permitted by law and any contractual obligations. You will not face any adverse treatment or discrimination for exercising your rights.

To exercise your rights, please submit your request by emailing us at support@igottabuddy.com or by sending correspondence to the following address:

I Gotta Buddy, LLC
900 Commonwealth Pl, Ste 200-1055
Virginia Beach, VA 23464