Privacy Policy

Last Updated: October 31st, 2017

 

At LifeDNA, Inc. we respect your privacy and appreciate the trust if you have placed in us. This Privacy Policy explains how LifeDNA, Inc. (“LifeDNA”, “we”, or “us”) collects, uses, and discloses information about you, including Genetic Data and Health Information (as each term is defined below), we obtain through www.LifeDNA.com, our mobile applications, and our provision of personalized supplements to support your health (collectively, the “Service”).

 

This Privacy Policy is incorporated by reference into LifeDNA’s Terms of Use (the “Terms”). By agreeing to this Privacy Policy in your account setup, or by using the Service, you consent to the processing of your information as set forth in this Privacy Policy. You understand that in order to use the services, you may be required to provide us with information regarding your genotype which is typically generated through analysis of your saliva (“Genetic Data”) and self-reported health-related information including disease history, personality traits, family information, ethnicity, and ancestry (“Health Information”).

 

HOW WE COLLECT YOUR INFORMATION

 

Information You Provide

We collect any information that you provide us when you use the Service.

 

  • Genetic Information. In order for us to provide you personalized supplements, you are required to provide us Genetic Data and Health Information maintained about you by third-party sources you have an existing relationship with. For example, with your authorization, you may provide us Genetic Data and Health Information maintained about you by 23andMe.

 

  • Registration. When you register for the Service, we will ask you to provide your email address, name, and billing and shipping address. We may also request that you provide additional Health Information about yourself through a brief lifestyle survey.

 

  • Communications and Other Interactions. We may collect information through your communications with our customer-support team. [We will also collect any information you provide when you interact with other registered users.]

 

  • Payments. If you make payments through the Service, we will ask you to provide your payment information, such as your credit card number, so our service providers can process your payments.

Information We Collect When You Use Our Service

We may automatically collect certain technical information from your computer or mobile device when you use the Service.

 

  • Device and Usage Information. We receive information from your device, including IP address, web browser type, mobile operating system version (to the extent applicable), and unique device identifiers. We may also collect and store your browser settings and preferences. We receive information about your interactions with our Service, such as the time spent interacting with content and the dates and times of your visits.

 

  • Information from Cookies and Similar Technologies. We and our service providers may collect information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies enable us to personalize your experience on the Service, maintain a persistent session, passively collect demographic information about your computer, and monitor other activities. Our website and mobile applications may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

 

HOW WE USE YOUR INFORMATION

 

Service-Related Usage

We use the information we collect about and from you for a number of purposes, including providing you personalized supplements through the maintenance and processing of your information, including your Genetic Data and Health Information, improving the Service, analyzing how you use the Service, managing our network, and better tailoring our Service to you.

 

Communications

We use your information to communicate with you. For example, we may send email to the email address you provide to verify your account and for informational and operational purposes, such as account management or customer service.

 

Marketing

We may use the information we collect for marketing purposes, such as providing you with promotional materials that may be useful, relevant, valuable or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications.

 

Compliance with applicable law and our own obligations

We may also process the information we collect about you or from you for the following purposes: (i) to enforce our Terms or other legal rights, including intellectual property infringement; (ii) as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and (iii) to comply with industry standards and our policies.

 

Aggregate Data

We may de-identify your information and process it in an anonymous and aggregated form for other purposes than described above.

 

HOW WE MAY DISCLOSE YOUR INFORMATION

 

Service Providers

We may share your information among our vendors, service providers, and other third parties that perform services on our behalf.

 

Research

Through your relationship with us, you may elect to participate in research sponsored by, conducted on behalf of, or in collaboration with third-parties, including non-profit organizations, academic institutions, pharmaceutical companies, or health care providers (collectively, the “LifeDNA Research Program”). The information we collect about and from you, including Genetic Data and Health Information, will only be used for the Life DNA Research Program if you have consented to this use and disclosure by affirmatively providing your consent via our Consent to Research Form. 

 

To the extent you have provided your consent, you may withdraw your consent to participate in the LifeDNA Research Program at any time by contacting us in writing using the contact information listed below. You understand, however, that the withdrawal of your consent will not have an effect on any actions taken prior to the date your withdrawal is received and processed. In addition, if you do not provide your consent or withdraw consent previously provided for the LifeDNA Research Program your Genetic Data and Health Information may still be used by us and shared with our third-party service providers as described above and shared as aggregate information that does not identify you as an individual.

 

Analytics

We use third party analytics vendors to evaluate and provide us with information about your use of the Service. We do not share your information with these third parties, but these analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different websites. On our websites, we use Google Analytics to collect and process certain analytics data; Google provides some additional privacy options described at www.google.com/policies/privacy/partners.

 

Ad Network Providers

We may also allow ad network providers to set and access their own cookies, pixel tags and similar technologies to collect information about website use. These network advertisers may use this and other information they have collected about you to deliver targeted advertisements for products and services in which you might be interested based on your use of the website. If you prefer to not receive targeted advertising, you can opt-out of some network advertising programs that use your information. To do so please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices.

 

Third Party Applications

We may enable you to share information from our Service to third party applications or services. For example, you may share information regarding your personalized stack of supplements with third party websites or applications. We are not responsible for how you share this information through these or similar services. These third parties may use or share your information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.

 

As Required by Law and Similar Disclosures

We may disclose information about you: (i) if we are required to do so by law, regulation, or legal processes, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm, injury, or loss to property; or (iv) in connection with an investigation of suspected or actual unlawful activity.

 

Merger, Sale, or Other Asset Transfers

We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

 

We may also disclose your information with your permission. In addition, we may share anonymous and aggregated reports with third parties.

 

YOUR CHOICES AND RIGHTS

 

If you do not want the Service to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or disable certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you disable or reject cookies, some features and Service may not work properly. You can opt-out of receiving further promotional messages from us by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at the contact information listed below.

 

HOW WE HOLD AND PROTECT YOUR INFORMATION

 

We take seriously the trust you have placed in us with your information, including your Genetic Data and Health Information. To protect against unauthorized destruction, loss, alteration, access, disclosure, or use (collectively, “Unauthorized Processing”), we maintain administrative, technical, and physical safeguards designed to protect the information you provide or we collect about you. Unfortunately, despite these efforts, we cannot ensure or warrant the security of any information you provide to us. In addition, we are not responsible for the security of information you transmit to the Service over networks that we do not control, including the Internet and wireless networks. As a result, we will not be liable for any loss or damage arising from any Unauthorized Processing of your information.

 

CHILDREN’S PRIVACY

 

The Service is not intended for anyone under the age of 18. As a result, we do not knowingly collect information online from children under the age of 13. If LifeDNA becomes aware that any person submitting information to the Service is under the age of 13, we will promptly take steps to delete any personal information collected and terminate the relevant account. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us at the contact information listed below.

 

INTERNATIONAL USERS

 

If you are visiting from the European Economic Area or other regions with laws governing data collection and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected, including the United States of America. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy. By providing your information and/or using the Service you consent to any transfer and processing in accordance with this Privacy Policy.

 

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

 

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws. To inform you of any change, we will post the updated Privacy Policy on the applicable websites and indicate at the top of the Privacy Policy when it was updated. If we decide to use particular personal information in a manner materially different from that stated at the time it was collected, we will let you know through our Service, by email, or other communication.

 

HOW TO CONTACT US

 

If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact us at privacy@lifedna.com or by writing to us at:


LifeDNA

PO BOX 11477

Honolulu, HI 96828

1.877-LIFEDNA(543-3362)