Last Revised on June 5, 2020
1. TYPES OF INFORMATION WE COLLECT
When you use the Services, we may collect and receive Information in the following categories:
- “Personal Information,” which means information that identifies you (whether directly or indirectly), such as your name, postal address, email address, telephone number, payment card information, health-related information, including your “Stored Materials” (defined below) and the results any genetic or other testing performed by us or on our behalf (“Testing Results”), and any other information that you submit, including answers to surveys or questionnaires, testimonials or other information regarding your experiences with LifeVault’s products or services); and
- “Non-Personal Information,” which means information that does not directly or indirectly identify, and cannot reasonably be used to identify, you. If Non-Personal Information is directly or indirectly associated with Personal Information, this Non-Personal Information is then treated as Personal Information.
Information we may collect about you includes:
- Registration details you provide when you create an account, such as your name, email address, telephone number, birthdate, username and password.
- Information you provide related to your cells from your peripheral blood, including, but not limited to: your DNA, plasma and peripheral blood mononuclear cells (collectively, your “Stored Materials”), as well as Information you provide related to your health history including, but not limited to: your family history, medical history, allergies, diet and exercise habits, and information related to other medical or health issues.
- Information we create and/or collect about you, including from our third party lab partners, in creating your Testing Results.
- Information you provide when you access or use the Services and each time you interact with the Services or otherwise with us, for example, when you update Information in your dashboard, communicate with us by telephone or email, and order or download updates. This includes your payment Information. We also store Information about the products you purchase through the Services, such as the product specifications, date of purchase, and details relating to any support issue.
- Information you provide in public forums through the Services, including using our review, comment, testimonials, post or similar functionality. As noted below, if you provide such Information to the Services, we will identify you by your initials and geographic location (e.g., state of residence) when posting such Information to any public or semi-public part of the Services, including the Site.
- Usage, viewing and technical Information, including your IP address or device identifier when you use the Services. If you access your account from a mobile device, that mobile device may also provide us with details of your location. Most mobile devices allow you to disable this functionality.
- Information we receive about you from third parties. For example, if you access the Services through a third party platform or log-in, we may also collect your email address and other Information associated with that third party, and any Information you have made public in connection with that service or which the third party shares with partner services. See also Section 9 (THIRD PARTY WEBSITES, REFERRALS AND LINKS).
2. HOW WE COLLECT YOUR INFORMATION
- We collect Information you provide to us when you: register with us; input Information into the Services; create user generated content; request products, services or information from us; participate in public forums or other activities through the Services; respond to customer surveys; or otherwise interact with us or the Services.
- We collect Information through unique identifiers (such as IP address or your mobile device advertising identifier). An Internet Protocol (“IP”) address is a number that automatically identifies the computer/device you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider.
- Each time you access the Services, LifeVault collects some Information to improve the overall quality of your online experience. For example, we collect aggregate queries for internal reporting and also counts, tracks, and aggregates our users’ activity into our analysis of general traffic-flow on the Services.
3. CONFIDENTIALITY OF TESTING RESULTS AND OTHER HEALTH INFORMATION
We understand that your health information is important to you and take appropriate measures to maintain the confidentiality of such information in accordance with applicable laws. We use and disclose your Testing Results in accordance with applicable laws, the terms of our GoodCell Consent for Testing Form and our Terms of Service. We also use and disclose Information that constitutes individual-level health information in accordance with applicable laws.
4. USE OF YOUR INFORMATION BY LifeVault
- To provide you with the Services and other products and services you request.
- To administer your GoodCell account, respond to your inquiries and send you administrative and service communications.
- To communicate with you about your account or transactions with us and send you details or updates about features of the Services or changes to our policies.
- To process payments.
- To create anonymized and aggregated data sets that may be used for a variety of functions, including research, internal analysis, analytics, and other functions.
- To ensure consistency with local law and choices and controls that may be available to you.
- To personalize content and experiences and advertising.
- To determine whether you would be suitable to take part in surveys, polls or questionnaires that we are conducting.
- To detect, investigate and prevent activities that may violate our policies or be illegal.
- To optimize or improve the content, products, services, and features of the Services and develop new products and services.
- To evaluate customer response to our products and services, personalize and improve the Services and user experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match user profiles or interests.
- To monitor and analyze the Services usage and trends and otherwise measure the effectiveness of the services.
- To send you offers and promotions for our other products and services.
In some cases, LifeVault may use Personal Information submitted by you, such as your answers to questions or surveys about our products or services, your demographic or geographic information, to demonstrate the value of its products and/or services in marketing and/or advertising materials or media. In such cases, LifeVault shall not identify you as the source of such information without your express consent, and absent such consent, shall ensure that any such presented information is anonymized so that the information will not be attributable to you when and as presented.
5. SHARING YOUR INFORMATION WITH OTHER COMPANIES
We will not sell, lease, or rent your individual-level information (i.e., information about a single individual’s genotypes, diseases or other traits/characteristics) to any third party or to a third party for research purposes without your explicit consent. We will use your information and share it with third parties for scientific research purposes unless you have opted out of Data Sharing. Note that we will disclose your individual-level information only if we obtain additional explicit consent from you. We may share your Personal Information outside LifeVault in the following circumstances, which you consent to:
- When you request our referral services to forward or share certain content with a friend, such as an email inviting a friend to use the Services or sharing certain content from the Services with a friend.
- In connection with the sale of a business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings).
- We may disclose your Personal Information to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We may also disclose your Personal Information if we believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law or regulation.
In addition, we may share Non-Personal Information and anonymized and aggregated data sets with third parties, alone or in combination with the Non-Personal Information of other users.
6. PUBLIC VENUES AND SEMI-PUBLIC VENUES OF THE SERVICES.
If you use a message board, comment function, conversation pages, blogs, social community environments, profile pages, or other public or semi-public venue or forums of the Services, you will be identified on those venues by the username you submit.
7. POSTING REVIEW OR OTHER COMMENTS TO THE SERVICES
If you submit a review or provide other comments to the Services, and we display such comments on a public or semi-public part of the Services, we will identify you by your initials and geographic location (e.g., state of residence).
8. YOUR CONTROLS AND CHOICES
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your Information. Your controls and choices may include:
- You may correct, update and close your registration account.
- You may change your choices for newsletters and alerts.
- You may choose whether to receive from us offers and promotions for our products and services.
- You may request access to the Personal Information we hold about you and that we amend or delete it, although we may be entitled to retain some information for certain purposes (e.g., to comply with regulatory requirements).
You may exercise your controls and choices, or request access to your Personal Information, by modifying your profile or by contacting us at firstname.lastname@example.org or following instructions provided in communications sent to you. Please be aware that, if you do not allow us to collect Personal Information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific Personal Information about you that we process or retain, please contact us at email@example.com.
9. THIRD PARTY WEBSITES, REFERRALS AND LINKS
11. RESPONSE TO “DO NOT TRACK” SIGNALS
Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. LifeVault and the Services recognize DNT.
12. CHILDREN’S PRIVACY
We do not seek or knowingly collect any Personal Information about children under 13 years of age. If we become aware that we have unknowingly collected Personal Information from a child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with Personal Information, you may contact us at firstname.lastname@example.org to request it be deleted.
14. CALIFORNIA PRIVACY RIGHTS
15. NEVADA RESIDENTS
Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain Personal Information a business has collected or will collect about you. GoodCell does not sell your Personal Information pursuant to Nevada law. For more information about how we handle and share your Personal Information or your rights under Nevada law, contact us at email@example.com.
16. HOW TO CONTACT US