iollo ("iollo, inc," "us," "our" or "we") acknowledges and recognizes the importance of privacy. We appreciate your need to store and access your information in a private and secure manner. This Policy explains how we handle your Personal Information, Sample Information and Metabolomic Information. Your Personal Information is data that may be used to identify you. Your Sample Information is data related to your blood tests or other samples collected. Your Metabolomic Information is data related to your metabolome.
We follow the following principles to protect your privacy
● We do not collect any more Personal Information about you than we need.
INFORMATION WE COLLECT
Personal Information iollo collects several types of Personal Information. Personal Information is data that could be used to identify you, either alone or when combined with other information. We gather this information from you when you buy our Services, subscribe to our newsletters, and/or use the Platform. You will also provide such information when you create a personal account and complete surveys and forms. When you communicate with us or request information from us we will collect Personal Information from you. Personal Information collected online can be combined with Personal Information collected offline. The Personal Information we collect may include your name, email address, mailing address, date of birth, gender, and credit card or bank account information. If you buy our iollo service/s, we will also collect certain health, test, and biometric information, including, but not limited to, blood metabolic data, height, weight, ethnicity, and heart rate as well as your exposome (diet, habits, product-usage, etc).
● Registration Information is information that we collect from you when you register for iollo Services. Examples include your name, age, login credentials, and contact information, such as an email address. We use this information to deliver our Services to you, to communicate with you, and to confirm your identity.● Biomarker data is data related to your sample and/or blood test results from tests done by iollo laboratories, or iollo laboratory partners. We may use your biomarker data in a de-identified, aggregated way for iollo research.
● Self-Reported Information includes information you provide in the iollo questionnaires or in any other website or application surveys or forms, such as sex, body weight, height, diet, habits, exercise, etc. We may use your Self-Reported Information in a de-identified way for iollo research.User Content is all information other than Metabolomic Information or Self-Reported Information provided by the users of the iollo Services and transmitted, whether publicly or privately, to iollo.
● User content may include data, text, software, music, audio, photographs, graphics, video, messages, or other materials. For example, user content includes comments made on iollo websites, apps, blogs and emails to customer support.
● Web Behavior Information is information on how you use the Platform (e.g. browser type, domains, page views). We may collect this information through log files, cookies, and web beacon, analytical and advertising technologies.
If you have purchased iollo as a gift for someone else, any information you provide about the gift recipient will be used only as needed to deliver the gift. Your gift recipient must create their own account. The gift recipient must also provide their own blood and/or other samples or data depending on the iollo plan selected. The gift recipient must provide their own consent. No one else can consent for them. iollo will never share any Personal Information of the gift recipient with you.
You can always refuse to supply the Personal Information that we request. If you do refuse to supply information, you may not be able to engage in certain Platform-related activities and receive certain Services and information.
HOW WE MAY USE YOUR PERSONAL INFORMATION
We may collect and use Personal Information for the following purposes:
● To provide iollo services. We use your Personal Information, including metabolomic and biomarker data, height, weight, ethnicity, along with your Self-Reported Information to produce your iollo analysis.
● To process transactions. Information you give to us lets us process transactions made on the Platform or otherwise as necessary to perform our contractual obligations to you, including confirming your order, billing, and delivering products or services.
● To improve customer service. Information you provide helps us respond to your customer service requests and support needs more efficiently. We will do this on the basis of our legitimate business interests.
● To personalize your experience.We may use combined, de-identified information to understand how our users as a group use the Services. We will do this on the basis of our legitimate business interests.
● To improve our Services. We may use combined, de-identified information and feedback you provide to improve our Services. We will do this on the basis of our legitimate business interests.
● To run a promotion, contest, survey, or other feature of the Platform. With your consent, we will use your Personal Information, preferences and details of your transactions to keep you informed by email, text, web or telephone about our products and services. These products may include tailored special offers, discounts, promotions, events, competitions and so on.
● To respond to your inquiries. We will use your Personal Information to respond to your inquiries, questions and/or other requests. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests.
● To share offers from third parties that may be of interest to you. With your consent, we may use your information to tell you about offers, programs, products, or services from third parties that may be of interest to you.
● To comply with our legal or contractual obligations to share data with law enforcement. If we are required to disclose your information, we will do our best to provide you with notice in advance, unless we are prohibited by law from doing so.
● To fulfill any other purpose for which you provide Personal Information. We may use your Personal Information for purposes that we tell you about at the time we collect the information or later with your consent.
● For scientific research. With your consent, we may include your anonymized metabolomic data and self-reported information in disclosures to third parties for the purpose of research. iollo research is intended to advance science and knowledge and to create, commercialize, or undertake activities toward the practical applications of this learning to the improvement of longevity, health and healthy lifespans. Research may be conducted by our own team, or by our research partners, which may include commercial or non-profit organizations that conduct or support medical research or conduct or support the development of drugs or devices to diagnose, predict, or treat health conditions.
HOW WE PROTECT YOUR INFORMATION
The security of your Personal Information is important to us. We have adopted generally accepted industry standards for our data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your Personal Information, username, password, transaction information, and data stored on the Platform. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to safeguard your password, secret questions and answers, and other authentication information you use to access our services. You should not disclose your authentication information to any third party. You should also immediately notify us of any unauthorized use of your password. We cannot secure Personal Information that you release on your own or that you request us to release. Neither can we protect your information once you have exported this data, or allowed third parties access to your iollo apps, websites and/or accounts.
In addition, you may choose to disclose, through other means not associated with us, any part of your Personal Information and/or Metabolomic Information. You may share this information with friends or family members, groups of individuals, third-party service providers, doctors or other health care professionals, or other individuals. We recommend that you make such choices carefully.
If you do choose to share metabolomic data with your doctor or other health professional, those data may become part of your medical record. Other health professionals and health insurance companies may be able to access the metabolomic data in your health record.We will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information and/or Metabolomic Information with a third party. It is your responsibility to share Personal Information and Metabolomic Information only with people you know and trust.
DISCLOSURE OF YOUR PERSONAL DATA
We may disclose aggregated, or other non-Personal Information or information about our users without restriction. We may disclose Personal Information about you in the ways described below and/or to the third-parties mentioned below.
● Agents and Service Providers. To contractors, service providers, and other third parties we use to support our business and provide the Services. These providers may complete transactions or perform services on our behalf or for your benefit.
● Legal Process. As required by law, such as to comply with a subpoena or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If we are required to disclose your information, we will do our best to provide you with notice in advance, unless we are prohibited by law from doing so.
● Consent. In additional ways upon your consent.
● Request a Copy of your Personal Information. You have the right to request a copy of any Personal Information that we hold about you. If you would like a copy of your Personal Information, please contact us using the contact information below. We may request proof of your identity before sharing such information. If you discover that the information we hold about you is incorrect or out of date, you may ask us to correct that information by contacting us using the contact information below.
● Cease Processing or Delete Personal Information. You may ask us to stop processing, or delete, the personally identifiable data we hold about you in certain circumstances. It may not be possible for us to stop processing or delete all of the information we hold about you were we are fulfilling a transaction or have a legal basis to retain the information, however please contact us to discuss how we can assist you with your request.
● Withdraw Consent. When we process your information on the basis that you have consented to such processing, you have the right to withdraw your consent, or ask us to stop or restrict processing the Personal Information we have about you, at any time by contacting us using the contact information below.
● Portability. You may also ask us to transfer your Personal Information to a third party in certain circumstances. If you would like any further information about your rights or how to exercise them, please contact us using the contact information below.Complaints. If you are in the European Union, you have the right to make a complaint at any time to the relevant data protection authority in your country.Retention. We will retain your information for as long as needed to fulfill your requests, provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.Unsubscribe. If you receive marketing emails from us, you can unsubscribe to our emails by clicking "unsubscribe" within each email. You may not opt-out of service-related communications, which are not promotional in nature.
CLOSING OR CORRECTING YOUR ACCOUNT
Your use of the iollo service is voluntary. It is your choice whether to participate or not. You may cancel the service at any time. If for any reason you believe that your use is anything but voluntary, please stop all use of the service.
If you no longer wish to use iollo Services, you may close your account by sending a request to Customer Support at email@example.com
. When closing an account, we remove all Personal Information within your account. However, Personal Information that you have previously provided will not be removed from ongoing or completed internal R&D or business activities that use the information (as de-identified statistical information). Similarly, if you close your account after you have separately agreed to the Research Consent document, any metabolomic information that you have previously given consent to use in de-identified form will not be removed from ongoing or completed studies. If you wish to have your data removed from our business partners, you must contact them separately. In addition, we keep limited information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes.
If your Personal Information changes, you may correct or update it on your Profile page. You may also correct or reset Personal Information entered into a survey, form, or feature by emailing a request to customer support at firstname.lastname@example.org and including the name of the specific survey, form, or feature.
COOKIES AND OTHER TRACKING TECHNOLOGIES
● As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Platform (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Platform.
● The length of time a cookie stays on your device or computer depends on its type. "Persistent" cookies stay on your device or computer until they expire or are deleted. "Session" cookies will only stay on your device or computer for as long as you are on our Platform.
● We use first party cookies and third party cookies on our Platform. First party cookies belong to us. Third party cookies are placed on your device or computer by a third party through our Services, such as an advertiser.
CHILDREN UNDER THE AGE OF 18
The Platform and Services are intended for adults. Users under the age of 18 are not permitted to use the Services. The Platform is not directed to, and we do not knowingly collect or solicit Personal Information from, children under the age of 18. If we learn we have collected or received Personal Information from a child under the age of 18, we will delete that information. If you believe we might have any information from or about a child under the age of 18, please contact us using the contact information below.
WHERE WE STORE YOUR INFORMATION
iollo is located, and the Platform is hosted, in the United States of America. In order for us to provide the Services to you, we will process and store Personal Data you provide to us in the United States of America, which may have different data protection laws than those in the country in which you reside.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information below.
iollo ("iollo, inc", "us", "our" or "we") is fully compliant with the HIPAA Standards for Privacy, Electronic Transactions and Security (including the HITECH Act and the Omnibus Rule of 2013). We have implemented policies, processes, and procedures designed to ensure compliance with Federal security laws, regulations, and rules, and we monitor ongoing compliance efforts and maintain various reporting mechanisms that are required by law or requested by our customers. We recognize that it is a key responsibility for our business and will continue to provide all of our various programs and services in accordance with the relevant requirements of all federal laws and regulations, including, as applicable, HIPAA.Questions regarding our HIPAA policies or compliance may be directed to: email@example.com.