Updated: May 6, 2020 

We at LifeOmic Holdings (LifeOmic Holdings LLC and our subsidiaries and affiliates) are committed to protecting your privacy. This privacy policy applies to our LIFE Extend and LIFE Fasting applications and associated APIs, websites and services (“Mobile Apps”), (each a “Site”, “Service”, or “Mobile App” or collectively, the “Services”), owned and controlled by LifeOmic Holdings.

This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our Services. 

Specifically, this Privacy Policy covers:

INFORMATION WE COLLECT ABOUT YOU 

When you use our Services, we collect the following types of information. 

INFORMATION YOU PROVIDE US (“PERSONAL INFORMATION”)  

ACCOUNT INFORMATION 

Some information is required to create an account on Services, such as your 

• name,  
• email address,  
• password,  
• company, and 
• phone number.

You provide this information to us directly by completing fillable webforms on the Services and submitting the information to us.

ADDITIONAL INFORMATION 

To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, such as  

• profile photos,
• profile information (such as a biography),
• country information,
• date of birth,
• demographic information (such as date of birth gender, height, weight and geographical residence location),
• test results as provided by third parties such as biometric testing and genomic testing,
• additional health information and logs (such as diet, exercise, sleep),
• data from linked devices such as wireless scales, fitness bands, blood pressure cuffs, other applications, etc.
• contact information (such as your mailing address and your mobile telephone number),
• community or social media username, and
• messages and media on discussion boards or to your social contacts on the Services. 

You may also connect with friends on the Services or invite friends who have not yet joined by providing their email addresses, accessing social networking accounts or using the contact list on your mobile device. We do not store your contact list and delete it after it is used for adding contacts as friends. 

If you contact us or participate in a survey, contest, or promotion, we collect the information you submit directly from you such as your name, email address, contact information, and message. 

INFORMATION FROM THIRD-PARTY SERVICES 

If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address and friend list. You may also choose to grant us access to your personal information such as activity data or health data from other services. You can stop sharing the information from the other services with us by removing our access to each other service. However, we will store historical data that has already been collected (such as steps, activity, sleep).

INFORMATION PROVIDED BY OTHER INDIVIDUALS 

While using our Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about You. When one individual provides us with information (including personal information) about another individual, we assume that the individual has permission and authority to do so and to consent on behalf of that individual to the collection and use of personal information as described in this Privacy Policy. Please contact us immediately if you become aware of an individual providing us with personal information about another individual without being authorized to do so, and we will act consistently with this Privacy Policy. 

PAYMENT AND CARD INFORMATION 

Some LifeOmic Holdings Services support payments and transactions with third parties. If you activate this feature, you must provide certain information for identification and verification, such as your name, billing address, credit, debit or other card number, card expiration date and CVV code. This information is used solely to check your financial qualifications and collect payment from you. We do not store your payment information. We use a third-party service provider to manage payment card processing. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms. This service provider is not permitted to store, retain or use information you provide except for the sole purpose of credit card processing on our behalf. 

INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES 

USAGE AND DEVICE INFORMATION 

When you use our Services, we receive certain usage data (“Usage and Device Information”). This includes information about your interaction with the Services, for example, when you view or search content, install or open applications or software, create or log into your account, import data into your account, or integrate a third-party service to your account. 

We may also collect data about the devices and computers you use to access our Services, including IP addresses, browser type, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information. 

HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA 

To the extent that information we collect directly from you is health data or another special category of sensitive personal data subject to the European Union’s General Data Protection Regulation (“GDPR”), we ask for your explicit consent to process such sensitive personal data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you activate the activity tracking features in our Mobile Apps or grant us access to your health or activity data from another service. You can use your account settings or contact us to withdraw your consent at any time by requesting deletion your data or closing your account.   

However, if we are acting as a service provider (a “Data Processor”) processing your personal information on behalf of a third party that has collected such data from you, and such third party is the party that has the right to determine the purposes for which it will process your personal information and the means it will use to process your personal information (the “Data Controller”), then such Data Controller has the legal obligation to ask for your explicit consent to process your sensitive personal data (including health data), and we are not responsible for obtaining such consent from you.  In such a scenario, the Data Controller may have their own, separate policies regarding the use and disclosure of your personal information, including any sensitive personal data you provide to such Data Controller.  In such a scenario, this Privacy Policy does not apply to, we cannot control the activities of, and we are not responsible for the activities of the applicable Data Controller generally; this Privacy Policy only applies to our processing of your personal information that we, as a Data Processor, have been asked to process on behalf of the applicable Data Controller.  We encourage you to review such Data Controller’s privacy policy and/or contact the applicable Data Controller for more information about the policies that apply to their use and disclosure of your personal information, including any sensitive personal data.   

HOW WE USE YOUR INFORMATION 

We use the information we collect for the following purposes. 

PROVIDE AND MAINTAIN THE SERVICES 

We use the information we collect to deliver the Services to you and honor our Terms of Service for each Service or business contract with you. For example, 

• to administer, operate, maintain and secure our Services; 
• to monitor and analyze trends, usage and activities in connection with our Services; 
• to calculate metrics in the application such as LIFE Points, biological age, lifespan, etc.;
• for accounting, recordkeeping, backup and administrative purposes; 
• to customize and improve the content of our communications, websites and social media accounts; 
• to provide customer service and support, service requests sent through the platform, requesting feedback, surveys, requesting testimonials about the Service; 
• to communicate with you, including responding to your comments, questions and requests regarding our Services; and  
• to process and complete transactions, and send you related information, including alerts and notifications about your service, purchase confirmations and invoices; and 
• to educate and train our workforce in data protection and customer support. 

For the Services’ social features, we may use your information to help you find and connect with other users and to allow other users to find and connect with you. For example, your account contact information allows other users to add you as a friend. When another user has your email or mobile phone number in their contact list or in their friend network on a connected service, we may show that user that you are a user of the Services. 

IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES 

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys and develop new features and Services. 

We may use the information collected about you and your use of the Services to provide you with generalized health and wellness notifications and information that may be of interest to you.

COMMUNICATE WITH YOU 

We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in as well as request feedback, user surveys, and testimonials. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the “Unsubscribe” link in an email. 

We may also contact you to provide feedback on the Service such as taking surveys or providing testimonials.

CONNECTING YOU TO OTHERS’ PRODUCTS AND SERVICES

We also use the information we collect about you and your use of our Services to provide you with targeted, personalized advertising and promotional information about offers, services or products of third parties that may be of interest to you. We do not share your personal information with third parties in connection with this targeted advertising and promotion (although you may choose to share your information with such third parties if you choose to access the third party’s website, click on the link in an advertisement, contact the third party in regards to the offer or otherwise communicate with the applicable third party whose products or services are being promoted).

Additionally, if you ask us to share your information with a third party provider of products or services, we may transmit information about you to such third party provider and otherwise facilitate your direct communications with such third party providers through our Services or through other communications channels with the third party provider. For example, you may choose to use the Services to associate and connect with an organization (such as in the case of researchers, public health initiatives, healthcare organizations, employers, etc.) in which case we will provide your information to that organization. Additionally, you may choose to use our LifeOmic Connect service to place a telephone call, engage in a video conference, web chat, or otherwise communicate with a service professional or adviser and you may choose to transmit certain information (including your personal information) directly to such professional or adviser when engaging with them through LifeOmic Connect. We do not control (and are not responsible for) the applicable third party provider’s policies and practices relating to the collection, use or disclosure of your information. We encourage you to review such third party providers’ applicable privacy policies for information on what information they collect about you and how they will use, maintain, protect and disclose that information. Two specific examples are as follows:

Use of LifeOmic Connect Service

You may choose to use the LifeOmic Connect service to place a telephone call, engage in a video conference, web chat, or otherwise communicate with a service professional or adviser. If you choose to use the LifeOmic Connect service in this manner, the LifeOmic Connect service will automatically transmit the following information to the service professional or adviser that you have chosen to interact with:

• Your name
• Your e-mail address

Additionally, in the course of your communications, interactions and transactions with such service professionals or advisers through the LifeOmic Connect service, you may choose to transmit certain additional information (including your personal information) directly to such service professionals or advisers. Once you direct us to disclose this information to the professional or adviser through the LifeOmic Connect service in this manner, you understand, acknowledge and agree that the applicable professional or adviser will independently have a right to determine the purposes for which it will process this information and the means it will use to process such information, subject in each case to the applicable business’s own privacy policy. You further understand, acknowledge and agree that we do not control (and are not responsible for) the applicable business’s policies and practices relating to their collection, use or disclosure of your information. We encourage you to review such third party providers’ applicable privacy policies for information on what information they collect about you and how they will use, maintain, protect and disclose that information. For further information, please refer to the LifeOmic Connect Privacy Policy, available online at https://cdn.connect-us.lifeomic.com/privacy-policy/.

Ordering Lab Tests or Other Services from Our Partners

Through the Services, we provide certain interfaces that enable you to (1) order lab tests or other services directly from certain third party providers that we have partnered with, and/or (2) view and store within the Services certain information provided from certain third party providers that we have partnered with. If you choose to use the Services in this manner, we may transmit some or all of the following information to the third party provider you have chosen to interact with:

• Your name
• Your e-mail address and other contact information (such as your mailing address, telephone number or mobile telephone number)

Additionally, in the course of your communications, interactions and transactions with such third party providers through the interfaces provided by the Services, you may choose to transmit certain additional information (including your personal information) directly to such third party providers. Once you direct us to disclose this information to the third party provider through the Service in this manner, you understand, acknowledge and agree that the applicable third party provider will independently have a right to determine the purposes for which it will process this information and the means it will use to process such information, subject in each case to the applicable third party provider’s own privacy policy. You further understand, acknowledge and agree that we do not control (and are not responsible for) the applicable third party provider’s policies and practices relating to their collection, use or disclosure of your information. We encourage you to review such third party providers’ applicable privacy policies for information on what information they collect about you and how they will use, maintain, protect and disclose that information.

PROMOTE SAFETY AND SECURITY 

We use the information we collect to promote the safety and security of the Services, our users and other parties. For example, we may use the information 

• to authenticate users;  
• to facilitate secure payments;  
• to respond to a legal request or claim, conduct audits, and enforce our terms and policies; 
• to investigate and protect against fraud, malicious or unauthorized access, and other illegal activities; and 
• to demonstrate and verify compliance with our internal policies and procedures, and applicable privacy and data security laws and regulations, such as HIPAA and GDPR. 

USE AND DISCLOSURE OF DE-IDENTIFIED INFORMATION 

“De-identified” means that we have removed, or rendered unreadable through complex computational algorithms, your personally-identifiable information, such as your name, address, or birthdate. We may use de-identified information that we have obtained from our Services for various purposes, including for example: 

• In accordance with regulatory requirements, we may de-identify, store and use your information for internal quality control, validation and research and development. This is important for LifeOmic Holdings to maintain high quality Services. We may use de-identified information as permitted by law.  
• We may contribute de-identified genetic variants that we have observed in the course of providing our Services to publicly available databases such as ClinVar. We do this to increase understanding and raise awareness of the significance of genetic variants within the medical and scientific communities. 
• We may use or disclose de-identified information for general research and communications purposes. This may include analysis of this information to communicate observations and learnings, for example in the case of aggregated data. This may also include research collaborations with third parties, such as universities, hospitals or other laboratories, in which we utilize de-identified clinical cases, at the individual level or in the aggregate, in accordance with our study protocols, and we may present or publish such information. This may also include commercial collaborations with private companies for purposes such as to determine the prevalence of particular disorders or variants among the patients we have tested, or to determine whether any of the patients we have tested might be suitable for potential recruitment for research, clinical trials, or clinical care.

We use cookies and similar technologies for the purposes described above. For more information, please read our Cookie Policy.  

For personal data subject to the GDPR, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and/or other tools; when the processing is necessary to perform a contract with you, like the Terms of Service; and our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above. 

AUTOMATED INDIVIDUAL DECISION-MAKING (PROFILING) 

We may create profiles to analyze or predict your health outcomes, personal preferences, interests and behavior.  However, we do not make any decision about you that would have legal consequences or similarly significant affects for you based solely on automated decision-making, including the use of such profiles.

HOW WE SHARE YOUR INFORMATION 

We do not share your personal information except in the limited circumstances described below.  

WHEN YOU AGREE OR DIRECT US TO SHARE 

You may direct us to disclose your information to others, such as when you use our social features in our Mobile Apps or as described in the section above titled “Connecting You to Others’ Products and Services”. For certain information, you may change your privacy preferences in account settings and use other provided tools to control how your information is visible to other users of the Services.  

You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account, or with your employer company or other organizations and provide consent to each organization. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs using your account settings. 

FOR EXTERNAL PROCESSING 

We transfer information to our corporate affiliates, service providers and other partners who process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys. 

FOR LEGAL REASONS OR TO PREVENT HARM 

We may preserve or disclose information about you to comply with a law, regulation, legal process or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect or investigate illegal activity, fraud, abuse, violations of our terms or threats to the security of the Services or the physical safety of any person. 

Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person. 

We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us or as part of the community benchmarking information we provide to users of our subscription services. 

IN CONNECTION WITH A MERGER, ACQUISITION OR SALE OF OUR ASSETS

We may disclose your personal information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction and any due diligence review with respect to any such proposed transaction.  If we are involved in such a transaction or related due diligence activities, we will continue to take measures to protect the confidentiality of personal information and give affected users notice for the transferring of any personal information to a new entity.

NO SALES OF PERSONAL INFORMATION

We do not sell your personal information to third parties (within the meaning provided in the California Consumer Privacy Act of 2018) and will not do so in the future without separately obtaining your prior express consent.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION 

You can access and control your personal information via account settings and/or our tools we provide to you, regardless of where you live.

REQUEST TO KNOW AND REQUEST TO DELETE

Subject to certain exceptions set forth under the California Consumer Privacy Act of 2018, you have a right to request that we disclose to you (and, if requested, to receive a portable copy of) the personal information about you that we collect, use, disclose and sell to third parties (a “Request to Know”), and you have a right to request that we delete your personal information that we have collected or that we maintain (a “Request to Delete”).  You may submit a Request to Know or Request to Delete by contacting us at our toll free telephone number, +1 855-LIFEOMIC (+1 855-543-3664), by visiting us on the web at https://lifeapps.io/contact/ and completing and submitting the interactive webform there, or by logging in to your password-protected account on the Site or the Mobile App and accessing the self-service portal we have provided for you there.  You can access the self-service portal by going to the app settings section located within the profile section of the app, and selecting the account deletion option from the list of items.

Upon receipt of your Request to Know or Request to Delete, we will take steps to verify your identity in order to confirm that the person making the request is actually the person about whom we have collected personal information (that the “you” making the request is actually you).  We verify such requests by asking users to log in to their existing password-protected accounts on the Site or the Mobile App and re-authenticate themselves by re-entering their user name and password.  If you choose to submit your Request to Know or Request to Delete using the telephone number or webform described above, we will respond (for verification purposes) by providing detailed instructions directing you to log in to your existing password-protected account on the Site or the Mobile App, access the self-service portal we have provided for you there (as described above), and re-authenticate yourself by re-entering your user name and password.  If you choose to submit your Request to Know or Request to Delete by logging in to your password-protected account on the Site or the Mobile App and accessing the self-service portal we have provided for you there (as described above), then for verification purposes we will ask you to re-authenticate yourself by re-entering your user name and password.

If you have submitted a verified Request to Delete, please note that while most of your information will be deleted within 14 days, it may take up to 90 days to delete all of your information, such as the data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the How We Share Your Information section.

You may also designate an authorized agent to make a Request to Know or Request to Delete on your behalf.  To designate an authorized agent to act on your behalf in this manner, you or your authorized agent must submit verifiable proof (acceptable to us, acting in our reasonable discretion) that either (1) such agent has actually been authorized in writing to act on your behalf, or (2) you have provided the authorized agent with power of attorney pursuant to the applicable laws in your jurisdiction.  You may submit such proof by e-mailing us at privacy@lifeomic.com.  If a duly-designated authorized agent makes a Request to Know or Request to Delete on your behalf, we will still require you to verify your own identity using the process described above, unless you have submitted verifiable proof to us that you have provided the authorized agent with power of attorney (in which case your submission to us of verifiable proof that you have provided the authorized agent with power of attorney, as described above, will serve as the required verification of your identity for purposes of processing the Request to Know or Request to Delete).

ADDITIONAL RIGHTS

In certain circumstances, you have a right under the law not to receive differential treatment by us as a result of your choice to exercise rights with respect to your personal information that are granted to you under applicable law.  Our treatment of you would be differential (and therefore prohibited by applicable law) if we treat you differently because you exercised a right with respect to your personal information that is granted to you under applicable law, subject to certain exceptions.  For more information, you should consult the privacy laws, rules and regulations that are applicable in your jurisdiction.

ADDITIONAL RIGHTS OF EUROPEAN DATA SUBJECTS

In addition, if you live in the European Economic Area, United Kingdom and Switzerland (the “Designated Countries”), you have a number of legal rights with respect to your information, as outlined below.

Accessing and Exporting Data. By logging into your account, you can access much of your personal information. Using your account settings, you can also request a download information in a commonly used file format, including data about your activities, body, foods and sleep. 

Editing and Deleting Data. Your account settings and certain platform APIs let you change and delete your personal information and/or account data. For instance, you can edit or delete the profile data you provide and delete your account if you wish. 

If you choose to delete your account, please note that while most of your information will be deleted within 14 days, it may take up to 90 days to delete all of your information, such as the data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the How We Share Your Information section. 

Objecting to Data Use. You can control usage of your data via account settings or other application APIs or tools. For example, you can

• limit how your information is visible to other users of the Services;  
• limit the notifications you receive from us; and  
• revoke the access of third-party applications that you previously connected to your account.  

If you live in a Designated Country, in certain circumstances, you can object to our processing of your information based on our legitimate interests, including as described in the How We Use Information section. You have a general right to object to the use of your information for direct marketing purposes. Please also review our Cookie Policy for your options to control how we and our partners use cookies and similar technologies for advertising. 

Restricting or Limiting Data Use. In addition to the various controls that we offer, if you reside in a Designated Country, you can seek to restrict our processing of your data in certain circumstances. Please note that you can always delete your account at any time.  

Onward Transfers of Data.    If we intend to disclose your personal information to any third party that will have the right to process it, we will enter into a contract with such third party that provides that your personal information may be processed only for limited and specified purposes consistent with the consent you have provided to us, that the third party must provide the same level of protection for your personal information that we are obligated to provide under this Privacy Policy while it is processing your personal information, and that the third party will notify us if it makes a determination that it can no longer meet these obligations (and in such a case such third party shall cease processing your personal information or otherwise be required to take reasonable and appropriate steps to remediate any unauthorized processing). Please note that in cases of onward transfer of your personal information to third parties processing your information on our behalf as our agent (our “Agents”), we will remain liable under the Principles of the E.U.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework if such Agents process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

In contrast, if we intend to disclose your personal information to any third party that will have the right to determine the purposes for which it will process your personal information and the means it will use to process your personal information (rather than just providing requested assistance to us in support of our permitted uses of your personal information) (such third parties, “Controllers”) we will notify you and present you an opportunity to opt out of such disclosure, and you should be sure to review such parties’ privacy policies for information on how they may use, disclose and protect your personal information.

Changes to Privacy Policy.  If we are using your personal information on the basis of your consent, and we change our Privacy Policy to permit any use or disclosure of your personal information that is materially different than the uses for which it was originally collected or subsequently authorized by you, we will obtain your consent before we make such further uses of your personal information. 

Further Assistance.  If you need further assistance regarding your rights, please contact our Data Protection Officer at privacy@lifeomic.com, and we will consider your request in accordance with applicable laws. You may also contact our EU representative at https://www.verasafe.com/privacy-services/contact-article-27-representative.

If you reside in a Designated Country and you are not satisfied with our response, you will have a prompt, no-cost way of asserting your claim by contacting our chosen independent dispute resolution body JAMS.  If you reside in a Designated Country, you may have the right, under certain conditions, to invoke binding arbitration, and, alternatively, you also have a right to lodge a complaint with your local data protection authority or with the Irish Data Protection Commissioner, our lead supervisory authority, whose contact information is available here.