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PRIVACY POLICY

Last updated January 31, 2018

PhysioAge Systems LLC ("PhysioAge", "us", "our", or "we") is committed to protecting your privacy. Our privacy policy, which applies to all users of our Website and Services, is designed to explain the information we collect and how we use it to provide our services and give users a better experience ("Privacy Policy"). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use . This Privacy Policy is part of, and incorporated into, the Terms of Use.

 

By accessing and using the Website and/or Services, you consent to our collection, storage, use and disclosure of your Personal Information (defined below) and other information as described in this Privacy Policy.

 

IF YOU ARE A USER ACCESSING THE WEBSITE OR SERVICES FROM THE EUROPEAN UNION, ASIA OR ANY OTHER REGION WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE AND DISCLOSURE THAT DIFFER FROM UNITED STATES LAW, THIS PRIVACY POLICY, AND OUR TERMS OF USE, YOU ARE TRANSFERRING YOUR PERSONAL INFORMATION TO THE UNITED STATES AND YOU CONSENT TO THAT TRANSFER. ADDITIONALLY, YOU UNDERSTAND THAT YOUR PERSONAL INFORMATION MAY BE TRANSFERRED TO AND PROCESSED IN COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE PROCESSING OF PERSONAL INFORMATION IN YOUR COUNTRY.

Types of Information We Collect

We collect both "Personal Information" and "Anonymous Information" about our users. Personal Information is information that can be used to contact or identify you, such as your full name, email address and phone number, as well as information that is linked to such information. "Anonymous Information" is information that cannot be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on the Services, such as usage data, to the extent that information is not linked to your Personal Information.

 

Authorized Users can access and browse certain portions of the Website and Services without disclosing Personal Information, although, like most website providers, we may passively collect certain information from your devices, such as your Internet Protocol ("IP") address and browser information. Please note that you can choose not to provide us with certain information, but this may not allow you full utilization of the Website and Service.

Voluntarily submitted information

We collect information that you provide to us during your use of the Website and/or Services, such as:

 

Personal Information that you or your clinician enter when creating or updating an Account, or that we receive about you from a third party, such as a lab, including your full name, email address and phone number.

 

Your communications with us through the Services. Information you provide in your Account or to our support team.

Information collected via technology

We may collect information from your use of the Website and Services, including your hardware model, browser type, operating system and IP address. If you are using a mobile device, PhysioAge may also receive your unique device identifier, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use cookies and URL information to gather information regarding the date and time you used the Website and Services and the information for which you searched and accessed. "Cookies" are small pieces of information that a website sends to your device while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help directions.

 

We use third party services, such as Google Analytics, to track the volume, source and flow of visitors to our Website. We do this to better understand how you use the Website and Services, with a view to offering improvements for all Authorized Users, and to tailor our business activities accordingly. If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en.

How We Use Your Information Personal Information

We may use your Personal Information for the following representative purposes:

  • Register and administer your Account, and provide customer support

  • Send communications and administrative emails

  • Personalize and tailor the features, performance and support of the Website and Services

  • Send you promotional information, newsletters, offers or other information from us or on behalf of our sponsors or partners

  • Improve the quality of the Website and Services and perform internal operations, such as fraud detection

  • Analyze, benchmark and conduct research on user data and interactions with the Services

  • Analyze and evaluate information about your health status and health indicators

Anonymous Information

We may use Anonymous Information for the following representative purposes:

  • Improve the Website and Services and customize the user experience, such as by providing targeted useful features based on the type of services you seek

  • Aggregate the information collected via Cookies and similar technologies to use in statistical analysis to help us track trends, market and promote our products, refine our offerings and communications and analyze patterns

  • Aggregate clinical data to provide context about relative health status and health indicators

How We Share and Disclose Information

We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third parties except as specifically approved by you at the time of disclosure or under the circumstances described in this Privacy Policy.

 

If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to provide your Personal Information and/or become an Authorized User. Notwithstanding the foregoing, when we receive Authorized Materials from a lab or other contracted third party that include Personal Information, such Authorized Materials will be matched with the appropriate Authorized User and entered into our system accordingly.

 

In addition to using the information collected by us for the purposes described in Section 2 above, we may also share your information as described below. Please review our sharing policy closely, especially with respect to your Personal Information. By becoming an Authorized User, you agree to allow us to share the Personal Information you provide to us in the ways described below. Your ability to make changes to the information shared is also described below.

Service Providers

We share Personal Information with vendors, consultants, payment processers and other third party service providers (collectively, "Service Providers") who perform services on behalf of - and at the request of - PhysioAge, including without limitation, companies that host our Website and provide our software. We only provide Service Providers with Personal Information that is necessary for them to undertake the particular work that we have delegated to them. In order words, Personal Information is only provided on a need-to-know basis. PhysioAge has selected companies who maintain high standards with respect to privacy and agree to use Personal Information only to perform specific services on behalf of PhysioAge and in accordance with the terms and conditions of this Privacy Policy.

Compliance with Laws, Law Enforcement and Safety

We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend PhysioAge's, or a third party's, rights or property.

Aggregated Anonymous Information

Aggregated anonymous information, or de-identified information, is the combination of your Anonymous Information with the Anonymous Information of other users ("Aggregated Anonymous Information"). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties for marketing and research purposes, among other purposes.

Business transactions

In the future, we may share all or some of your Personal Information with any of our subsidiaries, joint venturers or other companies under common control, in which case we will require them to honor this Privacy Policy. Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy.

Your Choices

As an Authorized User, you consent to receive certain communications from us. You may modify or opt out of receiving messages sent for marketing purposes, or certain other communications, by adjusting your Account settings or following the unsubscribe instructions in such messages. Please note that despite any indicated marketing preferences, we may send you administrative emails regarding the Website or Services, including, for example, notices of updates to our Privacy Policy.

Updating Your Personal Information

You may revise certain Personal Information by adjusting your Account settings or by contacting us directly at team@physioage.com. However, please note that we may be required to maintain certain Personal Information, or to maintain certain Personal Information for a period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from our active database, but may remain in our archives. We may also retain your information for fraud detection or similar purposes. Note that if we have already disclosed some of your Personal Information to third parties, we cannot access that Personal Information any longer and cannot compel the deletion or modification of any such information by the parties to whom we have made those disclosures.

Children

This Website is not directed or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Website is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user's Personal Information from our systems and delete the Account. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at team@physioage.com so that we may delete and remove such information from our system.

Security and Data Retention

We are very concerned with safeguarding your information. We employ all reasonable administrative, physical and electronic measures designed to protect your information from unauthorized access, including 256-bit TLS encryption. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations.

 

Your consent to such purpose remains valid after termination of our relationship with you.

Third Party Materials

PhysioAge may provide links to other websites, or content and materials, that are owned and/or operated by third parties ("Third Party Materials"). PhysioAge does not investigate or monitor such Third Party Materials, and therefore is not responsible or liable for the same. Moreover, PhysioAge is not responsible for the privacy practices employed by third party websites, nor are we responsible for the information or content they contain. This Privacy Policy applies solely to information collected by us through the Website and Services; thus, when you use a link to go from our Website to a third party website, this Privacy Policy is no longer in effect. We encourage users to read and consider the privacy policies of these other websites before using them.

Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in an adverse, materially different way from the uses described in this Privacy Policy without giving you an opportunity to opt out. Your continued use of the Services after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly.

California Privacy Rights

Under California's "Shine the Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties. direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at team@physioage.com.

Contact Us

If you have any questions regarding our Privacy Policy, you can contact us via email at team@physioage.com or send us a letter to PhysioAge Systems LLC, 30 Central Park South, Suite 8A, New York, NY 10019.

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