Segterra, Inc. Privacy Policy

InsideTracker · agreement dated April 26, 2024 · Official agreement

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Segterra (InsideTracker) – Privacy Policy

Last updated: April 26, 2024

Introduction

Segterra ("Segterra", "InsideTracker", "GoalGetter," "us," "our" or "we") recognizes the importance of privacy. We respect your desire to store and access your information in a private and secure manner. This Policy explains how we handle your Personal Information, Blood Information and Genetic Information. Your Personal Information is data that could be used to identify you. Your Blood Information is data related to your blood tests. Your Genetic Information is data related to your genotype for a specific set of genes.

This Privacy Policy governs the way in which we collect, use, maintain, and disclose information collected from users of our websites. These websites may include but are not limited to www.insidetracker.com, and any other website or mobile software application owned or operated by InsideTracker (the "Platform"). This Privacy Policy applies to the Platform and all products and services (collectively, the "Services") offered by us. We are committed to providing you a secure, user-controlled Platform. At the same time, you share responsibility for maintaining privacy and security. For example, we ask you to keep your password secure. Do not share it with any third parties. We urge you to read this Privacy Policy carefully.

The Policy applies to all new and existing InsideTracker users. To use the InsideTracker Services, you must agree to the Privacy Policy. You may not use the Services if you do not agree to the Privacy Policy because it is part of the Terms of Service ("Terms"). Any capitalized terms not defined in the Privacy Policy have the same meaning as those in the Terms.

Our Terms of Service explains that, by using our Platform and signing up for services provided by InsideTracker or on our behalf by third parties with whom we contract, you are allowing us to collect, use and process your Personal Information, Blood Information and Genetic Information according to the Terms, the Product Consent and this Privacy Policy. If you have any questions about this Policy, please contact us at support@insidetracker.com. If you do not agree with the terms of this Privacy Policy, please do not use the Platform or Services.

By voluntarily giving us Personal Information and agreeing to have partner companies transmit your blood data and/or your genetic data to us, you are consenting to our use of it in accordance with this Privacy Policy and our Product Consent. If you give Personal Information to us, you agree that such Personal Information may be transferred from your current location to the offices and servers of InsideTracker and third parties we authorize.

Privacy Principles

We follow the principles listed below to protect your privacy

Information we collect

  • Personal Information (Data). InsideTracker 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 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 InsideTracker service we will also collect certain health, test, and biometric information, including, but not limited to, blood biomarker data, height, weight, ethnicity, and heart rate. If you buy the InsideTracker genetics service, we will also collect certain DNA (Genetic) information. Personal information may include registration information, blood biomarkers information, DNA information, self-reported information, user content and web behavior information.
  • Registration Information is information that we collect from you when you register for InsideTracker 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.
  • Blood biomarker data is data related to your blood test results from tests done by InsideTracker laboratory partners. You may also upload existing blood test results from tests ordered by your doctor or insurance company. We may use your blood biomarker data in a de-identified, aggregated way for InsideTracker research.
  • Genetic (DNA) information is data related to your genotype for a specific set of genes related to healthy aging, nutrition, weight, sleep and physical activity. InsideTracker will receive your genetic information from our partner Helix when you buy the GoalGetter product. When you purchase the InsideTracker DNA kit, you will collect a DNA sample using the provided collection kit and send it to our partner AKESOgen for DNA extraction and analysis. If you purchase our genetics add-on service, you will provide your genetic data from DNA tests that you have previously had done. InsideTracker analyzes your DNA data using an algorithm that determines your genetic potential for certain traits. InsideTracker may use your aggregated, de-identified genetic data for research and development to improve future products. For research that we hope to publish in scientific publications, we will request separate permission through a Research Consent document to use your de-identified Genetic Information. Any Research Consent is optional and voluntary. You will not be required to agree to a Research Consent document in order to use the Platform or Services.
  • Self-Reported Information includes information you provide in the InsideTracker questionnaire or in any other website surveys or forms, such as sex, body weight, height, diet, etc. We may use your Self-Reported Information in a de-identified way for InsideTracker research.
  • User Content is all information other than Genetic Information or Self-Reported Information provided by the users of the InsideTracker Services and transmitted, whether publicly or privately, to InsideTracker. User content may include data, text, software, music, audio, photographs, graphics, video, messages, or other materials. For example, user content includes comments made on InsideTracker 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 InsideTracker 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 also must provide their own blood and genetic samples or data depending on the InsideTracker plan selected. The gift recipient must provide their own consent. No one else can consent for them. InsideTracker will not 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.

  • Non-Personal Information. We may collect non-Personal Information about you when you interact with our Platform. Non-Personal Information may include your browser name, type of computer, and the files you viewed on the Platform. Clickstream data, (i.e. a list of pages or URLs visited), and technical information about how you connect to the Platform, such as the operating system and the internet service providers used, are other types of non-Personal Information that we may collect. We may, in some cases, need to review this automatically collected data in combination with specific registration information to identify and resolve issues for individual users, detect fraud, etc. To the extent that we link this non-Personal Information with your Personal Information, this Privacy Policy governs our use of such information.
  • Electronic Health Records Disclaimer. At no time shall your Personal Information, including blood data or genetic data collected from you in accordance with this Privacy Policy be deemed to be an electronic health record or an electronic medical record for any purpose, including without limitation for purpose of compliance with the Health Insurance Portability and Accountability Act of 1996.

How we may use your Personal Information

We may collect and use Personal Information for the following purposes:

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. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. 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.

In addition, you may choose to disclose, through other means not associated with us, any part of your Personal Information and/or Genetic 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.

The Genetic Information Nondiscrimination Act of 2008 (GINA) says that you are not required to share your genetic information with your employer or your health insurance company. Other companies, such as life insurance, long-term care insurance, and disability insurance companies, may ask you to share your genetic information. Always be careful with whom you choose to share your genetic information as it is your ultimate right and choice to share such information.

If you do choose to share genetic data with your doctor or other health professional, those genetic data may become part of your medical record. Other health professionals and health insurance companies may be able to access the genetic 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 Genetic Information with a third party. It is your responsibility to share Personal Information and Genetic Information only with people you know and trust.

We reserve the right to update our privacy and security policies and practices from time to time at our sole discretion. We will employ commercially reasonable technical and organizational safeguards against unauthorized disclosure or access to your data or other personally identifiable information about you, consistent with our Privacy Policy. HOWEVER, YOU ACKNOWLEDGE THAT SECURITY SAFEGUARDS, BY THEIR NATURE, ARE CAPABLE OF CIRCUMVENTION AND INSIDETRACKER DOES NOT AND CANNOT GUARANTEE THAT PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU WILL NOT BE ACCESSED BY UNAUTHORIZED PERSONS CAPABLE OF OVERCOMING SUCH SAFEGUARDS. IN PARTICULAR, OUR PLATFORM MAY BE USED TO ACCESS AND TRANSFER INFORMATION, INCLUDING PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU OVER THE INTERNET. YOU ACKNOWLEDGE AND AGREE THAT INSIDETRACKER DOES NOT OPERATE OR CONTROL THE INTERNET AND THAT UNAUTHORIZED USERS (SUCH AS HACKERS) MAY USE VIRUSES, WORMS, TROJAN HORSES, KEYSTROKE LOGGERS AND OTHER UNDESIRABLE DATA AND SOFTWARE TO OBTAIN ACCESS TO OR DAMAGE OUR SITE OR TO ACCESS PERSONALLY IDENTIFIABLE INFORMATION ABOUT YOU. Furthermore, we cannot be responsible for any personally identifiable information about you that you release on your own, or that you request or authorize us to release.

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.

Your Rights

Closing or correcting your account

Your use of the InsideTracker 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 InsideTracker Services, you may close your account by sending a request to Customer Support at support@insidetracker.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 genetic 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 support@insidetracker.com and including the name of the specific survey, form, or feature.

Third-party websites

You may find advertising or other content on the Platform that link to the websites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these websites. We are not responsible for the practices employed by websites linked to or from the Platform. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing on and interacting with any other website, including websites which have a link to the Platform, are subject to that website's own terms and policies. We encourage you to read the Privacy Policies of each website that you visit. This Privacy Policy applies solely to information collected by InsideTracker.

Cookies and other tracking technologies

Changes to this privacy policy notice

We have the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date at the top of this page. If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on the Platform prior to the change becoming effective. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications.

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

Segterra (InsideTracker) 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.

HIPAA

Segterra ("Segterra", "InsideTracker", "GoalGetter", "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: support@insidetracker.com.

Clinician Oversight Services

The provision of clinician oversight services is provided by Wheel Provider Group. For more information, visit their Terms of use, Notice of privacy practices, and Telehealth informed consent

CONTACTING US

If you have any questions about this Privacy Policy, the practices of the Platform, or your dealings with us, please contact us at:

Privacy Office

Segterra, Inc. (InsideTracker)

One Broadway, 14th Fl, Cambridge, MA 02142

Tel: +1 (800) 513-2359

Email: privacy@insidetracker.com