Segterra, Inc. Privacy Policy

Legal Rights & Agreement Rules · Context

Privacy Policy last updated April 26, 2024

The Segterra (InsideTracker) Privacy Policy states that it was last updated on April 26, 2024.

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Last updated: April 26, 2024

Data Access & Collection · Context

Definitions of Personal Information, Blood Information, and Genetic Information

Segterra (doing business as InsideTracker and GoalGetter) defines Personal Information as data that could be used to identify you, Blood Information as data related to your blood tests, and Genetic Information as data related to your genotype for a specific set of genes.

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Segterra ("Segterra", "InsideTracker", "GoalGetter," "us," "our" or "we") recognizes the importance of privacy.

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.

Data Access & Collection · Context

Policy scope covers InsideTracker websites, mobile applications, products, and services

This Privacy Policy governs how InsideTracker collects, uses, maintains, and discloses information collected from users of its websites (including www.insidetracker.com) and any other website or mobile software application owned or operated by InsideTracker (the Platform), as well as all products and services (the Services) offered by InsideTracker.

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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.

Security & Safeguards · Restriction or exception

Users share responsibility for security and must keep passwords confidential

InsideTracker states that users share responsibility for maintaining privacy and security and asks users to keep their passwords secure and not share them with any third parties.

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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.

Legal Rights & Agreement Rules · Restriction or exception

Using InsideTracker Services requires agreeing to the Privacy Policy as part of the Terms of Service

The Privacy Policy applies to all new and existing InsideTracker users and forms part of the Terms of Service (Terms). Users must agree to the Privacy Policy to use the Services and may not use the Platform or Services if they do not agree. Unspecified capitalized terms take their meanings from the Terms of Service.

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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.

If you do not agree with the terms of this Privacy Policy, please do not use the Platform or Services.

Not stated here

• The full text of the Terms of Service is a separate document not supplied inside this Privacy Policy.

Use & Processing · Permission or license

Using the Platform and Services authorizes processing of Personal, Blood, and Genetic Information

By using the Platform and signing up for services provided by InsideTracker or on its behalf by contracted third parties, you allow InsideTracker to collect, use, and process your Personal Information, Blood Information, and Genetic Information according to the Terms of Service, the Product Consent, and this Privacy Policy. Policy questions may be sent to support@insidetracker.com.

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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.

Not stated here

• The separate Terms of Service and Product Consent documents referenced here are not supplied in this Privacy Policy text.

Sharing & Disclosure · Permission or license

Consent to partner transmission of blood and genetic data and transfer to offices, servers, and authorized third parties

By voluntarily providing Personal Information and agreeing to have partner companies transmit your blood data and/or genetic data to InsideTracker, you consent to its use in accordance with the Privacy Policy and Product Consent, and agree that Personal Information may be transferred from your current location to the offices and servers of InsideTracker and authorized third parties.

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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.

Not stated here

• The separate Product Consent document referenced here is not supplied in this Privacy Policy text.

Data Access & Collection · Company commitment

Privacy principles limit Personal Information collection to what is needed and use to specified purposes

Under its stated Privacy Principles, InsideTracker states that it does not collect any more Personal Information about you than it needs and only uses your Personal Information for the purposes specified in the Privacy Policy unless you agree otherwise.

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We follow the principles listed below to protect your privacy

We do not collect any more Personal Information about you than we need.

We only use your Personal Information for the purposes we specify in this Privacy Policy, unless you agree otherwise.

Qualifications & exceptions

• unless you agree otherwise

Sharing & Disclosure · Company commitment

Privacy principle against sharing Personal Information with third parties except as specified in the Policy

Under its stated Privacy Principles, InsideTracker states that other than as specified in the Privacy Policy, it does not share your Personal Information with third parties.

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Other than as we specify in this Privacy Policy, we do not share your Personal Information with third parties.

Qualifications & exceptions

• Other than as we specify in this Privacy Policy

Data Access & Collection · Company practice

Categories and sources of Personal Information collected across the Platform and Services

InsideTracker collects Personal Information—data that could identify you alone or combined with other information—when you buy Services, subscribe to newsletters, use the Platform, create an account, complete surveys and forms, or communicate with or request information from InsideTracker. Collected Personal Information may include name, email address, mailing address, date of birth, gender, credit card or bank account information, health/test/biometric information (such as blood biomarker data, height, weight, ethnicity, and heart rate), DNA (Genetic) information, registration information, self-reported information, user content, and web behavior information.

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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.

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.

Linking & Identification · Company practice

Personal Information collected online can be combined with Personal Information collected offline

InsideTracker states that Personal Information collected online can be combined with Personal Information collected offline.

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Personal Information collected online can be combined with Personal Information collected offline.

Data Access & Collection · Company practice

Registration Information is collected at signup to deliver Services, communicate, and confirm identity

When you register for InsideTracker Services, InsideTracker collects Registration Information such as your name, age, login credentials, and contact information (including email address), and uses it to deliver Services, communicate with you, and confirm your identity.

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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.

Use & Processing · Company practice

Blood biomarker data comes from partner labs or uploads and may be used de-identified for research

Blood biomarker data covers blood test results from InsideTracker laboratory partners as well as existing blood test results ordered by a doctor or insurance company that a user uploads. InsideTracker may use blood biomarker data in a de-identified, aggregated way for InsideTracker research.

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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.

Data Access & Collection · Company practice

Genetic information is collected via partners Helix or AKESOgen or from user-uploaded prior DNA tests

Genetic (DNA) information relates to your genotype for a specific set of genes tied to healthy aging, nutrition, weight, sleep, and physical activity. InsideTracker receives genetic information from partner Helix when you buy GoalGetter, from partner AKESOgen when you send a DNA sample using the InsideTracker DNA kit for extraction and analysis, or directly from you when you provide prior DNA test data for the genetics add-on service.

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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.

Inference & Profiling · Company practice

Algorithmic DNA trait analysis, R&D use of de-identified genetic data, and optional Research Consent for publication

InsideTracker analyzes your DNA data with an algorithm to determine your genetic potential for certain traits and may use aggregated, de-identified genetic data for research and development to improve future products. For research intended for scientific publication, InsideTracker requests separate permission through an optional, voluntary Research Consent document that is not required to use the Platform or Services.

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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.

Not stated here

• The separate Research Consent document referenced here is not supplied in this Privacy Policy text.

Use & Processing · Company practice

Self-Reported Information from questionnaires and surveys may be used in de-identified form for research

Self-Reported Information—such as sex, body weight, height, and diet provided in the InsideTracker questionnaire or other website surveys or forms—may be used in a de-identified way for InsideTracker research.

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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.

Data Access & Collection · Context

User Content covers public or private materials transmitted to InsideTracker besides Genetic or Self-Reported data

User Content is defined as all information other than Genetic Information or Self-Reported Information provided by users and transmitted publicly or privately to InsideTracker, including data, text, software, music, audio, photographs, graphics, video, messages, blog comments, and emails to customer support.

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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.

Data Access & Collection · Company practice

Web Behavior Information is collected via log files, cookies, web beacons, and analytics and advertising technologies

InsideTracker collects Web Behavior Information about how you use the Platform (such as browser type, domains, and page views) through log files, cookies, web beacons, and analytical and advertising technologies.

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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.

Sharing & Disclosure · Company commitment

Gift purchases require the recipient's own account and consent and withhold recipient data from the buyer

When you purchase InsideTracker as a gift, any information you provide about the gift recipient is used only as needed to deliver the gift. The gift recipient must create their own account, provide their own blood and genetic samples or data, and give their own consent, and InsideTracker will not share any Personal Information of the gift recipient with the purchaser.

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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.

Data Access & Collection · User right or choice

Users may refuse to supply Personal Information, which may limit access to Platform activities and Services

Users can always refuse to supply requested Personal Information, but refusing to supply information may prevent them from engaging in certain Platform-related activities and receiving certain Services and information.

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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.

Qualifications & exceptions

• 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.

Linking & Identification · Company practice

Non-Personal Information may be combined with registration data for troubleshooting or fraud detection

InsideTracker may collect Non-Personal Information when you interact with the Platform—including browser name, computer type, files viewed, clickstream data (pages or URLs visited), operating system, and internet service providers—and may review it in combination with specific registration information to identify and resolve individual user issues or detect fraud. To the extent Non-Personal Information is linked with Personal Information, the Privacy Policy governs its use.

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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.

Legal Rights & Agreement Rules · Restriction or exception

Personal, blood, and genetic data are disclaimed as electronic health or medical records under HIPAA

InsideTracker states that at no time shall your Personal Information, including blood data or genetic data collected under the Privacy Policy, be deemed an electronic health record or electronic medical record for any purpose, including compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

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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.

Cross-references

• qualifies (model-proposed): Segterra states compliance with HIPAA standards as applicable and directs HIPAA questions to support — qualifies: The Electronic Health Records Disclaimer states that Personal Information, blood data, and genetic data collected under the Policy are at no time deemed an electronic health or medical record for any purpose including HIPAA compliance, qualifying the HIPAA section statement that Segterra complies with federal laws and regulations including, as applicable, HIPAA.

Use & Processing · Company practice

Personal, blood biomarker, self-reported, and DNA information are used to produce InsideTracker and genetic analyses

InsideTracker collects and uses Personal Information—including blood biomarker data, height, weight, and ethnicity—along with Self-Reported Information to produce your InsideTracker analysis, and uses DNA Information when you buy genetic services to analyze your genetic potential.

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

We use your Personal Information, including blood biomarker data, height, weight, ethnicity, along with your Self-Reported Information to produce your InsideTracker analysis. If you buy InsideTracker genetic services, we will use your DNA Information to provide you with analysis of your genetic potential.

Use & Processing · Company practice

Provided information is used to process transactions, confirm orders, bill, and deliver products or services

InsideTracker uses information you provide to process transactions made on the Platform or as necessary to perform contractual obligations to you, including order confirmation, billing, and product or service delivery.

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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.

Use & Processing · Company practice

Customer support, group-usage analysis, and service improvement rely on legitimate business interests

On the basis of its legitimate business interests, InsideTracker uses information you provide to respond more efficiently to customer service requests and support needs, uses combined, de-identified information to understand how users as a group use the Services, and uses combined, de-identified information and user feedback to improve its Services.

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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.

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.

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.

Use & Processing · User right or choice

Marketing and promotional communications by email, text, web, or phone use consent and allow opt-out at any time

With your consent, InsideTracker uses your Personal Information, preferences, and transaction details to keep you informed by email, text, web, or telephone about its products and services—including tailored special offers, discounts, promotions, events, and competitions—and you may opt out from any of those channels at any time.

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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.

Of course, you are free to opt out from hearing from us by any of these channels at any time.

Use & Processing · Company commitment

Blood test results and DNA data are not used for marketing

InsideTracker commits that it does not use your blood test results or DNA data for marketing.

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We do not use your blood test results or DNA data for marketing.

Use & Processing · Company practice

Personal Information is used to respond to user inquiries and requests

InsideTracker uses your Personal Information to respond to your inquiries, questions, and other requests on the basis of its contractual obligations, legal obligations, and legitimate interests.

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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.

Sharing & Disclosure · Company practice

With consent, InsideTracker may present third-party offers without directly sharing your data with third parties

With your consent, InsideTracker may use your information to tell you about offers, programs, products, or services from third parties that may interest you, without directly sharing any of your data with any third party.

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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 without direct sharing any of your data with any 3rd part

Use & Processing · Company practice

Legally required and service-change notices by email or text do not require prior consent

InsideTracker uses Personal Information to send communications required by law or necessary to inform you about changes to the services or updates to the Privacy Policy. These non-promotional service messages do not require prior consent when sent by email or text message.

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As required by law To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Policy and other legally required notices or information. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your Personal Information for these purposes, we would be unable to meet our legal obligations.

Sharing & Disclosure · Company practice

Law enforcement disclosures under legal or contractual obligations include best-effort advance notice unless prohibited

InsideTracker may share data with law enforcement to comply with legal or contractual obligations and states that if required to disclose your information, it will do its best to provide advance notice unless prohibited by law.

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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.

Qualifications & exceptions

• will do our best to provide you with notice in advance, unless we are prohibited by law from doing so

Use & Processing · Company practice

Personal Information may be used for other purposes disclosed at collection or later with consent

InsideTracker may use your Personal Information to fulfill any other purpose for which you provide it, as disclosed at the time of collection or later with your consent.

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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.

Sharing & Disclosure · Company practice

Anonymized blood, fitness tracker, and self-reported data may be disclosed to commercial or non-profit research partners

InsideTracker may include anonymized blood test information, fitness tracker information, and self-reported information in disclosures to third-party research partners—including commercial or non-profit organizations conducting or supporting medical research or drug/device development—to advance and commercialize wellness, nutrition, and healthcare applications, while stating that no identifying information will be shared without your prior knowledge and consent.

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We may include your anonymized blood test information, fitness tracker information and self-reported information in disclosures to third parties for the purpose of research or other applications, but no identifying information will be shared without your prior knowledge and consent. InsideTracker research is intended to advance wellness and nutrition knowledge and to create, commercialize, or undertake activities toward the practical applications of this learning to the improvement of health care. Our research partners 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.

Sharing & Disclosure · User right or choice

Published scientific research using de-identified Genetic Information requires optional Research Consent

InsideTracker may ask permission to use your de-identified Genetic Information for research intended for scientific publication through a separate Research Consent document (https://www.insidetracker.com/research-consent), which is optional and voluntary and not required to use the website or services.

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We may ask permission to use your de-identified Genetic Information for research that we hope to publish in scientific publications. If you choose to give this permission, you will agree to a Research Consent document. The Research Consent document is optional and voluntary. You may use the website or services without agreeing to the Research Consent document.

Not stated here

• The linked Research Consent document (https://www.insidetracker.com/research-consent) is an external document whose text is not supplied in this Privacy Policy.

Security & Safeguards · Company commitment

InsideTracker uses industry-standard and commercially reasonable safeguards but cannot guarantee absolute security

InsideTracker states that it has adopted generally accepted industry standards and employs commercially reasonable technical and organizational safeguards to protect against unauthorized access, alteration, disclosure, or destruction of Personal Information, usernames, passwords, transaction information, and stored data, but cannot guarantee absolute security because no Internet transmission or electronic storage method is 100% secure.

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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.

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.

Qualifications & exceptions

• while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security

Security & Safeguards · Restriction or exception

Users must safeguard authentication credentials and immediately report unauthorized password use

InsideTracker asks users to safeguard their passwords, secret questions and answers, and other authentication information, not disclose authentication information to any third party, and immediately notify InsideTracker of any unauthorized password use.

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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.

Legal Rights & Agreement Rules · Restriction or exception

InsideTracker disclaims responsibility and liability for information you release or ask it to release

InsideTracker states that it cannot secure and will have no responsibility or liability for any consequences resulting from Personal Information or Genetic Information that you release on your own, share with a third party, or request or authorize InsideTracker to release.

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We cannot secure Personal Information that you release on your own or that you request us to release.

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.

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.

Sharing & Disclosure · Context

User-initiated sharing of genetic data may expose it to non-GINA insurers or place it in medical records

Users may choose to disclose Personal Information or Genetic Information outside InsideTracker to family, friends, third-party providers, or healthcare professionals. InsideTracker notes that while the Genetic Information Nondiscrimination Act of 2008 (GINA) states you are not required to share genetic information with an employer or health insurer, life, long-term care, and disability insurers may ask for it, and sharing genetic data with a doctor or health professional may make it part of your medical record accessible to other health professionals and health insurance companies.

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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.

Legal Rights & Agreement Rules · Permission or license

InsideTracker reserves the right to update privacy and security policies and practices at its sole discretion

InsideTracker reserves the right to update its privacy and security policies and practices from time to time at its sole discretion.

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We reserve the right to update our privacy and security policies and practices from time to time at our sole discretion.

Security & Safeguards · Restriction or exception

Users acknowledge that safeguards can be circumvented and hackers or malware may access data over the Internet

Users acknowledge and agree that security safeguards are capable of circumvention, that InsideTracker does not operate or control the Internet, and that InsideTracker cannot guarantee that unauthorized persons (such as hackers using viruses, worms, Trojan horses, keystroke loggers, or other malware) will not overcome safeguards to damage the site or access personally identifiable information transferred over the Internet.

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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.

Sharing & Disclosure · Company practice

Aggregated or non-Personal Information may be disclosed without restriction

InsideTracker states that it may disclose aggregated or other non-Personal Information about its users without restriction, and may disclose Personal Information in the ways and to the third parties described in the Privacy Policy.

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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.

Sharing & Disclosure · Company practice

Personal Information may be disclosed to parents, affiliates, joint ventures, promotion partners, and service providers

InsideTracker may disclose Personal Information to its parents, affiliates, joint ventures, or promotion partners for use consistent with the Privacy Policy, and to contractors, service providers, and other third parties used to support its business, provide the Services, complete transactions, or perform services on InsideTracker's behalf or for your benefit.

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Affiliates. To our parents, affiliates, joint ventures, or promotion partners, for their use in a manner consistent with the purposes described in this Privacy Policy.

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.

Sharing & Disclosure · Company practice

With consent, personal data may be shared with third parties for direct marketing, excluding identifiable PHI

With your consent, InsideTracker may share your personal data with third parties for their own direct marketing purposes, to provide information about products of interest, for other purposes set forth in the Privacy Policy, or in additional ways upon your consent. InsideTracker states that it does not share any identifiable PHI data with third parties for marketing purposes.

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Marketing. With your consent, we may share your personal data to third parties for their own direct marketing purposes, to provide you with information about products that may be of interest to you, and for other purposes as specifically set forth in this Privacy Policy. We do not share any identifiable PHI data with third parties for marketing purposes.

Consent. In additional ways upon your consent.

Sharing & Disclosure · Company practice

Disclosures for subpoenas, legal process, safety, fraud, or government requests include best-effort advance notice

InsideTracker may disclose Personal Information as required by law (such as to comply with a subpoena or other legal process) or when it believes in good faith that disclosure is necessary to protect its rights, protect your safety or others' safety, investigate fraud, or respond to a government request, and states it will do its best to provide advance notice unless prohibited by law.

Supporting quotations

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.

Sharing & Disclosure · Company practice

Personal Information may be disclosed in corporate transactions, bankruptcy, or receivership

Personal Information may be disclosed as part of a corporate business transaction—such as a merger, acquisition, joint venture, financing, or sale of company assets—or in the event of insolvency, bankruptcy, or receivership. InsideTracker states it will use reasonable efforts to direct any transferee to use your Personal Information consistently with the Privacy Policy.

Supporting quotations

Certain Business Transfers. As part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. We will use reasonable efforts to direct any such transferee to use your Personal Information in a manner that is consistent with our Privacy Policy.

Account & Service Control · User right or choice

Right to request a copy of Personal Information (with identity verification) and request corrections

You have the right to request a copy of any Personal Information InsideTracker holds about you—subject to InsideTracker requesting proof of your identity before sharing it—and to ask InsideTracker to correct information that is incorrect or out of date.

Supporting quotations

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.

Retention & Deletion · User right or choice

Requests to stop processing or delete data are subject to transaction fulfillment and legal retention bases

You may ask InsideTracker to stop processing or delete the personally identifiable data held about you in certain circumstances, though InsideTracker states it may not be possible to stop processing or delete all information where it is fulfilling a transaction or has a legal basis to retain the information.

Supporting quotations

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 where 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.

Account & Service Control · User right or choice

Rights to withdraw consent, request data portability to a third party, and lodge EU data protection complaints

When InsideTracker processes information based on consent, you may withdraw consent or ask to stop or restrict processing at any time. You may also ask InsideTracker to transfer your Personal Information to a third party in certain circumstances, and if you are in the European Union, you have the right to lodge a complaint at any time with your country's data protection authority.

Supporting quotations

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.

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.

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 & Deletion · Company practice

Information is retained as long as needed for services, legal obligations, dispute resolution, and enforcement

InsideTracker retains your information for as long as needed to fulfill your requests, provide services, comply with legal obligations, resolve disputes, and enforce its agreements.

Supporting quotations

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.

Account & Service Control · User right or choice

Users can unsubscribe from marketing emails but cannot opt out of non-promotional service communications

Users who receive marketing emails can unsubscribe by clicking "unsubscribe" within each email, but may not opt out of non-promotional, service-related communications.

Supporting quotations

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.

Retention & Deletion · User right or choice

Account closure removes account Personal Information but retains R&D/study de-identified data and order history

Use of InsideTracker is voluntary and you may cancel at any time or close your account by emailing support@insidetracker.com. Closing an account removes Personal Information within your account, but does not remove previously provided information used as de-identified statistical information in ongoing or completed internal R&D or business activities, de-identified genetic information used in ongoing or completed studies under a separate Research Consent, data held by business partners (whom you must contact separately), or limited order-history data (name, contact, and transaction data) kept for accounting and compliance.

Supporting quotations

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 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.

Not stated here

• The separate Research Consent document referenced here is not supplied in this Privacy Policy text.

Account & Service Control · User right or choice

Personal Information may be updated on the Profile page or reset in surveys/forms via customer support

If your Personal Information changes, you may correct or update it on your Profile page, or correct or reset Personal Information entered into a survey, form, or feature by emailing support@insidetracker.com with the name of the specific survey, form, or feature.

Supporting quotations

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.

Legal Rights & Agreement Rules · Restriction or exception

InsideTracker is not responsible for third-party websites linked on the Platform

InsideTracker states that it does not control the content or links on partner, supplier, advertiser, sponsor, licensor, or other third-party websites linked to or from the Platform and is not responsible for their practices. Browsing and interacting with any other website is subject to that website's own terms and policies, and this Privacy Policy applies solely to information collected by InsideTracker.

Supporting quotations

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.

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.

Data Access & Collection · Company practice

Log files automatically record IP addresses, browser, ISP, viewed files, OS, timestamps, and clickstream data

InsideTracker automatically gathers information and stores it in log files—including IP addresses, browser type, internet service provider (ISP), referring/exit pages, files viewed on the Platform, operating system, date/time stamp, and clickstream data—to analyze aggregate trends and administer the Platform.

Supporting quotations

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.

Data Access & Collection · Company practice

Persistent, session, first-party, and third-party advertiser cookies track movement and aggregate demographics

InsideTracker uses persistent cookies (which remain until expiration or deletion), session cookies (which last only while on the Platform), first-party cookies, and third-party cookies placed by third parties such as advertisers to store session information, analyze trends, run the Platform, track users' movements on InsideTracker, and gather aggregate demographic information.

Supporting quotations

InsideTracker uses cookies. A cookie is a small text file that is stored on a user’s computer when visiting certain websites. We use cookies or similar technologies to store session information, analyze trends, run the Platform, track user's movements on InsideTracker, and gather demographic information about our user base as a whole. These cookies are only applicable within our 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.

Account & Service Control · User right or choice

Browser cookie rejection may limit Platform access; industry opt-out links are provided for advertiser tracking

Users can modify browser cookie settings to reject cookies, though rejecting cookies may prevent full access to and use of the Platform. The Policy also links to the Digital Advertising Alliance (www.aboutads.info), Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp), and European Digital Advertising Alliance (www.youronlinechoices.eu) for advertiser collection and use choices, and includes a cookie-list link that points back to https://www.insidetracker.com/policy-privacy.

Supporting quotations

Please click here for a list of the cookies used on our site. You can modify your cookie setting by following the instructions provided by your browser. These instructions are usually found in the "Tools", "Help" or "Edit" tabs. If you set your browser to reject cookies, you may not be able to fully access and use our Platform. You can learn more about the choices provided by advertisers for individuals to decide how their information is collected and used by visiting the Digital Advertising Alliance (www.aboutads.info), the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) or the European Digital Advertising Alliance (www.youronlinechoices.eu).

Not stated here

• The link for 'a list of the cookies used on our site' points back to https://www.insidetracker.com/policy-privacy rather than a separate cookie table, and external DAA, NAI, and EDAA pages are not supplied in this source.

Legal Rights & Agreement Rules · Company practice

Material Privacy Policy changes receive advance notice on the page, by email, or on the Platform

InsideTracker may update the Privacy Policy at any time at its discretion and will revise the updated date at the top of the page. For material changes, InsideTracker will notify users on the Policy page, by email, or via a Platform notice before the change takes effect, while users agree it is their responsibility to review the Policy periodically.

Supporting quotations

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.

Account & Service Control · Restriction or exception

Users under 18 are not permitted to use the Services and any collected under-18 Personal Information is deleted

The Platform and Services are intended for adults and users under 18 are not permitted to use the Services. InsideTracker does not knowingly collect or solicit Personal Information from children under 18 and states it will delete any such information if learned of.

Supporting quotations

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.

Use & Processing · Company practice

Personal Data is processed and stored in the United States, where data protection laws may differ

Segterra (InsideTracker) is located and hosts the Platform in the United States of America, and processes and stores Personal Data in the United States, which may have different data protection laws than the country in which you reside.

Supporting quotations

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.

Account & Service Control · User right or choice

California residents may request information on third-party direct-marketing disclosures under Civil Code § 1798.83

Under California Civil Code Section 1798.83, California residents may request information regarding InsideTracker's disclosure of Personal Information to third parties for their direct marketing purposes by contacting InsideTracker.

Supporting quotations

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.

Legal Rights & Agreement Rules · Company commitment

Segterra states compliance with HIPAA standards as applicable and directs HIPAA questions to support

Segterra (InsideTracker / GoalGetter) states that it is compliant with HIPAA Standards for Privacy, Electronic Transactions, and Security (including the HITECH Act and the 2013 Omnibus Rule), maintains policies, procedures, and reporting mechanisms for federal security compliance, and provides its programs and services in accordance with applicable federal laws including HIPAA. Questions regarding HIPAA policies or compliance may be directed to support@insidetracker.com. Earlier in the Policy, however, the Electronic Health Records Disclaimer states that Personal Information, blood data, and genetic data collected under this Policy are at no time deemed an electronic health or medical record for any purpose, including HIPAA compliance.

Supporting quotations

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.

Qualifications & exceptions

• including, as applicable, HIPAA

Not stated here

• The Policy does not specify which InsideTracker programs or data flows are treated as subject to HIPAA ('as applicable') versus covered by the earlier Electronic Health Records Disclaimer stating that Personal, blood, and genetic data collected under the Policy are not deemed electronic health or medical records for HIPAA compliance.

Sharing & Disclosure · Context

Clinician oversight services are provided by Wheel Provider Group under separate linked terms and notices

The Policy states that clinician oversight services are provided by Wheel Provider Group and directs users to Wheel Provider Group's separate Terms of use, Notice of privacy practices, and Telehealth informed consent for more information.

Supporting quotations

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

Not stated here

• Wheel Provider Group's linked Terms of use, Notice of privacy practices, and Telehealth informed consent are separate external documents whose text is not supplied in this Privacy Policy.

Account & Service Control · Procedure

Privacy Office contact information for privacy questions and dealings with Segterra, Inc.

Users with questions about this Privacy Policy, the practices of the Platform, or their dealings with InsideTracker may contact the Privacy Office at Segterra, Inc. (InsideTracker), One Broadway, 14th Fl, Cambridge, MA 02142, by telephone at +1 (800) 513-2359, or by email at privacy@insidetracker.com.

Supporting quotations

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