Unified Privacy Policy

Last Updated: July 13, 2017


This privacy policy sets forth Epigenetic Data Sciences, Inc.’s data collection, use and disclosure practices, including the collection, use and disclosure of information that can be used on its own or with other information to identify, contact, or locate an individual person (“Personally Identifiable Information”). Personally Identifiable Information does not include, however, any information that you post or make available publicly, unless a specific applicable law protects such information.

Unless otherwise stated below, this Privacy Policy applies to all websites and applications we may provide, including applications that run natively on a computer or a mobile device. If an application also has its own Privacy Policy, to the extent that there are any conflicts, that application specific Privacy Policy will supersede any provisions of this Privacy Policy.

General: Privacy Policy effectiveness; changes to policy

This Privacy Policy is a part of the Terms of Service ("TOS") set forth at https://www.epigeneticds.com/EDS_Terms.html, which are incorporated herein by reference. Capitalized terms herein not otherwise defined shall have the meaning set forth in the TOS. This Privacy Policy is updated as of the date set forth above. We reserve the right to update this Privacy Policy. If we update this Privacy Policy, we will use reasonable electronic efforts to advise You of the change, which may include posting a notice of the change on the website or application, in or near a login area, or we may send You an electronic notification of the change. If we electronically notify You by an electronic communication, we will provide these electronic messages to your last known or provided electronic communication address (which may be for example, a text message address, email address, twitter user name, Facebook address or other electronic address). You are responsible to review communications we send to those addresses, to authorize communications from us and to keep those addresses up to date. Use of the website or application after our notice of a change in the Privacy Policy is acceptance of the terms and changes in the updated Privacy Policy, which shall, unless expressly prohibited by applicable law (or unless expressly stated in such changed Privacy Policy), be effective from the inception of your use of the website or application.

What data do we collect?

Automated data collection: Our website and applications use standard web and software technologies to collect certain non-identifying information about your computer or device – which may include such information as your browser and computer type, your internet protocol address, the type of device you are using, and other information that your device sends to our website or application automatically. Our website and applications may also automatically set “cookies” – small files that contain information that allow the website or application to track certain information such as where you were referred from, which pages you have clicked on, and other analytical information about your use of the website or application. Collectively this information is referred to as “Automated Data.” We do not link or associate Automated Data we collect with your name or email address. We may use and disclose Automated Data in any manner we choose without restriction. You have some ability, by using browser plugins, ad blockers, or other third party tools, to block or prevent some collection of Automated Data, however, our website or applications may not function correctly if you do so. We make no guarantees of any kind that our website or applications will function correctly in any particular environment or with any plugins or other tools.

Manual data collection: When using our services such as by ordering or registering, you may be asked to enter Personally Identifiable Information such as your email addresses, phone numbers, mobile device number, text message and/or social media contact information, physical mailing address, and other similar billing and communication information (“Contact Information”). In addition, because our services involve knowing your health and medical condition, we also collect health and medical information, which may include as examples, your cancer diagnosis, your genetic makeup and other similar information regarding your health condition (the “Medical Information”). We do link Contact Information and Medical Information, however, without your opt in or other consent, we do not sell or disclose Contact Information or Medical Information to anyone except (A) you or someone who has logged into our service as you; or (B) as permitted in the section “How Do We Use your Information.”

Third party data collection. We may also obtain information from third parties and we may combine that with Automated Data and/or Contact Information/Medical Information . For example, we may have access to certain information from a third-party social media service if you create or log into your online account through the service or otherwise provide us with access to information from that service. We will only access third party information in this manner consistent with the application program interface provided by the third party.

How do we use your information?

We may process, use and disclose the information we collect from or about you in the following ways:

  • To process orders you make for our products or services.
  • To work with our service providers such as web hosting companies, internet service providers and other services providers we use to be able to make the website and applications available to you.
  • To communicate with you about our products or services or the products and services of third parties (however, please see below as to your rights to limit some of these communications)
  • With your opt-in, to provide your Contact Information to third parties who may have products or services that we recommend or state are compatible with our products or services. You have the right to limit or terminate this use of your Contact Information.
  • To defend or bring any claim from/against you arising from our interactions;
  • To meet a legal requirement (see below under “Compelled Disclosure”)
  • To provide such information to our successor in a sale of our business or other change of control (see below under “Sale of Business”)

Compelled Disclosure. We will comply with all applicable laws, rules and regulations, which may require that we disclose your information to government authorities, or to parties in court actions under subpoenas or court orders, or otherwise as we are advised we are required to do to comply with a legal obligation.

Sale of Business. We may disclose your information, including but not limited to your Medical Information and Contact Information, to a corporate successor in interest if we sell our business, or engage in a merger, sale of stock, or our company’s ownership otherwise changes control.

Right to limit some communications. Applicable laws, such as the CAN SPAM law, may give you rights to limit some non-relationship communications. We will comply with such laws. Be aware, however, that you cannot limit certain communications with us, such as communications regarding transactions and orders, notices regarding updates to our TOS or this Privacy Policy, or other communications regarding our business relationship with you.

How do we protect your information?

We will use reasonable commercial effort to keep your information secure in our systems, however, you acknowledge that no system is hacker proof and that despite our reasonable efforts, your information could be accessed by unauthorized persons. In this regard, we will use the efforts required by applicable laws, rules, regulations and orders that apply to the specific types of information we have. Notwithstanding the above, you agree that we will not be liable for any unauthorized access to or use of your data or information except solely to the extent we violate applicable laws, rules, regulations or orders.

Third-party privacy policies and services

Occasionally, at our discretion, we may include or offer third-party products or services on our website or applications. These third-party sites have separate and independent privacy policies. We have not reviewed or verified any data or privacy policies of such linked sites and take no responsibility or liability for the content and activities of these linked sites, or their products or services.

Advertising on our website and applications

We may provide a space on our website and applications for third parties to advertise their goods and services. We are not responsible for the content of these advertisements and do not endorse the products or services in them. The advertisers and systems that provide such advertising may also track information about you, directly onto their site. For example, Facebook connect or Google may be aware that you are visiting our website or application, and may, by use of tools they operate, gather additional information about you during your visit to our website/application. We are not responsible for the privacy policies or acts of such third party advertisers, or their data collection, use or security policies.

There are technological tools and plugins you can use to block or prevent some and possibly all such third party advertiser tracking and data collection. Some advertisers and data collection companies permit you to opt out of their third party data collection.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out of some advertising tracking by visiting the Network Advertising Initiative Opt Out page (currently at http://optout.networkadvertising.org/) or by using an applicable browser add on.

Google Analytics

Our website or applications may make use of Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics uses cookies. The information about your use of our website or applications generated by the cookie will generally be transmitted to and held by a Google. Google will use the information on behalf of the website or application’s operator to analyze your use of the website or application, compile reports on the website or application’s activities and provide us with further services linked with the use of the website or application and the internet.

You can find further information on Google’s data use for advertising purposes, as well as settings and objection options, on Google’s websites: https://www.google.com/policies/privacy/partners/ (“How Google uses data when you use our partners’ sites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”) http://www.google.com/settings/ads (“Control the information Google uses to show you ads”) and http://www.google.com/ads/preferences/ (“Decide which ads Google shows you”).

We may use other data analytics companies in combination with or as a replacement of Google Analytics. All such data collected by Google and if applicable such other tools is Automated Data hereunder.

COPPA (Children Online Privacy Protection Act)

Our website and application are for use of adults at least 13 years old. We do not specifically market to children under the age of 13 years old.

Community Forums and Blogs

Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Such information is not Personally Identifiable Information.

Testimonials

We may display personal testimonials of satisfied customers on our website in addition to other endorsements. If you provide us with an email or other communication regarding our services or products, you automatically hereby consent to our use of all or a part of such email or other communication for marketing our goods and services, provided that we use only your first name. We will not use your image or likeness without specific authorization from you. If you notify us in writing to cease such use, we will do so within a reasonable time of receipt of such request.

Rights under Laws

You may have additional rights under applicable state law to access certain information; for example California residents may have rights under California Code Section 1798.83. We will comply with these applicable laws.

Communications Decency Act Notice.

We hereby notify You that parental control protections (such as computer hardware, software, or filtering services) are commercially available that may assist You in limiting access to material that is not suitable to minors. You can discover some of the providers of such parental control technology by searching for "parental control software" using a major search engine, or by visiting http://www.onguardonline.gov/articles/0031-protecting-your-childs-privacy-online

Contacting Us

If there are any questions regarding this privacy policy, you may contact us at: