General Website Privacy Policy

Effective Date: January 19, 2023

Last modified: March 13, 2024

LifeDNA Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website lifedna.com, our platform at my.lifedna.com, or mobile app (our “Services“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

Please see our Privacy Notice for EU Residents if you are an individual located in the European Economic Area (EEA), United Kingdom (UK) or Switzerland.

If you are a resident of California, please see our Privacy Notice for California Residents.

This policy applies to information we collect:

• On the LifeDNA website, web-app, and mobile app.
• In email, text, and other electronic messages between you and LifeDNA.
• Through mobile and desktop applications you download from LifeDNA, which provide dedicated non-browser-based interaction between you and LifeDNA.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• From you that may be offline or through any other means such as your saliva sample and genetic information.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using these Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of these Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. No one under age 18 may provide any information to the Services without verified parental consent. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on these Services or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at:

California residents under 18 years of age may have additional rights regarding the collection and sale of their personal information. For more information, please see our Privacy Policy for California Residents.

Information We Collect about You and How We Collect It

We collect several types of information from and about users of our Services, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, date of birth, sex, or any other identifier by which you may be contacted online or offline (“personal information“);
• That includes your genotype, diseases or other traits or characteristics, genetic data, and reports we generate from testing the saliva kit.
• That you provide on the test tube that contains your saliva (such as your year of birth and sex).
• Relevant information you provide may include information such as any disease conditions, health-related information, traits, ethnicity, family history, or anything else you provide to us.
• That is about you but individually that does not identify you. Such information is deidentified or anonymous data that does not identify you; and/or
• About your internet connection, the equipment you use to access our Services, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties. For example, we may receive your information from someone who has given you the gift of our product and service.

Information You Provide to Us.

The information we collect on or through our Services may include:

• Information that you provide by filling in forms in our Services. This includes information provided at the time of registering to use our Services, subscribing to our service, posting material, or requesting further services by email or through our customer services.
• Information related to participating in our Research Program.
• When you provide the saliva sample for us to perform services, we may ask you for information relevant to provide your genetic report.
• Survey information [such as your sex, age, ethnicity, weight, and height that a user may provide when responding to a survey. This also includes behavioral and social information such as a user’s occupation, commute, diet, alcohol consumption and tobacco use, fitness and exercise and sleep behavior.]
• We may collect information if you enter a contest or promotion sponsored by us, and when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete so we can improve our Services.
• Details of transactions you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information (i.e., credit card information) before placing an order through our Services.
• Your search queries in the Services.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Services, including [traffic data, location data, logs], and other communication data and the resources that you access and use in the Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically does include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Speed up your searches
• Recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services. You can learn more about how we use cookies in our Cookie Policy.
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Services and its contents to you.
• To perform services (i.e., analyze your genetic information so we can provide you a report regarding your genotype).
• To sign up for our services by creating an account.
• To fulfill any other purpose for which you provide it.
• To provide you with information, products, or services that you request from us.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Services or any products or services we offer or provide though it.
• To allow you to participate in interactive features in our Services.
• For research purposes. See Research Program.
• To give us feedback or contact us.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own products and services that may be of interest to you. If you do not want us to use your information in this way, please reach out to us at [email protected].

Disclosure of Your Information

We do not sell your information, and we will not use your genetic information for marketing or personalized advertising without your explicit consent. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. The primary example of this would be for shipping purposes.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of LifeDNA Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by LifeDNA Inc. about our Services’ users is among the assets transferred.
• If you request we share information with your friends, family members, doctors, or other healthcare professionals, and/or any other individuals or entities who may or may not be using our services, including through third party services such as social networks and third-party apps that connect to our services.
• To our subsidiaries and affiliates.
• For any other purpose disclosed by us when you provide the information.
• With your consent

We may also disclose your personal information:

• To academic institutions or companies that conduct research. If you participate in our Research Program, we will ask you to provide consent by opting-in. For more information regarding participating in research, see Research Program.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms of Services and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of LifeDNA Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Unless we are legally required, we will not disclose your personal information with:

• Public databases.
• Insurance companies or employers.
• Law enforcement or regulatory.

LifeDNA Research Program

We conduct research to create new discoveries about genetics and other variables that contribute to health and wellness. All LifeDNA users are given the opportunity to opt-in to the research program. You are not required to participate in our research program, and you can opt-out at any time.

How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by clicking the relevant opt-out links in the communications you receive from us, or reach out to us at [email protected].
• Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties’ products or services, you can opt out by following the relevant opt-out links in the communication, or by sending us an email stating your request to [email protected].
• Accessing and Correcting Your Information. You can review and change your personal information by logging into the Services and visiting your account profile page. You may also send us an email at [email protected]. to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
• Your California Privacy Rights
  If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, click Privacy Notice for California Residents. California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are 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 send an email to [email protected]. or write us at: 1050 Queen St., 100, Honolulu, Hawaii 96814.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained as part of the Services.

Retention

We will keep your personal information while you have an account with us or while we are providing products and services to you. We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the LifeDNA updates page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

To register a complaint or concern, please contact us at [email protected].

Disclaimer: LifeDNA’s reports have not been evaluated by the Food and Drug Administration. The contents on our website and our reports are for informational purposes only, and are not intended to diagnose any medical condition, replace the advice of a healthcare professional, or provide any medical advice, diagnosis, or treatment. Consult with a healthcare professional before making any major lifestyle changes or if you have any other concerns about your results.