EquiLife Privacy Policy

EquiLife Privacy Policy

Last Updated: September 1, 2024

INTRODUCTION AND OVERVIEW

EquiLife Inc, (“EquiLife” “we”, “us” or “our”) is a premium organic wellness supplements, at-home lab testing, and health coaching organization. Our mission is to offer products, services, and holistic approaches to individuals who want to reach the healthiest version of themselves.

EquiLife respects the privacy of the visitors to our digital properties and the users of our products and services, and we are committed to protecting it through our adherence to this privacy policy (“Privacy Policy”).

This Privacy Policy describes how EquiLife collects, stores, uses, and safeguards your information when you use our website at https://equi.life/ (the “Site”), our mobile/tablet/desktop applications such as EquiLife Coaching Connect, EquiLife Health Portal or Ayubowan by EquiLife (“Apps”), our loyalty rewards or membership programs, and through any other websites, pages, features, or content owned and operated by EquiLife that direct to this Privacy Policy (“Content,” and, collectively, including the Site and Apps, the “Services”).

By using our Services, you acknowledge that we will collect and process your personal information in accordance with this Privacy Policy, and you consent to the practices and terms set forth in our Terms of Use, available at https://equi.life/policies/terms-of-service. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Use, please discontinue use of the Services or engaging with EquiLife immediately.

Please also be aware that, as described more fully in our Full Disclaimer, you are responsible for your own health decisions, and any statements or claims about the possible health benefits conferred by any foods or supplements have not been evaluated by the Food & Drug Administration and are not intended to diagnose, treat, cure or prevent any disease. For the avoidance of doubt, EquiLife is not subject to the requirements of the Health Information Portability and Accountability Act of 1996 or its implementing statutes and regulations (collectively, “HIPAA”). This is because EquiLife does not engage in HIPAA covered transactions set forth at 42 C.F.R. Part 162. However, as described below, we do protect, safeguard and carefully limit access to your information in accordance with this Privacy Policy.

CONTENTS

UPDATES TO THIS PRIVACY POLICY
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
HOW WE USE YOUR INFORMATION
LEGAL BASIS FOR PROCESSING FOR RESIDENTS OF THE EEA, U.K. AND SWITZERLAND
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
COOKIES AND OTHER TRACKING TECHNOLOGIES
RETENTION
YOUR PRIVACY RIGHTS AND CHOICES
NOTICE TO CALIFORNIA RESIDENTS
INTERNATIONAL TRANSFERS
DATA SECURITY
INTEGRATION OF THIRD-PARTY PLATFORMS, SERVICES AND AI CHATBOTS
CHILDREN’S PRIVACY
CONSUMER HEALTH DATA
MOBILE MESSAGING PROGRAM TERMS & CONDITIONS
CONTACT US

1. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in the law or as we update or expand our Services, in which case we will provide you with notice of such updates by revising the “Last Updated” date at the top of this Policy. When we make a material change, such as if we take an action that would restrict privacy choices that you currently have, we will notify you as required by applicable law. All changes will be effective as of the “Last Updated” date. We encourage you to look for updates and changes to this Privacy Policy by checking this page when you access our Services. If you have any questions about this Privacy Policy, please reach out to us anytime at privacy@equi.life or as described in the contact information included within the “Contact Us” section below.

2. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

EquiLife collects personal information when you interact with our Services. The definition of personal information (used interchangeably in this Privacy Policy with the term “personal data”) depends on the applicable law based on your place of residence or physical location, but for purposes of this Privacy Policy, personal information generally is any information that identifies or makes a unique individual identifiable. Only the definition that applies to your residence or physical location will apply to you under this Privacy Policy.

Separately, please note that some U.S. states have laws that directly define and apply to “Consumer Health Data,” such as Washington State’s My Health My Data Act. If you are a resident of such a state, please see the “Consumer Health Data” section below and our supplemental Consumer Health Data Privacy Policy available at https://equi.life/pages/equilife-consumer-health-data-privacy-policy.

The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site and Apps, and information from third parties.

a. Information You Voluntarily Provide to Us: The personal information we collect on or through our Services may include:

Account Registration:information relating to the creation of an account on one of our websites or mobile applications, such as first and last name, email address, date of birth, postal address, telephone number, and/or a unique individual password;
Form Submissions:information that you provide by filling in forms that we make available. This includes, for example, contact or payment information when making purchases from our Site, health assessment questionnaires on EquiLife, or information you provide on a health questionnaire when registering your lab, or your message to us when requesting information or assistance;
Newsletter Sign-ups:information relating to our newsletter subscription page, including name and email address;
Customer Service:records and copies of your correspondence (including email addresses), if you contact us by telephone or in writing or via chat (including when interacting with third-party, artificial intelligence-powered chatbots or customer support tools across inbound messaging channels), including for customer or technical support;
Program Participation:information related to your participation in our programs, including our loyalty rewards programs, our Ayubowan Membership program (details of the program are available here: https://equi.life/pages/membership), our Mobile Messaging Program https://equi.life/pages/equilife-mobile-messaging-program-terms-and-conditions, or other programs;
Promotions and Feedback:information relating to your voluntary participation in a promotion, or survey that we may ask you to complete for research purposes;
Payment Information: payment card, transaction or financial account information, if you make a purchase online or sign up via our order forms;
Ambassador Program Information:information related to your participation in our Ambassador Program (details available here: https://equi.life/pages/ambassador), including your name, address, website, social media account information, and financial account information (to facilitate referral payments);
Job Applications: employment- and background-related information provided to us as a part of the job application process;
Labs Processing and Coaching Wellness Plans: if you request nutritional testing that requires processing via one of our CLIA-certified lab partners, or if you meet with a Wellness Coach, then you are requested to provide supplemental information via a web form on https://labs.equi.life/ or via an EquiLife App. In this case, we may collect, store and transmit to our lab partners or Wellness Coaches health-related information that you voluntarily provide, such as current and past health conditions and symptoms, surgical treatments, diagnoses, nutritional supplements taken, and other information you provide as part of a health questionnaire. Our Ayubowan wellness App or Coaching Portal also can directly record weight, desired weight, height, activity level, exercise plans, allergies and intolerances in order to provide you an ongoing meal plan and supplementation plan to help achieve your goals, with the option of having our Wellness Coaches design complete wellness plans that include meal plans, protocols, supplements, exercise, meditation, and related functions; or
Device Permissions and Third-Party Services: information relating to your use of features of our Services that may ask you to grant us access to location information, photos, microphone, video camera, or media on your computer or mobile device. You also may optionally choose to connect and transfer over information from third-party services, for example, Google Fit or Apple Health, to one of our Apps. Such sharing from an unaffiliated service is entirely voluntary, but if you provide us permission to do so, we will transfer over the information stored in the third-party service to your EquiLife App or account.

b. Information from Third Parties(e.g., social media or wellness providers/practitioners):

Social Media. When you interact with our Services or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service.

The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform and we will only collect and store such personal information that we are permitted to collect by those social media platforms. When you access our Services through social media channels or when you connect our Services to social media services, or in situations where you choose to sync information stored with an unaffiliated third-party service with your EquiLife App, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.

Wellness Providers/Practitioners. We may also receive your information if your third-party wellness provider invites you to our Equilife Coaching Platform, which you may choose to accept or decline. We record the invitations that a provider sends and whether their client (you) responds to those invitations, and if you accept, we record the provider-client relationship on your individual record. We also allow providers to request access to your EquiLife purchase history, questionnaires and lab results, but this information is only shared with your third-party wellness provider/practitioner if you affirmatively grant your permission for us to do so. You may choose to accept or decline provider access requests, and you may rescind access you previously provided to a provider via our Coaching Portal or by contacting us as described below. You may also invite providers/practitioners who do not use our Coaching Portal to do so, subject to the same privileges and restrictions described immediately above.

c. Information Collected Automatically:As you navigate through and interact with our Site or Apps, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Information About Your Use of the Services:when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request.
Device Information: if you access the Services through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general (i.e., country- or city-level) location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.
Performance Data: information about your preferences to make your use of the Services more productive, via the use of Cookies or similar tracking technologies.

For more information about how we collect your information automatically, please see the “Cookies and Other Tracking Technologies” Section below.

3. HOW WE USE YOUR INFORMATION

EquiLife will only use your personal information as described in this Privacy Policy or as disclosed to you prior to such processing taking place. We process your personal information for the following purposes:

a. To Provide You Our Services:providing any services or products that you request or purchase in connection with the Services, such as purchasing supplements, requesting at-home labs, processing lab results or storing them within our Services for you to access, product subscription management, and fulfilling health coaching requests or designing tailored diet and wellness plans, among other products and services.

Please note as well that we may use your phone number to send strictly account-related text messages to you when necessary for your requested order to be progressed, such as to remind you to register your purchased at-home lab kit or to schedule a call with a EquiLife Wellness Coach to discuss your lab results;

b. To Provide You with Service-Related Communications:contacting you via email, phone or SMS text message regarding the administration of any features or functions of the Site or Apps you have registered to use, and notifying you about changes to our Services, your account-related information, our policies, your program memberships, terms, or any products or services we offer or provide though our Services;

c. To Provide Customer Support or to Respond to You:providing you with notices about your account and responding to your questions or other requests;

d. To Send You Marketing and Promotional Emails:contacting you with newsletters, marketing or promotional materials and other information that may be of interest to you based on the Services that you already use or the offerings that you have already purchased or inquired about, unless you have opted not to receive such information. For more information about our promotional text messaging program, see the Mobile Messaging Program Terms & Conditions here;

e. For Internal Use and Services Improvement:accumulating and reporting aggregate, statistical information (which does not include any individual information that can relate back to an identifiable person) in connection with the Site, Apps, user activity, health questionnaires and labs data, including determining which features and services users like best to help us operate, enhance, and improve our Services, for quality assurance, and to identify typical ranges for different population groups;

f. To Enforce Compliance with Our Agreements or Policies:keeping you secure and safe while using our Services, which requires us to process your personal information in accordance with this Privacy Policy to combat spam, malware, malicious activities, fraud, or security risks as part of our ongoing maintenance and enforcement of our security measures, and carrying out our obligations and enforcing our rights arising from any contracts entered into between you and us, including for billing and collection;

g. To Maintain Legal and Regulatory Compliance:processing personal information to pay our taxes, fulfill our business obligations, for compliance with employment and recruitment laws, or as necessary to manage risk under applicable law;

h. For Customization:saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); tracking your return visits to and use of the services; tailoring your experience on the Services; and/or otherwise customizing what you see when you visit and use the Services;

i. For Research Purposes:for research purposes and to provide anonymous or aggregated reporting for internal and external clients and business partners;

j. With Your Consent:for any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction;

k. For Employment Purposes:processing job applications, including to communicate with you and to conduct applicant and employment-related statistical evaluation and record-keeping.

l. To Administer the Ambassador Program or Wellness Coaching Programs: including communicating with you about the program and processing referral payments;,

M. To Share Information with Ambassadors/Practitioners or Wellness Coaches. Whether in relation to a lab selection pre-purchase call, a lab results review, or as part of a general wellness coaching call, you have the ability to approve EquiLife sharing with a practitioner or Wellness Coachthe following information: your lab results, related information (e.g., wellness plans or notes), and your products purchased by you as a customer.

N. To Conduct Processing related to Voluntarily Provided Health Information:

In addition, as noted above, you also may optionally choose to connect and transfer over information from third-party services—for example, Google Fit or Apple Health— to one of our Apps. Such sharing from an unaffiliated service is entirely voluntary, but if you provide us permission to do so, we will transfer over the information stored in the third-party service to your EquiLife App or account. If you opt-in to sharing such information with EquiLife, we will use such information (whether or not it is displayed in your EquiLife App) for some or all of the following purposes:

To deploy additional coaching services designed to respond to wellness situations that labs could not previously identify.
To identify wellness issues that can be addressed by current offerings. For example, if you are interested in maintaining a more balanced blood pressure, we may recommend certain supplementation that is intended to assist the body in healthy management of circulatory function.
For internal research purposes, to identify in the aggregate wellness gaps EquiLife does not currently address where there may be a need to develop future products.
To assess the effectiveness of our wellness solutions and their designed impact for an individual customer or a group of customers, and to be able to recommend modifications to a wellness program when appropriate to do so.
To conduct double-blind studies administered by third-parties to determine or demonstrate the effectiveness of the wellness solutions.

We may also aggregate or deidentify any personal information that we collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated or de-identified information for our own legitimate business purposes without restriction.

4. LAWFUL BASIS FOR PROCESSING FOR RESIDENTS OF THE EEA, U.K. AND SWITZERLAND

For individuals who are located in the European Economic Area, the United Kingdom or Switzerland (collectively “EEA Residents'”) at the time their personal data is collected, our legal bases for processing your information under the EU or U.K. General Data Protection Regulation (“GDPR”) or local applicable law will depend on the specific context in the which the personal data is collected and the purposes for which it is used. When we process your personal data, depending on the context, we may rely on one of the following recognized lawful bases: (i) to perform a contract with you (or to take steps at your request prior to entering into a contract with you); (ii) necessity for our legitimate interests; (iii) to comply with our legal obligations and/or (iv) your consent. Below is a list of how we use your personal data, as described above in Section 3, with the corresponding legal bases for processing.

Purpose of Processing	Legal Bases for Processing
a. To Provide You Our Services b. To Provide You with Service-Related Communications c. To Provide Your Customer Support or to Respond to You k. For Employment Purposes l. To Administer the Ambassador Program or Wellness Coaching Program	Contract. Based on our contract with you or to take steps at your request prior to entering into a contract.
e. For Internal Use and Services Improvement f. To Enforce Compliance with Our Agreements or Policies h. For Customization i. For Research Purposes n. To Conduct Processing related to Voluntarily Provided Health Information	Legitimate Interests. Based on our legitimate interests. When we process your personal information for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.
g. To Maintain Legal and Regulatory Compliance	Legal Obligations. Based on our legal obligations, the public interest, or in your vital interests.
d. To Send You Marketing and Promotional Emails j. With Your Consent m. To Conduct Processing related to Voluntarily Provided Health Information	Consent. Based on your consent.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contact Us” Section below.

5. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

We may share or disclose your personal information in the following circumstances:

a. Within Our Corporate Organization. We may share your personal information with any subsidiaries and affiliates in order to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis.

b. Service Providers. We may employ other companies and individuals to facilitate our Services, provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Site or Apps are used. These service providers provide us support services such as credit card processing, payment gateways, subscription processing, artificial intelligence-powered chatbots and customer support tools, website hosting, laboratories analyzing and providing us the results of your in-home lab tests to share with you, online store platforms, mobile application development and management (including hosting/storage of your data, lab results, etc.), research firms and labs to conduct double-blind research studies, customer relationship management, order fulfillment and shipping, email and postal delivery, analytics, surveys, digital rewards, marketing services, videoconferencing, and calculating duties and taxes. The service providers have access to your personal information only to perform these tasks on our behalf.

c. Corporate Transactions. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information unless you contact us as described below with your request to opt-out of such transfer/assignment.

d. As Required by Law and to Protect Lawful Interests. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of EquiLife or our customers.

e. With Your Consent. We may disclose your personal information for any purpose with your consent.

f. EquiLife Wellness Coaches. We also work with Certified IHP2 Health Coaches, which are highly experienced Integrative Health Practitioner (https://www.integrativehealthpractitioner.org/, an organization also founded by EquiLife’s founder, Dr. Stephen Cabral)-certified holistic health coaches who are trained in understanding lab results and various protocols to help rebalance the body. Like our other EquiLife Health Coaches, more information for which is available at https://equi.life/pages/health-coaching, our Certified IHP2 Health Coaches will receive your lab test kit results, schedule a call at your convenience to review the results together, and create a tailored wellness plan for you in our Coaching Portal, which may include recommendations for you in relation to relevant supplements or other products we offer. When referring generally to both EquiLife Health Coaches and Certified IHP2 Health Coaches, we use the term “Wellness Coaches.”

Unlike our other Health Coaches, who are EquiLife employees, Certified IHP2 Health Coaches are independent contractors of Equilife. Unless you opt-out by contacting us as described below, then, as with our other Health Coaches, Certified IHP2 Health Coaches will have access in our Coaching Portal for a limited time to your lab results, health questionnaire and other customer data you provide, and they are strictly required to follow all EquiLife policies and federal and state law for protecting health-related data and keeping it confidential.

If you would prefer to work with only an EquiLife Health Coach, and opt-out of potentially being assigned a Certified IHP2 Health Coach (which is generally determined based on which lab test(s) you have chosen), or if you would like to opt-out of any wellness coaching, please let us know by emailing us at scheduling@equi.life. If you do work with a Certified IHP2 Health Coach and wish to continue the wellness coaching experience, you will also have the opportunity to continue to work with that coach beyond your introductory coaching call in a private coaching capacity, if you and the Certified IHP2 Heath Coach mutually agree to do so (i.e., outside of your relationship with EquiLife following the introductory call).

6. COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use cookies, embedded scripts, software development kits (“SDKs”) and other similar technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services.

a. Cookies

Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes:

To improve and make our Services function properly;
to make login to our Services easier (such as by remembering your user ID);
to recognize you when you return to our Services and to remember information you have already provided;
to track your interaction with the Services;
to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests;
and to provide a secure browsing experience during your use of our Services.

We may place cookies from third-party partners who may use information about your visits to other websites to target advertisements for products and services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies. The following types of cookies are used on our Site:

Strictly Necessary Cookies.These cookies are essential because they enable you to use our Site as you reasonable expect. For example, strictly necessary cookies allow you to access secure areas on our Site and provided necessary security functions. Without these cookies, some Site features cannot be provided. This category of cookies is essential for our Site to work and so they cannot be disabled.
Functional or Preference Cookies.We use functional cookies to remember your choices so that we may tailor our Site to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Site. While these cookies can be disabled, this may result in less functionality during your use of our Site.
Performance or Analytic Cookies.These cookies collect passive information about how you use our Site, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Site. You can disable these cookies.
Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They may perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting ads that are based on your inferred interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant ads on other sites. You may disable the use of these cookies as noted below.

b. Your Choices

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.

First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Site may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.
Third-Party Cookies. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.

Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/.

To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here:

c. Analytics

We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

d. Behavioral Remarketing

We also use remarketing services to advertise on third-party websites to you after you visited our Site or services. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service. We use Google Ads for these purposes.Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: http://www.google.com/settings/ads. We also use Criteo to assist in remarketing. Criteo’s opt-out page is available at: https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/.

Using Meta Business Tools, we may display interest-based ads to you when you are using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences page in addition to the methods listed in the Your Choices section above. We do not share any of your directly identifiable personal information with Facebook. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and Facebook matches the hashed data against its own users, generating a lookalike audience and deleting the uploaded list. We do not have access to the identity of anybody in the “lookalike” audience, unless they choose to click on one of our advertisements.

e. Other Tracking Technologies

To see how our Site is performing we sometimes use conversion beacons, tags, scripts and pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We also use these tracking technologies to analyze usage patterns of our Services. The use of these technologies allows us to record that a particular device, browser, or application has visited a particular webpage.

f. Do Not Track

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

g. Location-Based Services

If you enable location-based services on your computer or mobile device in connection with your use of the Services, you expressly consent to EquiLife collecting the geolocation (which may include specific longitude and latitude) of your device.

h. Mobile App Advertising

When you use our Apps, we or our third party marketing partners may use one or more of several different identifiers for your mobile device, including Apple Identifier For Advertising (IDFA) or Android Advertising ID (AAID), to target and deliver ads to you in our app or other apps. This means that, depending on your settings and permissions, your device identifier may be accessed by third-party ad networks and used to (a) help manage the number and types of ads you see; (b) track the source of installs related to ads seen in other apps; and (c) identify your interests and behavior and target advertising to you based on those interests and behavior.

Apple requires app developers to ask for permission before they can track your activity across apps or websites they do not own in order to target advertising to you, measure your actions due to advertising, or to share your information with data brokers. If you previously gave our mobile app permission to track, you can tell our app to stop tracking your activity. On iOS or iPadOS, go to Settings, tap on our app, then tap to turn off Allow Tracking. You can also reset your IDFA from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous IDFA.

If you have an Android device, and are running Android 12 or above, you can delete your AAID permanently by opening Settings, navigating to Privacy > Ads, tapping “Delete advertising ID,” then tapping it again on the next page to confirm. This will prevent any app on your phone from accessing it in the future. Please note that if you do so, you will still see advertisements, but they will not be tailored to your inferred interests.

You may also access industry-provided opt-out tools, although they are not tailored to our mobile applications. For instance, to opt-out of data collection by the Digital Advertising Alliance’s participating member companies for interest-based advertising across mobile applications, download the DAA’s App Choices mobile application opt-out offering at https://youradchoices.com/appchoices.

7. RETENTION

EquiLife will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data or the information you provided to us to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We will retain your marketing contact information until you unsubscribe from our marketing communications. We will also retain Site and Apps usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.

8. YOUR PRIVACY RIGHTS AND CHOICES

Depending on applicable law where you reside or are located, you may be able to assert certain rights identified below with respect to your personal information. If any of the rights listed below are not provided to you under the law that governs the processing of your personal information, we have absolute discretion in providing you with those rights. Please refer to the table below to determine the rights you have in your jurisdiction.

Your rights in relation to your personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious, or for other reasons.

Privacy rights include the following:

Right to Know/Access. You may have the right to obtain a copy, or a list of categories of the personal information that we hold about you, as well as other supplementary information, such as the purposes of processing, and the entities to whom we disclose your personal information.
Right to Correct. You may have the right to correct any of your personal information in our records and systems. You may request us to rectify, correct or update any of your personal information held by us that is inaccurate. In addition to the methods described below, you can correct your personal information through your account settings.
Right to Delete. Under certain circumstance, you may have the right to request that we delete the Personal Information that we hold about you. This right is not absolute, and we may refuse such a request if there are compelling legitimate grounds for keeping your personal information, for legitimate purposes, or as required by law. In addition, in the event your deletion request is honored, we may retain a record of your deletion request as required under applicable laws and their exceptions.
Right to Portability. You may have the right to receive a copy of the personal information we have collected about you in a structured, commonly used and machine-readable format.
Right to Opt-Out Sale / Right to Opt-Out of Sharing for Targeted Advertising. You may have the right to opt-out of: (i) the sale of your personal information; and (ii) the sharing of your personal information for targeted advertising. While we do not sell your personal information for money, like many websites, we use cookies, pixels, and similar technology, and we make available certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. Under some state privacy laws’ broad definition of “sell”, this could be considered a sale, and it could be considered “sharing” of your personal information for targeted, cross-context behavioral advertising purposes.You have the right to direct us not to sell your personal information to third parties, and to direct us not to share or use your personal information for targeted advertising purposes. To exercise your right to opt-out, please submit a request by visiting the Privacy Center or by emailing us as described in the “Contact Us” section below. Equilife processes opt-out preference signals in a frictionless manner in alignment with applicable law. To start using an opt-out preference signal for your web browser, please refer to the Global Privacy Control instructions provided here. You will need to submit a separate opt-out of selling/sharing request on each device and browser you use to visit our Site. Please note that you may still receive generalized ads after opting out of targeted advertising. For information about how to opt-out of sharing or selling on our Apps, please see refer to the “Mobile App Advertising” subsection within the Cookies and Other Tracking Technologies Section of this Policy.
Right to Limit Use and Disclosure of Sensitive Personal Information.If you are a California resident, to the extent your sensitive personal information, as that term is defined under California privacy law, is used to infer characteristics about you, you have the right to object to our processing of your sensitive personal information. We process your sensitive personal information to perform our Services, specifically our health coaching and lab testing services and to conduct processing related to voluntarily provided health information as described in Section 2 above, that you have requested us to provide you through your use of the Services. We do not disclose your sensitive personal information except as necessary to provide these features. For the voluntarily provided health-related information, you can revoke access to your activity information through your device settings, though our ability to provide you our Services may be restricted. If you no longer wish to have us process any of this information, please cease using the Services. Note, we may also process sensitive personal information as part of your job application.
Right to Opt-Out of Automated Decision-making or Profiling.You may have the right not to be subject to a decision which significantly impact your rights that is based solely on automated processing (where a decision is taken about you using an electronic system without human involvement). No decision will be made by us about you solely on the basis of automated decision making which has a significant impact on you.
Right Against Discrimination.You may have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your rights.
Right to Appeal.In certain jurisdictions, you may have the right to appeal if we refuse to take action on your rights request. Instructions on how to appeal will be provided to you upon such a denial, but in any event, such instructions will be substantially similar to those provided below for submitting requests.
Shine the Light. If you are a California resident, you have the right to ask us for a notice describing what categories of personal information we share with third parties or corporate affiliates for those third parties’ or corporate affiliates’ direct marketing purposes. That notice will identify the categories of personal information shared with third parties and used for direct marketing purposes and the name and address of the third parties that received such personal information.
Right to Object. You may have the right to object to processing of your personal information for direct marketing purposes or if we are processing your personal information on the basis of our legitimate interest under applicable law.
Right to Restrict. In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Right to Withdraw Consent. In certain jurisdictions, to the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
Marketing Communications.You may choose to provide us with your email address to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. If you sign up to our Mobile Messaging Program to receive text messages from us that contain promotional information, you can opt-out of receiving future messages by replying “STOP.”

Please note that “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process, and apply, during which time your information shall remain subject to this Privacy Policy. Additionally, you should be aware that any information provided to third-parties prior to your election to unsubscribe will not be retrieved or rescinded, unless required by applicable law.

15. Right to Lodge a Complaint.You may have the right to lodge a complaint with your local data protection authority about our processing of your personal information. Contact details for data protection authorities in the European Economic Area are available here, and contact details for the United Kingdom’s ICO are available here.

As mentioned above, depending on where you reside or are located, you may be able to assert certain rights with respect to your personal information. To determine which rights you have, please refer to the table below that references the rights as described above in the “Privacy Rights and Choices” section. Any places that are not listed either do not have a law providing such rights, or their law does not apply to our operations.

Please understand that this is not an absolute right, and we retain full discretion to maintain certain of our information even after honoring a deletion or rights request. For instance, we may need to retain certain information for the purposes of complying with our ongoing legal obligations (including our obligation to maintain a record of your deletion request or past purchases), helping ensure security and integrity of our systems and the information under our control and/or protect the rights and interests of EquiLife and/or other individuals.

Residence	Applicable Rights
European Economic Area, United Kingdom, or Switzerland	(a) Right to Know/Access; (b) Right to Correct; (c) Right to Delete; (d) Right to Portability; (e) Right to Opt-Out of Sale / Right to Opt-Out of Sharing for Targeted Advertising; (g) Right to Opt-Out of Automated Decision-making or Profiling; (h) Right Against Discrimination; (k) Right to Object; (l) Right to Restrict; (m) Right to Withdraw Consent; and (o) Right to Lodge a Complaint.
California	(a) Right to Know/Access; (b) Right to Correct; (c) Right to Delete; (d) Right to Portability; (e) Right to Opt-Out of Sale / Right to Opt-Out of Sharing for Targeted Advertising; (f) Right to Limit Use and Disclosure of Sensitive Personal Information; (g) Right to Opt-Out of Automated Decision-making or Profiling (upon issuance of regulations by the California Privacy Protection Agency); (h) Right Against Discrimination; and (j) Shine the Light.
Colorado, Connecticut, Virginia, Oregon, Texas	(a) Right to Know/Access; (b) Right to Correct; (c) Right to Delete; (d) Right to Portability; (e) Right to Opt-Out of Sale / Right to Opt-out of Sharing for Targeted Advertising; (g) Right to Opt-Out of Automated Decision-making or Profiling; (h) Right Against Discrimination; (i) Right to Appeal; and (m) Right to Withdraw Consent.
Any Location, including those listed above	(n) Marketing Communications; and (b) Right to Correct.

Submitting a Request to Exercise Your Rights. In addition to the methods specified above, you may exercise these rights by: (i) emailing us at privacy@equi.life with the subject line “Privacy Rights Request”; (ii) submitted a request through our Privacy Center, or (iii) sending your request via mail to the address provided in the “Contact Us” section below.

Before fulfilling your request, we may be required by law to have you to verify the personal information we already have on file to confirm your identity. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

You may use an authorized agent to submit a rights request on your behalf. If you use an authorized agent to submit requests on your behalf, we will require you to directly verify your identity with us, or have you directly confirm with us that the authorized agent has been authorized to act on your behalf.

9. NOTICE TO CALIFORNIA RESIDENTS

This section applies solely to individuals who reside in the State of California. The purpose of this section is to inform California residents (“consumers” or “you”), at or before the time of collection of personal information, about our data collection practices and your privacy-related rights under California law, including the California Consumer Privacy Act of 2018, as amended (“CCPA”). Your “right to know” about personal information collected, used, and disclosed by EquiLife includes what categories of personal information we collect from you and the purpose for its collection; how we use those categories of personal information; and how we share the personal information you entrust to us.

In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:

Identifiers
Personal information categories listed in the CCPA
Commercial information
Internet or similar network activity
Inferences drawn
Sensitive Personal Information, specifically information related to a consumer’s health to provide our Services and to process voluntarily provided health information

Category of Information	Sources of Information	Purpose of Information Collection	How we share it
Identifiers	We collect identifiers from the information you voluntarily provide to us and from the information we automatically collect, as outlined in Section 2 above.	We collect identifiers to provide our services; to communicate with you, including via marketing; for research and development and services improvement; to comply with applicable laws; to enforce our terms, and as otherwise outlined in Section 3 above.	We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 4 above.
Personal information under California Civil Code section 1798.80	We collect Section 1798.80 information from the information you voluntarily provide to us and from the information we automatically collect, as outlined in Section 2 above.	We collect Section 1798.80 information for the purposes outlined in Section 3(a)-(k) above.	We share Section 1798.80 information with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 4 above.
Commercial information	We collect commercial information from the information you voluntarily provide to us, as outlined in Section 2 above.	We collect commercial information to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, as outlined in Section 3 above.	We share commercial information with our service providers; internally; and to protect lawful interests, as outlined in Section 4 above.
Electronic network activity information	We collect network information through the information you voluntarily provide to us and from the information we automatically collect, as outlined in Section 2 above.	We collect network information to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, and as otherwise outlined in Section 3 above.	We share network information with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 4 above.
Inferences	We develop inference data through the information you voluntarily provide to us and from the information we automatically collect, as outlined in Section 2 above.	We develop inference data to provide our services; to communicate with you, and for research, development, and services improvement, as outlined in Section 3 above.	We share inference data with our service providers and to protect lawful interests, as outlined in Section 4 above.
Sensitive Personal Information	We collect sensitive personal information, specifically information related your health, through the information you voluntarily provide us as outlined in Section 2 above.	We process information related to your health to provide our Services and to process voluntarily provided health information as outlined in Section 3 above.	We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 4 above.

10. INTERNATIONAL TRANSFER

When you access or use our Services, your personal information may be processed in the United States or any other country in which EquiLife, its affiliates, or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.

We transfer your personal information subject to appropriate safeguards as permitted under the data protection laws, including: (i) through the use of standard contractual clauses approved by an appropriate regulatory authority, such as the European Commission or the U.K. Information Commissioner’s Office; (ii) an Article 49 derogation in specific situations; or (iii) any other compliant transfer mechanism. We may also rely on an adequacy decision of the appropriate regulatory authority confirming an adequate level of data protection in the jurisdiction of the party receiving the information.

11. DATA SECURITY

We have implemented measures intended to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third party payment processors, who will use appropriate security procedures.

The safety and security of your information also depends on you. Where you have chosen a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone, and you should not re-use passwords that you use on other websites or services.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services. If you believe that any of your personal information held by EquiLife has possibly been compromised, please contact us immediately as described in the “Contact Us” section below.

12. INTEGRATION OF THIRD-PARTY PLATFORMS, SERVICES AND AI CHATBOTS

The Services may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including third-party services. The Site or Apps may also feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Services or for the privacy practices of third party advertising companies. Once you leave our Services via a link, access a third-party service or click on an advertisement, you should check the applicable privacy policies to determine, among other things, how related companies process personal information they may collect about you. This Privacy Policy applies solely to information collected by EquiLife.

Our Services may also incorporate functionality provided by third-party, artificial intelligence (“AI”)-powered chatbots and similar tools to offer customer experience support across different inbound messaging channels (i.e., phone, email and chat). This AI-support service is intended to improve the useability of our Services and enhance the timeliness of responding to your inquiries and/or providing you information that you request (after having verified that you are the requester). This ChatGPT-based AI technology is not created by EquiLife but assists our business by analyzing and interpreting inbound customer service inquiries and requests, and providing responses based on our previous answers to frequently asked questions and through access to our knowledge base. With your permission, we may also access your customer account records to locate information upon your request. For more information, see Gorgias Inc.’s Privacy Policy at https://www.gorgias.com/legal/privacy.

13. CHILDREN’S PRIVACY

EquiLife does not knowingly collect any personal information online from children under the age of 16. If a child under 16 provided our Site or Apps with personal information, we ask that a parent or guardian contact us as described below so that we may promptly delete the child’s information from our record.

Please note that a parent or guardian may purchase an at-home lab test and/or provide health background information for a child three (3) years or older. The parent or guardian must purchase and register the lab test and must provide the child’s information. Individuals 16 years of age and up may purchase their own lab kits and provide their own health information.

14. CONSUMER HEALTH DATA

If you are a resident of a U.S. state, such as Washington or Nevada, that has an applicable Consumer Health Data law, please see our supplemental Consumer Health Data Privacy Policy. The definition of “Consumer Health Data” is dependent on the applicable definition in your jurisdiction but generally refers to personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present or future physical or mental status.

15. MOBILE MESSAGING TERMS AND CONDITIONS

EquiLife offers a mobile messaging program through Stodge Inc. d/b/a Postscript, such that you have the ability to sign up for promotional text messaging alerts from us if you choose to do so, in order to receive offers, discounts and sneak peeks of new offerings. Please see our Mobile Messaging Program Terms and Conditions here for more information: https://equi.life/pages/equilife-mobile-messaging-program-terms-and-conditions

Please note that regardless of whether you sign up for the mobile messaging program for promotional messages, we may send strictly account-related text messages to you when necessary for your requested order to be progressed, such as to remind you to register your purchased at-home lab kit or to schedule a call with a EquiLife Wellness Coach to discuss your lab results.

16. CONTACT US

We welcome your questions, comments, and concerns about privacy. You can contact us anytime via our website located at https://equi.life/, submit a privacy request via our Privacy Center at https://privacy.equi.life/, or as follows:

EquiLife, Inc

Attention: Privacy Team

55 West Street

Suite 201

Walpole, MA 02081

United States of America

(888) 348-8890

Email: privacy@equi.life