Last Updated: October 12, 2020
EquiLife, LLC (“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.
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:
Please note: When communicating with us by email or through forms on our Site, we ask that you please do not send us any sensitive information pertaining to yourself, medical conditions, prescriptions, or any other information relating to diagnosis or medical treatment of any health problems. EquiLife does not collect or store sensitive information or special categories of information. Insead, always consult with a licensed medical healthcare professional.
b. Information from Third Parties: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.
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:
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, and fulfilling health coaching requests, among other products and services;
b. To Provide You with Service-Related Communications:contacting you 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, our policies, 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;
e. For Internal Use and Services Improvement:accumulating and reporting aggregate, statistical information in connection with the Site, Apps, and user activity, including determining which features and services users like best to help us operate, enhance, and improve our Services;
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 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.
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, website hosting, online store platforms, 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 and are obligated not to disclose or use it for any other purpose.
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.
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.
Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.
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:
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.
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:
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
Using Facebook Business Tools, we may display interest-based ads to you when using Facebook. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook's Ad Preferences in addition to the Your Choices section above. We do not share any of your 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
In order to provide service to you, we may send you communications related to your transactions, security, or the administration of this website. From time to time, we may also send you other messages or updates about EquiLife, our website, and our other products and offerings. If you do not wish to receive non-transaction or security-related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us as specified in the “Contact Us” section below.
You may also update information about your account with us. We will update and correct your profile if you wish to make changes. Please note that if you opt out of receiving communications from us, we may still send you service communications such as emails about your account.
Please note that "opt-out" and "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 the prior privacy settings.
By downloading and using our mobile applications, you may receive messages, reminders, offers, news, and information from EquiLife within the mobile application itself. These “in app” messages are part of our mobile application’s functionality but can be adjusted using your device or app settings.
You have the right to access, correct, and delete your personal information that you shared with us on our Site or App or through other written or oral means. We are committed so that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. In most cases, you can review and submit changes to your personal information by logging into the Site and visiting your account profile page. You may also notify us via the information in the “Contact Us” section below to request access to, or to correct any personal information that you have provided to us. We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you no longer wish to have your personal information processed, you may request to delete your account (username and password), subject to certain limitations, by contacting us as described below.
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:
Category of Information
Sources of Information
Purpose of Information Collection
How we share it
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 underCalifornia 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.
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.
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.
Sale of Personal Information Under the CCPA –In the preceding twelve months we have not sold your personal information, as that term is generally understood but we recognize that the CCPA defines “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.”
In addition to the “Cookies and Other Tracking Technologies” Your Choices section above’s description for opting out of interest-based advertising and controlling browser settings, California consumers may also use the Digital Advertising Alliance’s tool to send requests under the CCPA for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/, or by downloading the DAA’s AppChoices mobile application opt-out here: https://www.privacyrights.info/appchoices.
Rights Under the CCPA
Access to Specific Information and Data Portability Rights – Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:
Deletion Request Rights – You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
Opting Out –As described in “How We Sell Your Information” above, California residents have the right to opt-out of having their personal information sold.
Non-Discrimination –We recognize and respect that you have the right to not receive discriminatory treatment by the business for exercising any of your CCPA rights.
Exercising Access, Data Portability, and Deletion Rights –To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to us by contacting us as described in the “Contact Us” section below.
Use of an Authorized Agent to Submit a Request – Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.
Direct Marketing -- If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes. To request a notice, please submit your request by postal mail to the contact information listed below.
The Services and their servers are operated in the United States. Please be aware that your information, including your personal information, may be transferred to, processed, maintained, and used on computers, servers, and systems located where the privacy laws may not be as protective as those in your jurisdiction. If you choose to use our Website while located outside the United States, such as in the EEA, the United Kingdom, Switzerland, Canada, Australia, New Zealand, or elsewhere, you hereby irrevocably and unconditionally consent to such transfer, processing, and use of your information in the United States and elsewhere. If you do not wish for your information to be transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately cease accessing our Site or Apps.
Lawful Bases of Processing – Where EquiLife is acting as a data controller that determines the purposes and means of processing your personal data, such as when we collect, use, and share personal data as described in Sections 2 through 4 above, we must have a lawful processing basis for doing so. Our lawful bases for processing personal data include:
You can withdraw your consent at any time by contacting us as described in the “Contact Us” section below.
Your EEA Data Subject Rights – Under certain circumstances, by law you have the right to:
To exercise any of these rights, please contact us as set forth in the “Contact Us” section below and specify which GDPR privacy right(s) you wish to exercise. We must verify your identity in order to honor your request, which we will respond to within 30 days of receipt.
Transfers –When we transfer or receive personal data from the EEA, we do so pursuant to appropriate safeguards or your explicit consent under GDPR Article 49.
Retention – As described in the “Retention and Disposal of Your Information” section above, as a general rule, we keep your data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your data for longer than our specified retention periods to honor your requests, including to continue keeping you opted out of marketing emails, or to comply with legal, regulatory, accounting or other obligations.
Complaints – If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority (link). We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us per the “Contact Us” section below.
We have implemented reasonable measures designed 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.
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.
EquiLife Services are not directed toward children under the age of 16, and we do not knowingly collect any personal information 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.
We welcome your questions, comments, and concerns about privacy. You can contact us anytime via our website located at https://equi.life/, or as follows:
Attention: Privacy Team
1150 Great Plain Ave
PO Box 920172
Needham, MA 02492-9998
United States of America