Last Updated: February 10, 2023
1. What have we collected?
Below, we describe the categories of Personal Information as defined under the CCPA for California residents. The examples of Personal Information provided for each category are taken from the CCPA and are included to help you understand what the categories mean. The examples are not meant to indicate what we actually collect, use or disclose. Some Personal Information included in the categories may overlap with other categories.
In the last twelve (12) months, we have collected the following categories of Personal Information from general sources including you, your use of our Sites and our Products or Services, your devices, our vendors, our service providers or contractors, and our partners:
- Identifiers: such as your name, display name, address, online identifier, IP address, email address, username, or other similar identifiers.
- Personal information categories listed in the California Customer Records provisions: such as your name, address, phone number, payment information, physical characteristics or description, or details about your employment or education.
- Characteristics of protected classifications under California or federal law: such as your age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, and genetic information (including familial genetic information).
- Commercial information: such as products or services purchased, obtained, or considered, survey responses regarding past purchasing history, information about products you purchased or considered, or other purchasing or consuming histories or tendencies.
- Biometric information: Certain information from Testing Information and/or Research Information such as physiological, behavioral, and biological characteristics that can be used to establish an individual’s identity.
- Internet or other electronic network activity information: Web-Behavior Information such as data generated from your use of our Site or Products and collected through log files, cookies, web beacons, and similar technologies. Such information may include your browser type, domains, page views, how long you spent on a page or feature of the website, or other data about your engagement with us or our Site.
- Geolocation data: such as Web-Behavior Information that includes the identification or estimation of physical location or movement.
- Audio, electronic, visual, thermal, olfactory, or similar information: Certain information from Self-Reported Information and/or User Content you provide to us through surveys or other engagement on our platform, such as when you upload a profile picture, or photos or videos taken at our events.
- Professional or employment-related information: Personal Recruitment Information, certain information from Research Information, Self-Reported Information and/or User Content such as education, household income, occupation, and other professional information. This information can be collected when you apply for a job with us, fill out a survey, or otherwise engage with us.
- Inferences drawn from any of the above: includes any information, data, assumptions, or conclusions Elysium Health infers based on analyses of facts, evidence, or another source of Information (such as Web-Behavior Information). Elysium Health may derive Genetic Information, Test Results and other Test Information, such as epigenetic data, biological age, rate of aging, etc. Generally this information is created or derived by Elysium Health and not collected directly from you.
- Sensitive personal information: certain Test Information, Research Information and Self-Reported Information may be considered “sensitive.” This includes data that reveals your: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; mail, email, and/or text messaging contents where Elysium Health is not an intended recipient; and genetic data.
2. How we use and share your Personal Information?
- Providing Products and Services: To provide our Products and services to you, including maintaining or servicing your account, providing customer service, verifying customer information, processing or fulfilling orders and transactions, processing payments, and more.
- Audit: Auditing related to a current interaction and concurrent transactions, or compliance with applicable laws or standards.
- Security and Integrity: Detecting security incidents, maintaining integrity, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Transient Use: Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with our business, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction.
- Research and Development: Elysium Health that we perform to improve and develop our products and services and for other purposes.
- Quality Assurance and Product Improvement: Activities to verify or maintain the quality or safety of a product or service that is owned, manufactured, manufactured for, or controlled by Elysium Health, and otherwise to improve, upgrade, or enhance the product or service that is owned, manufactured, manufactured for, or controlled by Elysium Health.
In the past 12 months, we have disclosed Personal Information for the business or commercial purposes described above, such as to:
- Third parties integrated into our services, our service providers, vendors and contractors.
- Third-party companies for cross-context behavioral, targeted advertising or other marketing and commercial purposes.
- Our research collaborators or partners for research purposes.
- Other third parties for whom we have obtained your permission to disclose your Personal Information or as permitted under the law.
3. What are your rights?
Under the CCPA, you may have the right to:
- Know what categories of Personal Information we collect, use, disclose, share, or sell.
- Receive a copy of your Personal Information.
- Modify and delete your Personal Information.
- Opt-out of: targeted advertising or the sale/sharing of your Personal Information with third parties.
- Limit the use and sharing of your sensitive Personal Information.
- Not receive discriminatory treatment if you exercise your privacy rights.
Please note that these rights are not absolute and are subject to conditions or limitations. For example, CCPA may provide certain exemptions to the rights summarized herein (such as with regard to the deletion of your personal information).
Right to Know and Access
You may submit a verifiable request for information regarding the: (i) categories of your Personal Information we collected, disclosed or shared; (ii) business or commercial purposes for which your Personal Information are collected, disclosed or shared by us; (iii) categories of sources from which we collect Personal Information; (iv) categories of third parties or persons to whom we share your Personal Information; and (v) specific pieces of Personal Information we have collected about you.
Right to Opt-Out of Sharing
Right to Limit Use of Sensitive Personal Information
You can request to limit the use of your Sensitive Personal Information only for the business purposes permitted by law, which include, for example, to perform our services and allow our service providers or contractors to perform services for us, to ensure security and integrity, to provide non-personalized advertising, detect and prevent security incidents, to improve, upgrade, or enhance our services, and other purposes as allowed under the law.
4. How can you exercise your rights?
If you have any questions, comments, or concerns about, or you would like to exercise your privacy rights under this Notice, please email to firstname.lastname@example.org with “California Privacy Rights” on the subject line or call (888) 220-6436.
Depending on the sensitivity of your request, you may be required to provide additional information to verify your identity and request before further action is taken. If your request is for access to your personal data, we will confirm your email and one or more additional pieces of information provided in your request to verify against information already in our possession, such as name and state or country of residence. In some cases, we may be unable to fulfill your request because we have no way to verify your identity to the standard the law requires. For example (but without limitation), if you have visited our Site, but never left a comment, completed a purchase or a financial transaction with us, or interacted with us via email or other means, we probably do not have enough information to confirm your identity to even a reasonable degree of certainty.
We will disclose and deliver the above information to you free of charge within 45 days of receiving a verifiable request from you. If reasonably necessary, we will extend the above time period by an additional 45 days, but before we do so, we will provide you a notice for the extension.
Your authorized agent may make a request on your behalf. We will consider any evidence the agent submits to demonstrate that you gave the agent signed permission to submit the request. We may email you to confirm that the agent is indeed acting on your behalf.
5. Notice of Financial Incentive
While we do not assign a monetary value to the Personal Information we collect from a customer with a free Product, we may receive value in the form of customer loyalty, research participation (if they choose to opt-in to Elysium Research), and increased engagement. The value of the Personal Information that we collect is reasonably related to the expenses related to our offering to such customer. This value will vary by customer depending on their engagement on the Sites or our services, and many other factors.