Privacy Policy

PRIVACY POLICY

This Privacy Policy describes how Keyspan, Inc. (“Keyspan,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

Information We Collect

We collect information about you in a variety of ways depending on how you interact with us and our website, mobile application, products, and services, including:

Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, place an order/make a purchase or subscribe to our dietary supplement and diet/lifestyle planning services, submit a blood sample for testing, interact with our health coaches, or contact us by phone, email, or otherwise.
Automatically through the use of cookies, server logs, and other similar technologies when you interact with our website, mobile application, advertisements, and emails.
From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, other third-parties (such as Neurotrack, Vital, Mobile Phlebotomy, GetLabs, Apple, wearables, and Suggestic) that facilitate and/or conduct blood, cognition, and other testing related to our services or provide health and fitness data collection and health optimization technologies, or from publicly available sources. For example, if you submit a job application we may conduct a background check.

The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

Context	Types of Information	Primary Purpose for Collection and Use of Information
Account Registration	We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We collect this information to provide account-related functionalities to our users. Accounts can be used for easy checkout and to save your preferences, transaction and subscription history, test results, and customized supplement and nutrition recommendations.
Blood Sample Information	We collect your blood sample, which you submit using our blood sample kits.	We collect this information for testing, for analysis, and to develop tailored diet, exercise, and lifestyle plans for our users.
Health Information	We collect information concerning your health, fitness, cognition, overall wellbeing, and medical history.	We collect this information to better understand your physiological characteristics to develop tailored diet, exercise, and lifestyle plans for you.
Genetic Information	We collect information regarding your genotype (e.g., the As, Ts, Cs, and Gs at particular locations in your DNA).	We collect this information to use in our analysis to develop tailored diet, exercise, and lifestyle plans for you.
Vendor Information	We may collect information about the employees of companies with whom we do business, including name, email address, and mailing address.	We collect this information to contact our vendors and their employees to communicate with them concerning normal business administration, such as test results, test analysis, and billing, and to otherwise provide our services to you.
Cookies and First-Party Tracking	We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed.	We use cookies to ensure that our website operates efficiently, to provide you with more customized offers and information, and to customize our website to match your personal preferences.
Cookies and Third-Party Tracking	We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites.	We collect this information to analyze how our website is being accessed and used, to improve user experience and the overall quality of our website, and to customize advertising and content..
Demographic Information	We collect personal information, such as your age, gender, or location.	We collect this information to understand our users and provide tailored services.
Distance Information	When you use our website or mobile application, we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location..	We collect this information to understand our users and provide tailored services.
Email Interconnectivity	If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.	We have a legitimate interest in understanding how you interact with our communications to you.
Job Applicants	If you apply for a job posting, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.	We collect this information to make employment-related decisions (e.g., hiring for new positions).
Inquiries, Comments, Feedback, and Support	If you provide us feedback or contact us for support or for inquiries regarding your order or subscription, we will collect your name and email address, as well as any other content that you send to us, in order to reply.	We collect this information to respond to or follow up on your comments, reviews, inquiries, and other requests.
Mailing List	When you sign up for one of our mailing lists, we collect your email address or postal address.	We collect this information to share material about our products and services or other special offers that may be of interest to you.
Mobile Devices	We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or using our app.	We collect this information to identify unique visitors and understand how users interact with us on their mobile devices.
Order Placement and Subscriptions	We collect your name, billing address, shipping address, email address, phone number, credit or debit card number, and/or bank account information when you place an order or sign up for a subscription.	We use your information to provide you with our services and fulfill your order when you make a purchase, including arranging for shipping and providing you with invoices and/or order confirmations.
Partner Promotion	We collect information that you provide as part of a co-branded promotion with another company.	We collect this information to fulfill our promotions.
Public Health and Safety	In certain situations where a serious public health threat has been identified, we may collect information from individuals accessing our facilities. This may include medical and health information, such as body temperature, symptoms, and underlying health conditions.	We collect this information to protect the health and safety of our visitors and guests. In some jurisdictions we may be required by law, regulation, or governmental order to collect and retain information related to issues of public health and safety.
Surveys	When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.	We collect this information to understand your opinions and collect information relevant to our organization.
Fitness Tracker Data	When you wear one of our fitness trackers, we collect information such as your heart and lung function, sleep patterns, workout statistics, and weight.	We collect this information to accurately track your health and workouts through the fitness tracker.
Website Interactions	We use technology to monitor how you interact with our website. This may include which links you click on or information that you type into our online forms. This may also include information about your device or browser.	We collect this information to understand how you interact with our website, to improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also collect this information to detect and prevent fraud.
Web Logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for your visit.	We collect this information to monitor our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

How We Use Information

In addition to the purposes and uses described above, we use information in the following ways:

To identify you when you visit our website or use our mobile application.
To provide our products and services or to process returns.
To improve our services and product offerings.
To streamline the checkout process and to facilitate new subscriptions and renewals.
To conduct analytics.
To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
To debug, identify, and repair errors that impair the existing intended functionality of our website and mobile application.
To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
For internal administrative purposes, as well as to manage our relationships.
To generate sample data from your test results to make personalized supplements and health and lifestyle recommendations through our website.
For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in collecting your information, in many situations, we have more than one purpose.

How We Share Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, our business, or our assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
Public. Some of our websites may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
Partner Promotion. We may offer contests, sweepstakes, or other promotions with third-party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third-party partner, the information that you provide will be shared with us and with them. Their use of your information is not governed by this Privacy Policy.
Service Providers. We share your information with service providers. Among other things, service providers help us to administer our website, conduct surveys, provide technical support, process payments, assist in the fulfillment of orders and subscriptions, provide blood test results, create dietary profiles (Suggestic), maintain health coach call notes (Suggestic), generate recipes (Suggestic), provide phlebotomy services (Mobile Phlebotomy, GetLabs), fulfill lab orders, conduct brain cognition tests (Neurotrack), and fulfill supplements (OK Capsule).
Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.

Any third party that we share information with will provide the same or equal protection of the information as stated in this privacy policy.

Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

Access To Your Personal Information. You may request access to your personal information or confirmation that we have and process information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
Changes To Your Personal Information. We rely on you to update and correct your personal information. Our website and mobile application may allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information by modified. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
Deletion of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, to resolve disputes, to enforce our agreements, or for another business purposes.
Opt-out of Sales and/or Targeted Advertising. Although we do not “sell” your personal information for money, we may use some of your personal information for advertising performance analysis, use your information for audience modeling for ongoing advertising, and/or disclose your information to data brokers, which may constitute a “sale” under certain privacy laws. You may opt out of online tracking-based targeted advertising (e.g., cookies) by clicking the “Do Not Sell or Share My Personal Information” link on our homepage. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference. You may also opt out of other forms of targeted advertising by submitting a request via that link.
Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
Online Tracking. We do not currently recognize the “Do Not Track” signal.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us 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.
Revocation Of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note that if you revoke your consent for the processing of personal information, then we may no longer be able to provide you services.

Please note that not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

You may exercise the rights described above through our online portal or by contacting us as indicated in the Contact Information section below. If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal.”

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct, or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of a completed Authorized Agent Designation Form indicating that you are able to act on another person’s behalf.

How We Protect And Retain Information

No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

We retain your personal information for only as long as necessary to fulfill the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

Changes To This Privacy Policy

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

Keyspan, Inc.

[INSERT EMAIL CONTACT]

[INSERT MAIL CONTACT]

[INSERT PHONE CONTACT]

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Additional Information For California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of this Privacy Policy.

California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact Information section above.
California Notice of Financial Incentive. We offer programs that provide certain perks, such as rewards, discounts, and exclusive offers (the “Reward Programs”). When you sign up for a Reward Program, we will ask you to provide your name, email address, and in some cases your telephone number. Under California law, our Reward Programs might be interpreted as “financial incentive” programs as they involve the collection of personal information. We do not assign a monetary value to the information we collect. Based on our reasonable estimate, the value of your personal information to us is related to the value of the free or discounted products or services that you obtain when you redeem points. This value is based on the expense related to offering those free or discounted products or services. You may withdraw from participating in the Reward Programs at any time by contacting us at the address described in the program terms and conditions.

Notice of Collection. The table below describes the categories of personal information we collect, disclose for a business purpose, “sell” and/or “share” (as those terms are defined by California law). Please note that, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information for money. As discussed elsewhere in this Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising. For more information, please see the portions of this Privacy Policy discussing cookies and similar tracking technologies and/or the Cookie Preference Center. For details regarding how we use personal information, please see the Information We Collect section of this Privacy Policy. For information regarding how long we retain personal information, please refer to the How We Protect And Retain Information section of this Privacy Policy.

Category of Personal Information	Category of Recipients
	Disclosures for a Business Purpose	Sell or Share for Cross-Context Behavioral Advertising
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Business partners Data analytics providers Data brokers Internet service providers Joint marketing partners Operating systems and platforms Other service providers Payment processors and financial institutions Professional services organizations, which may include auditors and law firms Social networks	Advertising networks
Government-issued identification – this may include Social Security, driver’s license, state issued identification, or passport number.	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Payment processors and financial institutions Professional services organizations, which may include auditors and law firms
Financial information – this may include bank account number, credit card number, debit card number, and other financial information.	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Payment processors and financial institutions Professional services organizations, which may include auditors and law firms
Health-related information – this may include medical information, or mental or physical condition or treatment.	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Affiliates or subsidiaries Data analytics providers Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Payment processors and financial institutions Professional services organizations, this may include auditors and law firms	Advertising networks
Biometric information – this may include imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns, or rhythms, and sleep, health, or exercise data that contain identifying information.	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	Affiliates or subsidiaries Data analytics providers Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Geolocation data
Audio, electronic, visual, thermal, olfactory, or similar information	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Professional or employment-related information	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Non-public education information (as defined in the Family Educational Rights and Privacy Act)	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Inferences drawn from any of the information listed above	Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Professional services organizations, which may include auditors and law firms
Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include credit card number, debit card number, and other financial information, and physical characteristics or description.	Affiliates or subsidiaries Government entities, as may be needed to comply with law or prevent illegal activity Other service providers Payment processors and financial institutions Professional services organizations, which may include auditors and law firms

California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): 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 an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, or text messages when we are not the intended recipient; genetic data; biometric information for the purpose of uniquely identifying an individual; health information; and information concerning sex life and sexual orientation. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.