Last modified: August 5th, 2019
Million Marker Wellness (“Million Marker Wellness,” “we,” “us” or “our”) is committed to being responsible stewards of Personal Information and transparent about our information practices.
· We collect your website Usage Data, Registration Information, and Health Information including your urine sample (collectively “Personal Information”) in order to provide our Services.
· We use the information we collect to process your order, provide your results and interpretation, to develop new product features, understand how our Services are being used, and to market to you.
· If you choose to allow us, we will also use your data for scientific research and to store your sample for future use.
We will not sell your data or share it with any public database.
To the extent we notify you of different or additional privacy policies or practices those additional terms shall govern such data collection and use.
1. Information collected as you use the Service. We and our third party service providers automatically collect and store certain information whenever you visit or interact with the Services (“Usage Information”). Usage Information may be non‑identifying or may be associated with you. Whenever we associate Usage Information with Personal Information, we will treat it as Personal Information. This Usage Information may include:
· your Device functionality (including browser, operating system, hardware, mobile or local network information);
· the areas within our Services that you visit and your activities there, including remembering you and your preferences; and
· certain other Device data, including the time of day, IP address, and location, among other information.
We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). For example, we use “cookies” or “tags.” A cookie is programming code that is designed to collect information about your interactions with the Services, such as the links you click. We may use Tracking Technologies for the following purposes:
· Analytical. We may use Tracking Technologies that are useful to assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services.
· Functionality. We may use Tracking Technologies that are required to offer you enhanced functionality when accessing the Services, including identifying you when you visit our Services or keeping track of our specified preferences, including in terms of the presentation of content on our Services.
There may be other Tracking Technologies now and later devised and used by us in connection with the Services. Further, third parties may use Tracking Technologies in connection with our Services, which may include the collection of information about your online activities over time and across Devices and third party web apps or online services.
2. Information collected from you. Through the Services, we may ask you to provide two general categories of Personal Information:
· Registration Information: demographic and personal identifiable information, which is information that identifies you personally, such as your first and last name, age, gender email address, address, and phone number, and
· Health Information: information about your health (e.g., history of disease, environmental exposures, symptoms) and information about the medications you are taking (e.g., current medications, supplements), and your physical urine sample for lab analysis.
We may collect Personal Information in the following ways:
· forms you fill out on our website,
· sample collection kits received in the mail,
· information provided by you in connection with our Services, and
· surveys, polls, blogs and postings, and submittals.
3. Third Party Services. The Services may include functionality that allows certain kinds of interactions between the Services and your account on a third party website, application or other service (such as Facebook or Google). We will never share information with these third parties without your consent. If you choose to use third party services, when you use third party apps or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third party privacy policies before using such third party services with our Services.
We may use Personal Information or Usage Information for various purposes, including:
to provide the Services to you;
to process your sample through a third party lab and provide you with the results in your account;
to store your sample at our third party lab;
to enable you to participate in a variety of the Services’ features;
to improve the Services, or our offerings;
if you consent, for scientific research and publication;
to provide customer support;
to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services’ policies;
to provide you with information or to provide you with special offers or promotional and marketing materials;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
for other internal purposes in connection with our business or the Services; and
Information Disclosed to Third Parties
We do not share, license or sell information we collect or receive from you through the Services in a personally identifiable form with third parties.
Service Providers. We may use third party vendors, contractors, and other service providers to perform certain services on behalf of us or in connection with the Services, such as: (i) to assist us in operation; of the Services (ii) to manage databases of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. For example, a third party, contracted lab will receive and analyze your urine sample and provide us the test report. We may provide these vendors with access to user information, including Health Information, only as necessary to carry out the services they are performing for you or for us.
Partners. We may de-identify your Health Information so that you are not identified as an individual, and provide that information to our partners (for example, to enable our partners to publish research based on such de-identified data). If you consent, we may use some or all of your Registration Information and Health Information in scientific research. Our research is aimed at publication in peer-reviewed journals and may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations or the federal government, academic institutions or for-profit companies. Additional information about the research study or studies will be supplied in the applicable consent document.
In addition, we may disclose Personal Information as follows:
· Affiliates and Business Transfer. We may share Personal Information, including your Device Identifiers and Personal Information and Usage Information with any parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of Million Marker Wellness or the Services; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change in which personal information held by us about our users is among the assets transferred, and you agree to and do hereby consent to our assignment or transfer of rights to your personal information.
· For any other purpose disclosed by us when you provide the information.
Information Controls and Preferences
You have several choices you can make about how Personal Information is used in our Service, including choosing:
· Whether or not to allow Million Marker Wellness store your sample for future use,
· Whether or not to participate in scientific research,
· Which reports to view, and
· Choosing to share your reports with others, both within your Million Marker Wellness account or independently (through email or a third party platform such as Facebook).
You will be presented with those choices through your account or through other communication and can control them as directed in such a communication.
You may review, correct, or update Personal Information through your account settings. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. Please note that we reserve the right to send you certain communications relating to your use of our Services, such as administrative and Services announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.
If you no longer wish to use our Services, you may close your account by sending a request to email@example.com. When closing an account, we remove all personally identifiable information from your account within thirty (30) days of our receipt of your request. However, any Registration Information or Health Information that you have previously provided and for which you have given consent to use in Million Marker Wellness research cannot be removed from ongoing or completed studies that use the information. Our contracted laboratories, service providers, and partners may also retain Personal Information as required by local law and we may retain backup copies for a limited period of time pursuant to our data protection policies. In addition, we retain limited amounts of your Registration Information related to your order history (e.g., name, contact, and transaction data) as long as your account is active or as needed to provide you Services, as well as for accounting, audit and compliance purposes.
The Services are offered and available only to users who are 18 years of age or older. We do not solicit, collect, or maintain information from people we actually know are under 18 years old. If we obtain actual knowledge that a user is under 18 years old, we will use our best efforts to promptly remove that person’s information from our database. If you are not 18 years of age or older, you must not access or use the Services.
We understand that protecting Personal Information is important and endeavor to incorporate reasonable safeguards to help protect and secure Personal Information. All personal information you provide to us is stored on our secure servers behind firewalls. 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 Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone. Be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.
Unfortunately, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.