Introduction
This Privacy Policy describes how Superform Life, LLC and certain of its corporate affiliates (collectively, “Superform,” “we,” “us” or “our”) process personal information that we collect or otherwise generate through our digital or online properties or services that link to this Privacy Policy (including, as applicable, our website, mobile applications, and social media pages) as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”). Superform may provide individuals with supplemental or separate privacy policies for specific products or services that we offer, including at the time we collect personal information (also known as “just-in-time” disclosures).
Superform may process personal information that identifies your past, present, or future health or mental health status, or that otherwise constitutes “consumer health data” or an equivalent term under applicable U.S. state laws (“Consumer Health Data”). If those laws apply, the Consumer Health Data section below supplements this Privacy Policy.
This Privacy Policy does not apply to personal information that we receive from and process on behalf of our enterprise customers while providing Superform services to them. For example, to the extent that we receive your personal information from your employer related to your eligibility for our Service, our use of that personal information may be governed by our agreements (including, as applicable, a business associate agreement) with the relevant enterprise customer. If you have questions regarding your personal information that we process on behalf of an enterprise customer, please direct your questions to the relevant enterprise customer.
The personal information we collect may differ depending on your relationship with us. For example, if you are a representative of a prospective enterprise customer, we will collect limited personal information in comparison to if you were a Superform member who obtains tests through Superform. Please consider your relationship with us in the context of reading this Privacy Policy.
Notice to U.S. state residents: please see the U.S. State Privacy Rights Notice at Collection section of this Privacy Policy for additional information if you are a U.S. resident.
Guiding privacy principles
We built Superform for families, ourselves and you. Your privacy is one of our top priorities. We empower you to take control of your health, and that includes having control of certain aspects of your personal information. While Superform and its corporate affiliates may operate as a “business associate” as the Health Insurance Portability and Accountability Act (“HIPAA”) defines that term, HIPAA does not apply to all personal information that we process. Regardless, we leverage measures designed to protect and process your personal information in accordance with our guiding privacy principles below and as otherwise stated in this Privacy Policy. Please read the Privacy Policy in full to understand our personal information practices.
- Your identity is not for sale for money. In the ordinary course of our daily operations, we do not disclose your personal information to third parties in exchange for money. For more information on how we may disclose your personal information, please see How we share your personal information.
- We limit the information we collect and retain. We collect personal information to provide you with our products and Services. We retain your personal information for the period of time necessary to fulfill the purposes for which we collected it, including delivering requested products and Services, protecting the interests of our members, and for the period of time required by law.
- We limit the manners in which we share your test results with third parties. In order to deliver our product and Services to you, it may be necessary for us to provide certain information to our lab and other provider partners. We limit how such recipients may use your personal information.
Personal information we collect
Depending on how you interact with the Service, the personal information you may provide to us through the Service or that we generate about you or otherwise may include:
- Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
- Demographic data, such as your city, state, country of residence, postal code, age, date of birth, gender or gender identity, racial or ethnic identity, assigned sex at birth, and sexual orientation.
- Account data, such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, photograph or picture, links to your profiles on social networks, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.
- Service-eligibility data — if you are accessing the Service as part of an enterprise customer-provided offering or benefit, you may provide us with relevant information such as your employer or other enterprise customer name, eligibility data, and relevant enterprise customer identification number.
- Health-related data, such as mental or physical history, conditions and diagnoses, treatments, medications, medical images, biomarkers, lab samples, lab results, clinical notes, and other physical or mental health information. This may include personal information that you provide directly to us when you complete electronic forms designed for you to self-report your physical or mental health status, upload medical records, or link a wearable or Internet of Things device to our Services.
- Genetic data — certain of the lab tests available through the Service may produce data that relates to inherited characteristics.
- Audiovisual recording data, such as video and audio recordings of you.
- Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. This includes purchase considerations, consumption history, and purchase tendencies.
- Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
- Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
- Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party vendor to directly collect and process your payment card information, as described further below.
- Government-issued identification number data, such as a state or local identification number (e.g., driver’s license or state ID number) and an image of the relevant identification card.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- User-generated content data, such as photos, images, music, videos, comments, reviews, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
- Derived data, such as inferences about you that we derive or otherwise infer from your personal information.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Private sources, such as data providers and social media platforms.
- Linked third-party services, such as Google or other third-party services that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
- Linked third-party devices, such as wearable or Internet of Things devices that you link to your Service account. This data may include your username, profile picture, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service, and may include your device’s health app information and historical data related to your use of the wearable device.
- Lab and provider partners, including third-party healthcare services providers, laboratory services providers, and other providers of medical and medical-adjacent services.
- Our enterprise customers, such as employers, gyms, and other entities that may provide us with some of your personal information, such as your Contact data and Service-eligibility data.
- Our corporate affiliates, including certain members of the Superform Life group of companies.
- Marketing partners, such as joint marketing partners.
- Service providers that provide services on our behalf or help us operate the Service or our business.
- Third parties that you designate, such as lab providers with whom we do not have a contractual relationship.
- Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee, or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
- Precise geolocation data when you authorize our mobile application to access your device’s location.
- Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data, such as your interactions with our email, text, or other communications (e.g., whether you open and/or forward emails) — we may do this through use of pixel tags (also known as clear GIFs), which may be embedded invisibly in our emails, enabling us to detect if you have opened or forwarded a message.
Some of the automatic collection described above is facilitated by the following technologies:
- Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place, and “third party” cookies that our third-party business partners and service providers place.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
- Chat technologies that enable you to communicate with us through the Service. Our chat technology providers may access and use information about pages visited on our website, your IP address, your general location (for example, city and state), and personal information you choose to share in a chat to provide and support those features.
How we use information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
We may use your personal information to:
- provide, operate, and improve the Service and our business;
- process your requests, orders, and transactions;
- personalize the Service, including understanding your needs and interests, remembering the devices from which you have previously logged in, and remembering your selections and preferences as you navigate the Service;
- establish and maintain your user profile on the Service;
- enable security features of the Service, such as by sending you security codes via email, and remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions, and feedback.
We may use your personal information for:
- insights, including research and publication of de-identified or aggregated findings, or identifiable information with your consent;
- analyzing your usage of the Service, helping us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails; and
- development purposes, including to analyze and improve the Service and our business and to develop new products and services.
We, our service providers, and our third-party advertising partners may collect and use certain of your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications (including in relation to our products and those of others) and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Your Choices section below.
- Interest-based advertising. Our third-party advertising partners may use cookies, pixels, and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications, and other third-party online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. We do not use health-related information or genetic data for interest-based advertising.
- Testimonials. With your consent, we may use your feedback to post comments about your experience with the Service on our website or in marketing and promotional materials.
- We may use your personal information to administer promotions and contests and to communicate with you about any such promotions or contests in which you participate.
- We may use your personal information to administer events and communicate with you about events in which you participate.
We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations, or requests from government authorities;
- protect our, your, or others’ rights, privacy, health, safety, or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events — we may share certain personal information in the context of actual or prospective corporate events with our advisors, the prospective or actual counterparties to the corporate event, and their advisors.
With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.
To create aggregated, de-identified, and/or anonymized data. We may create aggregated, de-identified, and/or anonymized data from your personal information and other individuals’ personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. Except as required or permitted by applicable law, we will not attempt to re-identify any data that has been aggregated, de-identified, and/or anonymized. We may use this aggregated, de-identified, and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, promote our business, and for research purposes.
In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:
- Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password-protected areas of the Service.
- Functionality. To enhance the performance and functionality of our services.
- Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent its use in relation to your use of our sites at tools.google.com/dlpage/gaoptout.
Your choices
In this section, we describe the rights and choices available to all users. Users located in certain U.S. states can find additional information about their rights below.
- Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.
- Opt out of communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. If you opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. If you receive text messages from us, you may opt out of receiving further text messages by replying STOP to our message. For marketing you have consented to receive based on your health-related data and/or genetic data, you can control how we market to you by contacting us at concierge@superform.health.
- Cookies. Most browsers let you remove or reject cookies via your browser settings. Many browsers accept cookies by default until you change your settings. If you disable cookies, the Service may not work properly. For more information, including how to see what cookies have been set on your browser and how to manage and delete them, visit allaboutcookies.org. You can also configure your device to prevent images from loading, which prevents web beacons from functioning.
- Advertising choices. You may be able to limit use of your information for interest-based advertising through the following:
- Browser settings — changing your web browser settings to block third-party cookies.
- Privacy browsers/plug-ins — using privacy browsers and/or ad-blocking plug-ins that let you block tracking technologies.
- Platform settings — Google and Facebook offer opt-out features for interest-based advertising: Google · Facebook.
- Ad industry tools — opting out through industry programs: Network Advertising Initiative · Digital Advertising Alliance.
- Mobile settings — using your device settings to limit use of your advertising ID for interest-based advertising.
- Blocking images/clear GIFs. Most browsers and devices allow you to configure your device to prevent images from loading — follow the instructions in your particular browser or device settings.
- Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services you visit. We currently do not respond to “Do Not Track” signals. Learn more at allaboutdnt.com.
- Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
- Declining to provide information. We need to collect personal information to provide certain services. If you do not provide information we identify as required or mandatory, we may not be able to provide those services.
- Privacy rights. Depending on applicable law, you may have certain rights with respect to your personal information (for example, if you reside in a state that provides rights in relation to genetic data), which may include rights to request access, delete, and/or destroy genetic data and biological samples from which genetic data may be derived. To exercise potentially available privacy rights, contact us at concierge@superform.health. Not all rights are absolute, and we may deny requests to exercise such rights in accordance with applicable law.
- Linked third-party platforms. If you log into the Service with a third-party service such as Google, or link a wearable or Internet of Things device to your Service account, you may be able to use your settings on that platform to limit the information we receive from it. If you revoke our access to information from a third-party platform, that choice will not apply to information we have already received from it.
Other sites and services
This Privacy Policy does not apply to third-party websites, applications, products, services, or other properties, even if they link to our Service or we refer you to them as part of our Service. Our content may also be integrated into web pages or other online services that are not associated with us. These links, relationships, and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and services you use.
Security
We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including to satisfy legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period, we may consider factors such as the length of our ongoing relationship with you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process it and whether we can achieve those purposes through other means; applicable legal obligations (for example, certain laws require us to keep transaction records for a period of time before we can delete them); our legal position, such as applicable statutes of limitations, litigation, or regulatory investigations; and other applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and for a period thereafter during which we may have a legitimate need to reference it to address issues that may arise.
When we no longer require personal information we have collected about you, we may delete it, anonymize it, de-identify it, or isolate it from further processing.
Children and teens
The Service is available to individuals age 16 and older. Individuals age 16 or 17 may participate only with the consent of a parent or legal guardian and subject to applicable service-specific eligibility requirements. The Service is not intended for anyone under age 16. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf without required authorization, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this policy
The “Last Updated” legend at the top of this Privacy Policy indicates when it was last updated. We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will notify you by updating the date of this Privacy Policy and posting it on the Service or through other appropriate means. Modifications are effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business.
Contact us
If you have questions about our personal information practices or would like to exercise any privacy-related right that may be available to you, please contact us via the method below.
Superform Life, LLC — Attention: Privacy
420 Pennsfield Place, Unit 101, Thousand Oaks, CA 91360
Email: concierge@superform.health
U.S. state privacy rights
Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively, the “State Privacy Laws”). This State Privacy Rights Notice at Collection is part of our full Privacy Policy.
This section describes how we collect, retain, use, disclose, sell, and share (for targeted advertising purposes) personal information of residents of applicable U.S. states, and the rights these users may have with respect to their personal information. Not all rights listed below may be afforded to all individuals — if your state does not afford you a right, you may not be able to exercise it. We may also be unable to process your access, correction, or deletion request if you do not provide sufficient detail for us to confirm your identity and understand and respond to your request.
For purposes of this section, “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device. We do not attempt to reidentify deidentified information derived from personal information, except to test whether our deidentification processes comply with applicable law.
You may request to exercise the rights listed below. We will respond in accordance with applicable law and may decline to honor a request where an exception applies.
- Right to know.
- You can request to know whether we process your personal information.
- You can request the following information about how we have collected and used your personal information during the past 12 months and how we will continue to do so:
- The categories of personal information we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting, selling, and/or sharing personal information for targeted advertising purposes.
- The categories of personal information sold or shared for targeted advertising purposes, and the categories of third parties to whom it was sold or shared, by type of personal information and type of third party.
- The categories of personal information disclosed for business purposes and the types of entities to whom it was disclosed.
- The specific third parties to which we have disclosed personal information.
- Access. You can request a portable copy or representative summary of the personal information we have collected about you.
- Correction. You can ask us to correct inaccurate personal information we have collected about you.
- Deletion. You can ask us to delete the personal information we have collected from or about you.
- Revoke consent. You may have the right to revoke your consent to our processing of your personal information.
- Opt out.
- Opt out of targeted advertising. We process certain personal information for targeted advertising purposes, and you can opt out of that use. We do not use health-related data for targeted advertising.
- Other than for targeted advertising purposes, we do not sell personal information (including Sensitive Personal Information), as defined under applicable law, and have not done so in the 12 months preceding the date this Privacy Policy was last updated. We do not sell or “share”/knowingly sell or “share” personal information (including Sensitive Personal Information) of minors under 18.
- Automated decision making. We do not use your personal information to engage in automated processing or profiling to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements in order to make a decision that produces legal or similarly significant effects.
- Sensitive Personal Information. Where applicable law provides a right to limit our use or disclosure of Sensitive Personal Information, you may submit that request by emailing concierge@superform.health. We use Sensitive Personal Information only for the purposes described in this Privacy Policy or as otherwise permitted by law.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.
- Appeal. You can appeal our denial of any request validly submitted.
Exercising your right to know, access, correction, deletion, appeal, or limit processing of Sensitive Personal Information. You may submit a request by emailing concierge@superform.health. We cannot process your request if you do not provide us with sufficient detail to understand and respond to it.
Exercising your right to opt out of or revoke consent to the “sale” of personal information or “sharing” for targeted advertising. You may submit a request by emailing concierge@superform.health or by broadcasting the Global Privacy Control signal (learn more at globalprivacycontrol.org). These signals set your preferences for the browser or device you are using and any consumer profile we associate with it. If you are logged in, we will also apply the signal to your account and the offline consumer profile associated with it.
Verification of identity; authorized agents. We may need to verify your identity to process your know, access, correction, deletion, or appeal requests, and reserve the right to confirm your residency. We may request your name, email address, phone number, address, or other information to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices and require you to reauthenticate before disclosing or deleting your personal information. If you request deletion, we may ask you to confirm before we proceed.
Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. We may need to verify your agent’s identity and authority to act on your behalf, which may require a copy of a valid power of attorney under applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that the request is authorized — such as providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, providing the information we request to verify your identity, or confirming that you have given the authorized agent permission to submit the request.
Retention. We generally retain personal information to fulfill the purposes for which we collected it, including to satisfy legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes, considering the same factors described in the Retention section above. When we no longer require personal information we have collected about you, we may delete it, de-identify it, anonymize it, or isolate it from further processing.
Consumers under 18. We may collect personal information from eligible members age 16 or 17 with parental or legal guardian consent, as described in this Privacy Policy. We do not sell or share the personal information of minors under 18 for targeted advertising. The Service is not intended for individuals under age 16.
Additional information for Nevada residents. Nevada residents have the right to opt out of the sale, as defined under Nevada law, of certain personal information for monetary consideration. While we do not currently engage in such sales, Nevada residents who would like to make a request to opt out of any potential future sales may email concierge@superform.health.
Consumer health data
To the extent applicable state consumer-health privacy laws apply, this section supplements the rest of this Privacy Policy. We may collect the health-related data, genetic data, demographic data, precise location data, transaction data, and derived data described above from you, connected devices and services, laboratory and provider partners, enterprise customers, and the other sources described above. We use Consumer Health Data to provide and personalize the Service, coordinate requested testing and provider services, communicate with you, maintain security and legal compliance, and conduct research or product development as permitted by law. We may share it with service providers and processors, laboratory and provider partners, parties you direct, professional advisers, authorities, and transaction counterparties as described above.
We do not sell Consumer Health Data, and we do not use geofences to identify or track consumers seeking health care services. Where required, we obtain consent before collecting or sharing Consumer Health Data, and a separate authorization before any sale. You may request access, correction, deletion, withdrawal of consent, or an appeal by emailing concierge@superform.health. Withdrawal does not affect prior lawful processing and may limit our ability to provide the Service.