Privacy Policy

Last updated: 10/28/2020

Your privacy comes first.  Control over your data, transparency, security, and privacy are the pillars of any product or technology we build. 

We respect your personal information when we help you to collect, and manage your health data, participate in digital health trials and A.I. training projects, for personal health insights. 

1.  Introduction

This Privacy Policy describes the types of personal information we collect from the users of the mobile application (the “App”) and related website, (the “Site”) and the services offered via the App and Site (together with the App and Site, the “Services”).  We also describe how we use the information we collect, with whom we may share it, the choices available to you regarding our use and disclosure of your information, the measures we take to protect the security of your information, and how you can contact us about our privacy practices.

By using our Services, you agree that your information will be handled as described in this Privacy Policy, and you agree that your use of the Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service (which are incorporated by reference into this Privacy Policy), including its applicable limitations on damages and the resolution of disputes. 

2. Information We Collect About You and From You

The Information We Collect About You.

We collect information about you directly from you, from third parties, and automatically through your use of our Services.

Information We Collect Directly From You. The information we collect from you depends on how you use our Services. To create an account (which is required to use our Services via our App), you must provide your first and last name, email address and select a password for your account.  Account creation also requires you to agree to the Terms of Service and this Privacy Policy.

We also may collect additional information from you that you choose to provide to us, including age, gender, sex, photographs, physical activity, health information (including medical conditions, medical vitals such as blood pressure and heart rate, lab results, and prescription drug history), and genetic information.  

In addition, if you choose to participate in one of the digital health trials, research studies, or A.I. trainings (the “Trial” or “Trials”) offered via our Services, you may be asked to provide additional information relevant to the topic of the Trial. 

Finally, we collect any information you provide to us via your communications with us, including in connection with any support features offered via our Services.  

Information We Collect From Other Entities. 

At your direction, we may collect information about you from other sources, such as when you direct us to import data from other entities (for example, when you direct us to import into the Services your lab results from your medical provider or prescription information from your pharmacy).  

In addition, if you choose to participate in one of the Trials offered via our Services, our research institute partners (who run such Trials) will analyze the information provided (please see below for further information regarding how we disclose your data) and provide back via the Services the results or insights derived from the data provided as part of the Trial.  This information is made available to you via your account.

Information We Collect Automatically.

We automatically collect information about your use of our Services through cookies, web beacons, and other technologies. This may include location information; your browser type and operating system; webpages you view on the Site; links you click on the Site; your IP address; the length of time you visit our Site and or use our Services; the referring URL, or the webpage that led you to our Site; your mobile device ID, name, model, operating system type, name, and version; language information; primary account information; activities within the App; and the length of time that you are logged into Services via the App.  

To the extent permitted by applicable law, we combine this information with other information we collect about you, including your personal information. Please see the section "Cookies and Other Tracking Mechanisms" below for more information.

3. How We Use Your Information

We use your information to provide our Services to you and to improve our Services.  This includes: 

  • to allow you to use the Services, including to participate in Trials offered by our research institution partners.  
  • to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services.
  • to communicate with you about your use of the Services.
  • to improve our Services, including to better train our artificial intelligence tools.  For example, if you upload a photo of yourself via the Services, as part of our Services we will estimate your age and ask you to confirm this information.  Each time we do this, we are training our age recognition tool.  
  • to better understand how users access and use our Services, both on an aggregated and individualized basis. For example, we will evaluate which features of our Services are more (or least) used by users.

We also use your information for marketing purposes.  This includes:

  • to send you email marketing about our Services.
  • to assist us in advertising on third party websites, mobile apps, and other online services, and to evaluate the success of our advertising campaigns through third party channels (including our online targeted advertising and offline promotional campaigns).

And we use your information for legal and business-related purposes.  This includes:

  • to comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  • where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Privacy Policy.

4. How We Share Your Information

We may share your information, including personal information, as follows:

  • Research Institution Partners.  Via our Services, users may elect to participate in one or more Trials offered by our research institution partners.  If you elect to participate in such a Trial, we will provide certain of your information to our research institution partner that is conducting the Trial.  Each Trial requests users to provide different types of information, so the information we provide varies.  You will always be informed of what information will be provided before you agree to participate in any such Trial. If you choose to leave the Trial prior to its completion, we will not collect any further information from you relevant to the Trial but the information already collected from you will continue to be available to our research institution partner that is conducting the Trial. 
  • Service Providers. We may disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf who are required to destroy all data after performing the task(s) they were asked to perform. 

We also disclose information in the following circumstances:

  • Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third party advisors, including attorneys and consultants.
  • In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Privacy Policy, or as evidence in litigation in which we are involved.
  • Aggregate and Not Individually Identifiable Information. We share aggregate information about users with third parties for marketing, advertising, research or similar purposes.

Where we qualify as a service provider or “business associate” to a covered entity under the Health Insurance Portability and Accountability Act, we may use or disclose your protected health information (“PHI”) only as permitted by our business associate agreement with the covered entity, including to provide services to the covered entity, to aggregate patient data, for our proper business and management services, or as otherwise required by law. Covered entities that collect your PHI will provide you with a separate privacy policy called a Notice of Privacy Practices that describes how that entity uses and discloses PHI collected from you.  That privacy policy is a separate document from this Privacy Policy and this Privacy Policy is not intended to cover the disclosures required by that separate privacy policy.  

5. Our Use of Cookies and Other Tracking Mechanisms 

We and our third party service providers use cookies and other tracking mechanisms to track information about your use of our Services. We may combine this information with other personal information we collect from you (and our third party service providers may do so on our behalf). 

Cookies.  Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities via our Service. There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Services. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Services.
  • Persistent Cookies. Persistent cookies remain on your device after you have closed your browser or turned off your device. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse certain areas of the Site, but some features may not function.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Services to, among other things, track the activities of users of our Services, help us manage content, and compile statistics about usage of our Services. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third Party Ad Network section.

Third-Party Ad Networks.We use third parties such as network advertisers to serve advertisements on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at or the NAI’s website at

Third-Party Links.

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

6. Security of My Personal Information 

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

7. What Choices Do I Have Regarding Use of My Personal Information?

Disclosures.  It is always your choice to participate in Trials offered via our Services.  If you do not want your information shared with our research institutions in connection with Trials offered via our Services, you can simply not participate.  

Access.  You may modify personal information that you have submitted by logging into your account and updating your profile information. 

Deletion.  You can delete individual data elements that you have provided via the Services by logging into your account and deleting that information.  You may request that we delete your account and all related information by contacting us at

Marketing and Account Communications.  We may send periodic promotional emails to you. You may opt-out of promotional emails by following the unsubscribe instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you unsubscribe from receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.

8. Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

9. Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at

10. Changes to this Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site and App. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site and App and by contacting you at the email address you have provided to us.