Consistent with our Terms, Ahara is intended solely for users within the United States, and individuals outside of the United States should not use the Platforms. Also consistent with our Terms, by providing your data to or using the Platforms, you acknowledge and consent to the transfer, processing and maintenance of your data as described in this Policy.
You or your authorized agent can always contact us if you have a question at email@example.com. Additionally, you can send a letter to:
Attention: Privacy Admin
1901 Avenue of the Stars
Century City, CA 90067
1. Your Rights
When we talk about “Personal Information” in this Policy, we mean any information that identifies, relates to, describes, is capable of being associated with you, or could reasonably be linked, directly or indirectly, with you, and as otherwise defined in the U.S. State Data Protection Laws. The U.S. State Data Protection Laws do not consider publicly available information, deidentified, or aggregate consumer information as “Personal Information.”
We will not attempt to reidentify deidentified information (except as necessary to test our deidentification processes to ensure no individuals can be identified) and will use it only in deidentified form.
We make it easy to exercise your rights to know (ie, request a copy of your information including health information), correct, and delete your Personal Information by sending an email request to firstname.lastname@example.org. We might require some additional information to verify your identity in order to process your request.
If you do not have an Ahara account and would like to make a privacy rights request, or to appeal an action we made related to your privacy request, you can email us at email@example.com.
Alternatively, you may exercise your privacy rights through an authorized agent. If you use an authorized agent, we will require you to verify your identity and confirm that you have provided the authorized agent permission to submit the request on your behalf.
We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days. Your rights under the U.S. State Data Protection Laws are not absolute and Ahara may exercise limitations or exemptions as permitted by the U.S. State Data Protection Laws.
Notice of Right to Opt-Out of Sale/Sharing
Ahara believes in providing you with a frictionless experience by responding to Global Privacy Control (“GPC”) signals sent by your browser or mobile device. A GPC is a signal from your browser that notifies us of your privacy preferences, such as whether or not you want us to drop cookies on your device. To check your GPC preferences, check out the settings or extensions in your browser or mobile device.
Notice of Financial Incentive
We may provide special offers and benefits to certain customers. For example, a customer may be invited to get a free test or supplement order via a discount code or special promotion. Such offers and benefits are voluntary and customers can choose not to accept. If a customer accepts, they can choose to close their account at any time via Account Settings or by contacting us at firstname.lastname@example.org. We collect the same Personal Information from a customer with a free order as a customer who purchased their order from us. Both customers’ Personal Information will be handled as detailed in this Policy.
While we do not assign a monetary value to the personal information we collect from a customer with a free order, we do receive value in the form of customer loyalty, Research participation (if they choose to opt-in to Research), and increased engagement. The value of the personal information that we collect is reasonably related to the expenses related to our offering to you. This value will vary by customer depending on their engagement on the Ahara Services, and many other factors.
2. What We Collect
We collect Personal Information for various purposes with privacy principles in mind.
Below, we describe the categories of Personal Information consistent with the terminology used in California Consumer Privacy Act (ie, CCPA), and may include reference to certain key definitions from our Privacy Statement. We have collected the following categories of Personal Information:
- Identifiers: Registration Information and information contained in Web-Behavior Information and/or User Content such as your name, display name, address, online identifier, IP address, email address, phone number, or other similar identifiers.
- Personal information: Certain information from Registration Information (including payment information), certain User Content (such as your name, address, or phone number), and/or certain Self-Reported Information.
- Characteristics of protected classifications under California or federal law: Certain information from Registration Information, Self-Reported Information, and/or User Content, such as your age (40 years or older), race, color, ancestry, national origin, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), and genetic information (including nutrigenetics).
- Commercial information: Certain information from Self-Reported Information and/or User Content such as products or Services purchased, obtained, or considered, survey responses regarding past purchasing history, information about products you purchased or considered, or other purchasing or consuming histories or tendencies.
- Biometric information: Certain information from Self-Reported Information and/or User Content such as physiological, behavioral, and biological characteristics that can be used to establish an individual’s identity. To the extent we collect this information, we collect it directly from you when you choose to share it with us.
- Internet or other electronic network activity information: Web-Behavior Information such as data generated from your use of our Services and collected through log files, cookies, web beacons, and similar technologies. Such information may include your browser type, domains, page views, how long you spent on a page or feature of the website, or other data about your engagement with our Services.
- Geolocation data: Web-Behavior Information that includes the identification or estimation of physical location or movement.
- Inferences drawn from other personal information: Inferences and Derived Data includes any information, data, assumptions, or conclusions laboratory services performed by clinical laboratories (collectively, "Labs") infer based on analyses of facts, evidence, or another source of information or data. Ahara may derive Genetic Information, such as imputed genotype data, genetic risk scores, and phenotypes (which are observable characteristics or traits). Generally this information is created by the Labs and not collected directly from you. The Labs may derive information from data that was collected in relation to our genetic testing services, directly from you, or through tracking technology.
- Sensitive personal information: Genetic Information, and certain Registration Information, Sample Information, and Self-Reported Information may be considered “sensitive.” This includes data that reveals your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; precise geolocation; racial or ethnic origin; mail, email, and/or text messaging contents where Ahara is not an intended recipient; and genetic data.
3. How We Use Your Personal Information
Ahara may use Personal Information listed above for the purposes described below or at your direction. Such purposes include:
- Providing Services: To provide our Services to you, including maintaining or servicing your account, providing customer service, processing or fulfilling orders and transactions, and more.
- Audit: Auditing related to a current interaction and concurrent transactions, or compliance with applicable laws or standards.
- Security and Integrity: Detecting security incidents, maintaining integrity, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Transient Use: Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with our business, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction.
- Advertising and Marketing: To provide advertising and marketing to you, including cross-context behavioral advertising.
- Research and Development: Internal research that Ahara performs to improve and develop its products and services.
- Quality Assurance and Product Improvement: Activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Ahara, and otherwise to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Ahara.
If you have given your explicit consent, for example via a data transfer authorization or other consent document, we may use, disclose, or share your Personal Information for research purposes to third parties. The purpose, such as recruitment for external research or participation in Ahara Research, may vary and will be described in the consent at that time.
We have disclosed Personal Information to service providers and contractors for business purposes, including third-party advertising and marketing companies for cross-context behavioral or targeted advertising of Ahara’s services. Please note, Ahara will never sell your data to advertisers or third parties.
Important to us and you, we do not use or disclose sensitive Personal Information for purposes other than the business purposes permitted by CCPA, which include, for example, to perform our services, to detect and prevent security incidents, to perform services on behalf of the business, and other purposes as allowed by CCPA.
4. Changes to this notice
We may change this policy from time to time and if we do, we’ll post any changes on this page. If you continue to use Ahara after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide more prominent notice or obtain your consent to the changes.