CA Privacy Notice – Alumia: Personalized Daily Vitamin Packs

Alumia – California Privacy Notice

Effective Date: May 20, 2021

INTRODUCTION

This California Privacy Notice (the “CA Privacy Notice”) supplements the information contained in our Privacy Policy and applies only to individual residents of the State of California (“consumers” or “you”).

This CA Privacy Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this CA Privacy Notice have the same meaning as defined in our Privacy Policy or as otherwise defined in the CCPA.

PERSONAL INFORMATION

When we use the term “Personal Information” in this CA Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of this CA Privacy Notice, Personal Information does not include:
      a)   Publicly available information from government records.
      b)   Deidentified, aggregated or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
      c)   Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
      d)   Information relating to our employees, contractors and other personnel.

Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of Personal Information from the categories of sources and for the purposes set forth below, which reference the Personal Information, sources, and purposes described in the INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT and HOW WE DISCLOSE AND SHARE YOUR INFORMATION sections of our Privacy Policy.

Disclosure of and Recipients of Personal Information

Alumia does not sell Personal Information to third-parties. We generally only disclose and share Personal Information with our third-party service providers to help provide you with the Service. We do not share Genetic Information with any third-parties other than our laboratory partner to process your saliva sample.

For more information, please see the HOW WE DISCLOSE AND SHARE YOUR INFORMATION section in our Privacy Policy.

The table below summarizes the categories of Personal Information we collect as well as how we use and disclose your Personal Information.

Category of Personal Information Collected	Sources	Business Purpose for Collection	Business Purpose for Disclosure
Identifiers and Registration Information (e.g., name, email address, and other similar identifiers)	• Directly from you when you register an Account. • Third parties you direct to share information with us.	• To provide you with an Account. • To deliver, provide, and improve our Services, including processing, analysis, and delivery of your genetic testing results. • To process payment for our Services. • To tailor content we display to you and offer we may present to you, both on the Service and elsewhere online. • To promote to you products, services, offers, and events offered by Alumia. • To address your inquiries. • To monitor habit formation and apply rewards. • To communicate with you about your order. • For customer service purposes. • For quality assurance purposes. • For regulatory compliance purposes.	• With our service providers to perform service-related operations such as fulfillment and shipping, quality assurance, web analytics, and fraud detection.
Personal information categories as per the California Customer Records statute (Cal. Civ. Code §1798.80(e)), (e.g., contact information and payment information)	• Directly from you when you register an Account or fill out a form. • Third parties you direct to share information with us. • Your browser or device.	• To provide you with an Account. • To deliver, provide, and improve our Services, including processing, analysis, and delivery of your genetic testing results. • To process payment for our Services. • To tailor content we display to you and offer we may present to you, both on the Service and elsewhere online. • To promote to you products, services, offers, and events offered by Alumia. • To address your inquiries. • To monitor habit formation and apply rewards.	• With our service providers to perform service-related operations such as fulfillment and shipping, quality assurance, web analytics, and fraud detection.
Protected Classification Characteristics (e.g., age and gender)	• Directly from you when you register an Account or fill out a form.	• To process, and analyze your genetic testing results. • To deliver, provide, and improve our Services. • To tailor content we display to you and offer we may present to you, both on the Service and elsewhere online. • To promote to you products, services, offers, and events offered by Alumia. • To monitor habit formation and apply rewards.	• With our service providers to perform service-related operations such as quality assurance and web analytics. • With our genotyping laboratory to process, analyze, and deliver your genetic testing results.
Commercial Information (e.g., shopping and purchase history)	• Directly from you when you register an Account or fill out a form. • Your browser or device.	• To deliver, provide, and improve our Services. • To process payment for our Services. • To tailor content we display to you and offer we may present to you, both on the Service and elsewhere online. • To communicate and promote to you products, services, offers, and events offered by Alumia. • To address your inquiries. • To monitor habit formation and apply rewards. • To communicate with you about your order. • For customer service purposes. • For quality assurance purposes. • For regulatory compliance purposes.	• With our service providers to perform service-related operations such as fulfillment and shipping, quality assurance, web analytics, and fraud detection.
Biometric Information (e.g., Genetic Information and Self-Reported Lifestyle Information)	• Directly from you or developed or analyzed by Alumia in relation to our genetic testing services.	• To deliver, provide, and improve our Services, including processing, analysis, and delivery of your genetic testing results. • For customer service purposes.	• With our service providers to perform service-related operations such as fulfillment and shipping, quality assurance, web analytics, and fraud detection. • With our genotyping laboratory to process, analyze, and deliver your genetic testing results.
Internet or Electronic Network Activity Information (e.g., device information, logs, browser cookies, analytics data)	• Directly from you when you access our Website. • Your browser or device.	• To deliver, provide, and improve our Services. • To investigate fraud and to enforce our Terms of Service. • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online. • To promote to you products, services, offers, and events offered by Alumia. • To address your inquiries.	• With our service providers to perform service-related operations such as quality assurance, web analytics, and fraud detection.
Geolocation Data	• Your browser or device.	• To deliver, provide, and improve our Services. • To investigate fraud and to enforce our Terms of Service. • To monitor habit formation and apply rewards. • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online. • For customer service purposes.	• With our service providers to perform service-related operations such as quality assurance, web analytics, and fraud detection.
Inferences and Derived Data (e.g., predictions about your interests and habits)	• Directly from you. • Your browser or device. • Information generated or derived from your purchases, online browsing and usage activity.	• To deliver, provide, and improve our Services. • To investigate fraud and to enforce our Terms of Service. • To tailor content we display to you and offers we may present to you, both on the Service and elsewhere online. • To communicate and promote to you products, services, offers, and events offered by Alumia. • To monitor habit formation and apply rewards.	• With our service providers to perform service-related operations such as quality assurance, web analytics, and fraud detection.

YOUR CALIFORNIA CONSUMER RIGHTS

Under the CCPA, California residents are provided the following rights:

The Right to Know

You have the right to request any or all of the following information relating to your Personal Information we have collected and disclosed in the last 12 months, upon verification of your identity:
      a)   The specific pieces of Personal Information we have collected about you;
      b)   The categories of Personal Information we have collected about you;
      c)   The categories of sources of the Personal Information;
      d)   The categories of Personal Information that we have disclosed to third-parties for a business purpose, and the categories of recipients to whom this information was disclosed;
      e)   The categories of Personal Information we have sold about you (if any) and the categories of third-parties to whom the information was sold; and
      d)   The business or commercial purposes for collecting or, if applicable, selling the Personal Information.

The Right to Request Deletion

You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions.

The Right to Opt Out of the Sale of Your Personal Information

You have the right to direct us not to sell Personal Information we have collected about you to third-parties now or in the future.

The Right to be Free from Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

How to Exercise Your Right to Know or Right to Request Deletion

Registered users may delete their genetic information and/or their Account by accessing their Account settings on the Website. For more information on how to exercise your rights under the CCPA, please contact us at hello@alumia.com. Please note that we may require you to verify your credentials, by matching your email address, or other Account information to the information in our systems, before you can submit a request to exercise any of these rights. If you authorize another person to act as your agent to submit requests on your behalf, then unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity.

How to Exercise Your Right to Opt Out of the Sale of Your Personal Information

We do not sell your Personal Information to third-parties, therefore we do not offer an opt-out mechanism.

CHANGES TO THIS NOTICE

Alumia may update this CA Privacy Notice at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will post a notice on our website and update the Effective Date at the top of this Notice upon becoming effective. We may also notify you by email, at our discretion.

HOW TO CONTACT ALUMIA

If you have any questions about this CA Privacy Notice, please contact our team at hello@alumia.com.