Full Privacy Statement

PH360 Respects Your Privacy

PH360 recognizes the importance of privacy and respects your desire to store and access your information in a private and secure manner.

This Privacy Statement for PH360 including our mobile application is intended to notify you of how we handle your Personal Information. We are committed to providing you a secure, user-controlled environment for the use of our Services. At the same time, you share responsibility for maintaining privacy and security – for example, by keeping your password secure.

We encourage you to familiarize yourself with this Privacy Statement. Our Terms of Service explain that, by using our Services, including signing up for our service, you are consenting to our use of your personal information according to the provisions set forth in those documents and this Privacy Statement.

Definitions

“PH360″ means PH360, Inc., whose principal place of business is at Gloucester Rd, Wanchai, Hong Kong and all affiliates and entities under common ownership PH360.

“R&D” means research and development activities performed by PH360 on user data. These activities include, without limitation: improving our Services and/or offering new products or services to you; performing quality control activities; conducting data analysis that may lead to and/or include commercialization with third parties. We will never share your personal information with a third party without your consent.

“Service” or “Services” includes, without limitation: PH360′s products, software, services, mobile application, and website as accessed from time to time by the user, regardless if the use is in connection with an account or not.

Your Personal Information

In the course of your relationship with PH360, we will collect several types of Personal Information. “Personal Information” is information that could be used to identify you, either alone or in combination with other information. We collect such information from you when you purchase our Services, create a personal account, complete surveys and forms, and/or when you communicate with us or request information from us. Personal Information collected online or through our mobile application can be combined with Personal Information collected offline. We collect five primary types of Personal Information through our Service and website.

“Registration Information” is information that we collect from you when you purchase or sign up for our Services. Examples of such information include but are not limited to your name, credit card information, billing and shipping addresses, and contact information, such as email address and telephone number.

“Self-Reported Information” includes information you provide to us, including but not limited to information about disease conditions (e.g. Type 2 Diabetes), other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), personal traits (e.g. eye color, height, weight), ethnicity, lifestyle (e.g. current diet, activity level), and/or family history (e.g. similar information about family members). We collect this information from you if and when you enter the information into your profile, surveys, forms, or features while signed in to your account.

“User Content” includes information other than Self-Reported Information, generated by users of PH360 Services, transmitted, whether publicly or privately, to PH360. User Content includes without limitation data, text, software, music, audio, photographs, graphics, video, messages, or other materials. For example, User Content includes posts made to the PH360 community forums or emails to Customer Support. User Content does not include Self-Reported Information.

“Web Behavior Information” includes information on how you use the PH360 website (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology, or other means.

“Referral Information” includes information that you provide when referring PH360 Services to your friends and contacts as part of a PH360 referral program. This information can include your name, your email address, and the name and email address of the person you are referring our Services to. If you chose to allow PH360 to access your address book or contacts on your computer or mobile device, we will collect the contact information of the friends you select to enter the referral program. When you make referrals using a social network such as Facebook or Twitter it may also include information from your profile that is made available to PH360 when we connect to your social network to post the referral on your behalf. The information that PH360 is provided during this process varies depending on the social network and your privacy settings, but can include information such as your name, profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers and any other information you have permitted the social network to share with third parties. Additionally, we and our third party partners who administer our referral program may use cookies to identify you and your referred friends and to monitor the success of our referral program.

How We Use Personal Information

PH360 collects Personal Information from you for all purposes necessary to ensure the regular operation of your account and/or availability of our Services. These include, among other things, providing you with our Services; improving our Services and/or offering new products or services to you; informing you about events; inviting you to participate in specific research projects, contacting you to obtain testimonials or for other promotional purposes; performing quality control activities; conducting other R&D; and conducting Our Research.

PH360 may provide your Personal Information to our third-party service providers, which are companies and people that help us provide, understand and improve our Services. For example, we may use service providers to help host our website, run our mobile application, send emails, implement our marketing campaigns, measure the effectiveness of our advertising, conduct surveys or polls, obtain testimonials, or otherwise help us run or improve our business. In all instances, our service providers act on PH360’s behalf and we require by contract that they protect the confidentiality of any information they receive from us.

We may access, or track your location-based information from your computer or mobile device while you are downloading or using our mobile application or Services for security or health information purposes. Below we will describe the additional ways in which we use subsets of Personal Information.

How We Use Registration Information

We use your Registration Information to authenticate your website and mobile application visits and usage; to enable your purchase; to communicate with you about information, services, and products that you have requested; and to manage and improve our website, mobile application, software, and Services. We give you the opportunity to opt out of optional communications, either through our Service or by contacting our Privacy Administrator at [email protected]

How We Use Phenotype and Self-Reported Information

We use your Phenotypical and Self-Reported Information to provide you with PH360 Services, customize the user experience, and enhance our features. If you allow sharing, Phenotypical and Self-Reported Information may be displayed in other users’ accounts. Self-Reported Information is used to customize your user experience – for example, by adjusting reports of your Phenotype to account for your reported behaviors or environmental exposures.

By using PH360 you give consent to participate in Our Research. We may include your Phenotypical Information and Self-Reported Information in Aggregated Phenotypical and Self-Reported Information disclosed to third parties for the purpose of publication in a scientific journal. Our Research is intended to advance Phenotype knowledge and to create, commercialize, or undertake activities toward the practical applications of this learning to the improvement of health care. Towards the same goals, we may allow research contractors to access your individual-level Phenotypical and/or Self-Reported Information onsite at PH360’s offices for the purpose of conducting scientific research, provided that all such research contractors will be supervised by PH360 and subject to PH360’s access rules and guidelines. We may provide your individual-level Phenotypical Information and/or Self-Reported Information to qualified researchers for the purpose of scientific research and publication in a scientific journal, which could also lead to commercial uses of such information. When your Phenotypical Information and/or Self-Reported Information is being used for research purposes, pursuant to our Research, research onsite at PH360 or via a Research Portal, it will never be combined with your Registration Information.

You may withdraw your consent to participate in our Research and still continue use of PH360 by contacting us at [email protected]  If you do not give your consent to participate in our Research, PH360 may still use your Phenotypical and Self-Reported Information for purposes such as quality control or other R&D activities. Phenotypical and Self-Reported Information used for such purposes may be included in Aggregated Phenotype and Self-Reported Information disclosed to third-party research partners who will not publish the information in a peer-reviewed scientific journal. Research partners may include commercial or non-profit organizations that conduct or support scientific/medical research or conduct or support the development of programs or devices to diagnose, predict, or treat health conditions.

How We Use User Content and Web Behavior Information

PH360 uses User Content to provide our Services and improve the overall user experience. For example, posts made to the PH360 community forums are publicly displayed to other users. By submitting, posting, or displaying User Content, you give PH360 a non-exclusive license to use any User Content that you submit, post, or display on or through the Services, as further described in Section 13 of the Terms of Service. PH360 may make such User Content available to other companies, organizations, or individuals with whom PH360 has relationships, and to use such User Content in connection with the provision of those services. PH360, in performing the required technical steps to provide the Services to our users, may also (a) transmit or distribute your User Content over various public networks and in various media; and (b) make such changes to your content as are necessary to conform and adapt that content to the technical requirements of connecting networks, devices, services, or media.

Web Behavior Information is collected through log files, cookies, and web beacon technology during a visit to the PH360 website. Web Behavior Information is used to improve our Services and the overall user experience, and if participating in Our Research, your Web Behavior Information may be used and disclosed to third parties in aggregate form for our Research intended to be published in scientific journals. If you choose to withdraw consent to participate in our Research, we may still use your Web Behavior Information for R&D purposes as described above, which may include disclosure of aggregated Web Behavior Information to third-party non-profit and/or commercial research partners who will not publish that information in a peer-reviewed scientific journal.

Log Files. When users visit our website or use our mobile application, PH360 gathers certain information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider, referring/exit pages, operating system, date/time stamp, and clickstream data (i.e. a list of pages or URLs visited). This information may be linked to a particular user’s profile ID or order number. We use this information to analyze trends, administer the site, track users’ movements around the site, identify and resolve issues, and gather demographic information about our user base as a whole.

1. The ph360.me website also uses cookies. For information about cookies and how they are used on PH360’s website, please read our Cookie Policy.

Web Beacons. A web beacon is a clear graphic image that is loaded by your web browser when it accesses a website and that records a user’s visit to a particular web page. We, or third parties that work for us, may place cookies and web beacons on our website, in our emails, and in our advertisements that appear on other websites or in emails sent by others that mention our products and services with our permission. The purpose of our web beacons is to support operation of our website and to offer additional products and services through targeted advertisements. For example, we may use beacons to determine when someone views a web page, count how many individuals visit our website after clicking advertisements placed on other websites, or count how many people have purchased products from our website after viewing an advertisement we placed. Web beacons may also help us determine the effectiveness of an email campaign because the beacons can count the number of individuals who open an email or forward it to others. We use this Web Behavior Information to better tailor our marketing to you and may also use this information to customize content on our website, enable a shopping cart, or conduct research. Third parties only collect anonymous Web Behavior Information through the use of web beacons, allowing statistical analysis relating to the performance of our advertising.

If you wish to disable web beacons, it is possible to prevent your browser from loading them, although there is not currently a standard method for doing so.

Information Sharing

PH360 may provide you the ability to connect with other individuals who have PH360 accounts through our community forums, social media and other sharing features. For some features, opt-out is required to avoid notifications. In addition, you may be provided with the ability choose to disclose certain parts of your Personal Information to friends and/or family members, groups of individuals, third-party service providers, doctors or other health care professionals, and/or other individuals. We recommend that you make such choices carefully.

Personal Information, once released or shared, can be difficult to contain. PH360 will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with a third party. Likewise, if you are reading this because you have access to the Personal Information of a PH360 customer through a multi-profile account, we urge you to recognize your responsibility to protect the privacy of that person. It is incumbent upon customers to share Personal Information only with people they know and trust. Users with multi-profile accounts should use caution in setting profile-level privacy settings.

Ordering PH360 Services as a Gift

If you provide us personal information about others, or if others give us your information for purposes of ordering a PH360 account as a gift, we will only use that information for the specific reason for which it was provided to us, provided that once a gift recipient registers for his or her Services and agrees to our Terms of Service and Privacy Statement, his or her information will be used consistent with this Privacy Statement and those agreements.

Sharing Discoveries

If you provide us personal information about others within the mobile application for the purposes of sharing a PH360 discovery we will use the email address you provide, or access your contacts list if you choose to allow us to do so, to send a one-time email with the discovery and an invitation inviting him or her to visit the site. PH360 does not store this information.

If you provide us personal information about others on our website for the purposes of sharing a PH360 discovery we will use the email address you provide and any additional information you provide to send a one-time email with the discovery and an invitation inviting him or her to visit the site. PH360 stores this information for the sole purpose of sending this one-time email. Your friend may contact Customer Care at [email protected] to request that we remove this information from our database.

Making Referrals

If you take part in a PH360 referral program to promote PH360 Services to your friends we will use the Referral Information you provide for the sole purpose of sending these referral emails. If as part of the referral program you provide us with a friend’s email address, you confirm that your friend has provided you with his or her consent to be sent the referral email. We will let your friend know that you asked us to contact them. Additionally, we may collect information from you and your friends through the use of cookies and other technology, so we can monitor the success of our referral program and keep track of friends you refer who may sign up for our services and to credit you with any benefit that is available under our referral program . For information about cookies and how they are used on PH360’s website, please read our Cookie Policy. If your friend or contact has any questions about our use of this information then they may contact Customer Care at [email protected]

Information Disclosure

We do not sell, lease, or rent your individual-level Personal Information without your consent. As a general rule, PH360 will not disclose your individual-level Personal Information to any third party, except under the following circumstances:

Partners or service providers (e.g. credit card processors) process and/or store the information in order to help us provide, understand or improve PH360′s Services.

In your consent for research, research contractors may access your individual-level Phenotypic and Self-Reported Information onsite at PH360′s offices for the purpose of scientific research, provided that all such research contractors will be supervised by PH360 and subject to PH360′s access rules and guidelines. Qualified researchers (who must comply with certain requirements) may access your individual-level Phenotype and/or Self-Reported Information for the purpose of scientific research, which could lead to commercial use.

We are required to disclose this information by law or we do so in coordination with regulatory authorities (see the section below titled “Information Disclosure Required By Law”).

You have provided explicit consent for us to do so.

PH360 may disclose Personal Information for the following reasons:

Our Research. PH360 may disclose Aggregated Phenotypic and Self-Reported Information intended to be published in a scientific journal to research collaborators or as a result of publication. You may give/withhold consent for your data to be used in Our Research at any time through your Account Settings at any subsequent time which will be effective thirty (30) days thereafter; however, we cannot withdraw information that has previously been used for published research or shared with external collaborators prior to your request to withdraw consent. PH360 will not use your Phenotypic Information in new research that starts thirty (30) days or more after your withdrawal of consent.

Contact information. PH360 will ask for and require your explicit consent to allow partner organizations (not including service providers) direct access to your Registration Information.

Commercial partnerships. PH360 may enter into commercial arrangements to enable partners to provide our Service to their customers and/or to provide you access to their products and services. We will not provide any individual-level Personal Information to these commercial partners without your consent. PH360 may include your Phenotypic and/or Self-Reported Information in Aggregated Phenotypic and Self-Reported Information disclosed to these commercial partners even if you have chosen not to give consent for your data to be used in Our Research.

Information Disclosure Required By Law

Under certain circumstances Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. You acknowledge and agree that PH360 is free to preserve and disclose any and all Personal Information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that PH360 may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the PH360 Terms of Service; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of PH360, its employees, its users, its clients, and the public. In the event we are required by law to make a disclosure, we will notify you through the contact information you have provided to us in advance, unless doing so would violate the law or a court order.

Linked Websites

PH360 provides links to third-party websites operated by organizations not affiliated with PH360. PH360 does not disclose your Personal Information to organizations operating linked third-party websites. PH360 does not review or endorse, and is not responsible for, the privacy practices of these organizations. We encourage you to read the privacy statements of each and every website that you visit. This Privacy Statement applies solely to information collected by PH360.

Customer Testimonials

We post testimonials from consenting customers on our web site, and may use testimonials in other formats consistent with consent received. Customer testimonials may contain personally identifiable information. We may use your Personal Information to contact you to obtain a testimonial and obtain your consent via email or agreement sent via fax, or mail prior to using such testimonial and/or using your name along with your testimonial as required.

Your Choices Regarding Your Information

You can opt-out of receiving certain messages or notifications from us by logging into your PH360 account and changing Account Settings or by contacting our Privacy Administrator at [email protected] You can also click the “unsubscribe” button at the bottom of promotional email communications. Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

At your written request we will close your account and will remove Phenotypic Information from your account. See the section below titled “Account Closure and Correction of Personal Information.”

You can use the browser that you are viewing this website with to enable, disable or delete cookies. Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the website and other parts of the website may also not work properly. To find out more about cookies and how to manage them, please review our Cookie Policy.

Account Closure and Correction of Personal Information

If you no longer wish to participate in our Services, you may close your account by sending a request to [email protected] When closing an account, we remove all Phenotypic Information within your account (or profile) within thirty (30) days of our receipt of your request. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes.

If your Personal Information changes, you may correct or update your Registration Information via your Account Settings page.

Newsletter and Email Communications

You may choose to stop or start receiving our newsletter or marketing emails by changing your notifications settings in your account via your Account Settings page, or you can contact us at [email protected]

Security

PH360 takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, PH360 uses a range of reasonable physical, technical, and administrative measures to safeguard your Personal Information, in accordance with current technological and industry standards. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.

Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify PH360 of any unauthorized use of your password or account. PH360 cannot secure Personal Information that you release on your own or that you request us to release.

Business Transitions

In the event that PH360 goes through a business transition including but not limited to a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

Changes to This Privacy Statement

This Privacy Statement was last updated June 17, 2014. Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our customers’ account login pages for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes.

Contact Information

If you have questions about this statement, please email PH360′s Privacy Administrator at [email protected]