At Attayn Live, we make your privacy a central part of our Services. This privacy statement explains our collection, use, and disclosure of Personal Information.
This privacy statement applies to Attayn Live. and our controlled affiliates and subsidiaries. References to our “Services” in this statement include our websites, apps, software, and related services. This statement applies to our products that display or reference this statement. You’ll also find information about how you can exercise your privacy rights. By using our Services, you agree to Attayn Live using your personal information as described in this Privacy Notice.
This Privacy Notice is incorporated into our Terms of Use. By using the Site, you acknowledge that you have read, understand, and accept the Terms of Use, including this Privacy Notice. If you use this site as an employee or member of an organization, this site may also be operated pursuant to any agreement we may have with your employer, association or group sponsor, or benefit program sponsor.
This statement however does not apply to any third-party products that display or reference a different privacy statement.
We collect your personal information when you interact with us or use our services, such as when you use our Sites to place an order. We also look at how visitors use our Sites, to help us improve our services and optimize the customer experience.
The personal data we collect depends on how you interact with us, the products you use, and the choices you make. We collect information about you from different sources and in various ways when you use our products, including information you provide directly, information collected automatically from third- party data sources and data we infer or generate from other data.
We collect the personal data you provide to us. For example, we collect your contact information including name, email address, phone number, username, and password when you create an account or purchase a Service from us. If you make a purchase, we also collect credit card numbers and other payment information through our payment processor.
You may also provide us with other information when interacting with us by email, phone call, via Attayn Live Support, or through other methods of communication. This may include feedback and customer support inquiries. This also includes your preferences for receiving communications about our activities, events, and publications.
We also collect voluntary information through surveys. Basic information surveys may collect personal traits and characteristics such as sex, age, ethnicity, weight, and height. This may also include behavioral and social information such as your occupation, commute, diet, alcohol consumption, and tobacco use, fitness and exercise, and sleep behavior. Health surveys may collect more detailed information about your present or past physical or mental health, medical conditions, diseases, and symptoms, and other medical information.
Through your use of the services, you may voluntarily submit saliva and/or blood sample. DNA is then extracted from your blood and/or saliva at one of our partner labs and is converted to a machine-readable code (“DNA Data”) which is used to provide our Gene Sequencing Services. DNA test kit code, year of birth, and sex may also be collected for activation purposes.
| Information Category | Description |
|---|---|
| Registration Information |
|
| Payment Information |
|
| Feedback and Correspondence | Information you provide when interacting with us by email, phone call, via Attayn Live Support, or through other methods of communication. This also includes your preferences for receiving communications about our activities, events, and publications. |
| Survey Information (self-reported) |
|
| Genetic Information | DNA extracted from your saliva at one of our partner labs is converted to a machine-readable code ("DNA Data") which is used to provide our Gene Sequencing Services. |
| DNA Kit Activation Information |
|
When you use our products, some information is collected automatically. For example, when you visit our websites and interact with us, our web servers automatically log your device's operating system, Internet Protocol (IP) address, access times, browser type and language, the website you visited before our site, and your activity on our websites.
Depending on your device and app settings, we use various tools to enhance your user experience when you use our apps or online services. Our websites and online services store retrieve data using cookies and similar tracking technologies set on your device. We may also use cookies and web beacons to collect information from third parties (such as Google) to help advertise our products and services, to analyze the effectiveness of our marketing or the performance of our websites, and to determine whether you may be interested in other products or services. You can refuse to accept and delete cookies by adjusting your browser setting. Please note that refusing or deleting cookies may impact your browsing experience on our websites, or prevent you from using some of its services, and it may result in the deletion of any preferences you have set. For more information on cookies and how to reject or delete cookies please visit our Cookies Notice.
We also log information about your use of the Services, including your interactions with the Services and histories of your transactions, and the parties with whom you’ve shared your genetic information.
We may collect information from you, your representative, your employer, association, group, or benefit program sponsor, and/or third parties that have roles in delivering services to you, your employer, association, group, or benefit program sponsor. These may include insurance companies, plan administrators and vendors, brokers or agents, credit agencies, and financial institutions. You might provide this information when you visit this site; apply for insurance coverage; enrol in an association, group, or benefits program; communicate with us through email, chat, and instant messenger; speak to an Attayn Live representative by phone or in a call center, or send mail/faxes to our office. In addition, your employer, association, group, or benefit program sponsor or someone acting on their behalf may provide us with information about you.
Note: If you supply us with personal information about other people, you represent that you have the authority to provide this information on their behalf. In these instances, you further represent that the individuals to whom this information relates have been informed of and understand the reason(s) for obtaining the information, the manner in which this information will be used and disclosed and have consented to such use and disclosure.
We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. For example, Google Analytics aids us in inferring your city, state, and country location based on your IP address. We also generate your DNA sequence from your saliva sample with assistance from our lab partners.
When you are asked to provide Personal Information, you may decline. But if you choose not to provide or allow information that is necessary for certain products or features, those products or features may not be available or function correctly.
A. Generally: to provide you with our Services and analyze and improve our Services.
We use your data to provide, personalize, analyze, and improve our Services and as otherwise described in this statement or otherwise disclosed to you. These activities include, among other things, using your information to:
In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience.
B. Genetic Results: to process, analyze and deliver your genetic results.
To receive results from our Services you must first create an Attayn Live account, register your kit, and submit your saliva sample to our contracted laboratories which then analyze your samples and provide us with the resulting data. Attayn Live uses your Genetic Information for these primary purposes:
C. Blockchain Ledger
Attayn Live uses blockchain technology to improve transparency and control over genetic data. We are currently in the process of developing our blockchain infrastructure to record user consent settings and requests for access to user data. This will be designed to increase transparency and immutability of data access requests and user consent for sharing data. By storing data requests and consent settings on the blockchain, Attayn Live hopes to enable users to audit any transactions involving their data to ensure that all of the data sharing is acceptable, and no misuse of data has taken place.
Attayn Live is committed to transparency in data sharing and giving you certain control over when and how your genetic data is shared. We only share your Personal Information, including your Genetic Information with third parties with your explicit permission, as necessary to complete your transactions or provide the products you have requested or authorized, or as otherwise described in this Privacy Statement. We may share personal data with our subsidiaries and affiliates that share common data systems and process data as needed to provide our products and operate our business. We do and will continue to, develop our Services around these principles. In the spirit of transparency, the circumstances described below explain when sharing might occur.
As part of our Services, you have the option to share your Genetic Information with others through sharing features in the Services. This includes, but is not limited to, sharing your genetic reports or ancestry information with others on social media platforms such as Facebook.
Note: If you decide to share details about your ancestry, traits, or any other information through these sharing features, you do so at your own risk. We encourage you to review the privacy statements of these third parties before using these features.
You will have the choice to participate in Attayn Live research. Attayn Live research may be conducted by Attayn Live in partnership with third parties such as non-profit foundations, academic institutions, or pharmaceutical companies; or similar third parties independently performing research with Attayn Live facilitating access to the data. These studies may focus on a specific group or population, identify potential areas or targets for therapeutics and drug discovery, genetic research to help in further understanding the relationship between health and the human genome, and ultimately apply all this knowledge to improve healthcare.
Attayn Live is not currently engaged in sharing your data with any researchers. In the nearest future, as the opportunity for you to connect with researchers arises, we will ensure either having acquired the proper consent from you for such sharing or in turn will reach out to see if you are interested in engaging in Attayn Live’s research.
We work with other companies to provide our Services. In turn, we share information with these third-party services providers as necessary for them to provide their services to us and help us perform our contract with you. These third parties support our Services in several ways, including the following areas:
We may use personal data in our possession to create de-identified and aggregated data sets. In other words, some of the data that we collect from you is stripped of all information that may be used to identify an individual and is stored in a data set in combination with other users’ de-identified data. We may then use this aggregate data for any purposes or disclose it to third parties for their purposes in accordance with applicable laws. For example, we use Aggregate Information to provide statistical information such as our users’ Oral Microbiome percentiles.
Attayn Live will not voluntarily share your genetic information with law enforcement. However, under certain circumstances, your genetic information may be subject to processing pursuant to laws, regulations, or judicial or governmental orders, warrants, or subpoenas. In other words, a lawful demand by public authorities may require that we share your Personal Information.
Attayn Live will not share any other categories of Personal Information, other than to cooperate with law enforcement, protect the safety of persons or property, or in enforcing ours, our affiliates or partners’ legal rights. For example, if a user defrauds our Services, we may share that user’s personal information with law enforcement in an effort to recuperate the defrauded costs.
If we are compelled to disclose your Personal Information, we will do our best to provide you with advance notice, unless we are prohibited under the law from doing so. In the spirit of transparency, we will produce a Transparency Report to provide disclosure of the number of valid law enforcement requests for user data across all of our Services.
We may share your personal data if we believe it is reasonably necessary to enforce the Attayn Live Terms and Conditions, protect the security and integrity of our Services, or protect the rights, safety, or property of Attayn Live, our employees, or users.
In the event that Attayn Live is acquired or transferred including in connection with a corporate transaction, bankruptcy, or similar proceedings (including financing, merger, acquisition, dissolution, or a transfer, divestiture, or sale of a portion or all of our business or assets), we will share your personal data Information with the acquiring or receiving entity as a part of the transaction or negotiation for such a transaction. Nonetheless, the promises of this Privacy Statement will continue to apply to your personal data that is transferred to the new entity.
If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:
To make such requests or contact our Data Protection Officer, you can follow the directions outlined in this privacy statement or contact us at [email protected] You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
If you are resident in the United Kingdom, we guarantee the protection of your data in line with the provisions of the GDPR. As such, we shall observe the following principles;
We also recognize your data protection rights to wit:
If you are resident in India, we guarantee the protection of your data in accordance with the following laws;
We retain personal data for as long as necessary to provide the products and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different products, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, the existing data laws in the relevant region(s) and our legal or contractual obligations. For example, all of the data collected by Google Analytics for the purposes understanding our website usage is automatically deleted after 26 months, all mobile identifiers and cookie identifiers placed by Adroll expire and are then deleted after 13 months, and the Recent User Activity feed collected by Hotjar are retained for 1 year.
Attayn Live will store your account profile information, including your raw genetic data, health surveys, and related reports and information, as long as your account is open, unless you make a request for us to delete all or any of your information prior to the closing of your Account as described in this privacy statement. If you decide to close your Account, then Attayn Live will automatically destroy this personal data related to your account. In specific circumstances such as by court order, subpoena, or other legal or regulatory obligations, however, Attayn Live may be required by law to store your information beyond the deletion of your Account or request for deletion of Personal Information. Attayn Live may also retain disaster recovery copies for a fixed period following this deletion, although this data will not be used for any purpose other than disaster recovery.
You may access and delete or change much of your information through your Account Settings. Otherwise, any information that is not accessible in your Account Setting can be accessed and changed or deleted by reaching out to [email protected]
Attayn Live maintains a comprehensive information security program designed to protect your Personal Information through the use of many safeguards. Attayn Live has measures in place designed to protect against inappropriate access, loss, or misuse of Personal Information. For example, we use secure server software to encrypt Personal Information and work with data storage cloud partners that meet our security standards.
While we cannot guarantee that loss, access, or misuse of data will not occur, we use reasonable efforts to prevent these outcomes. We also undertake to notify you as soon as practicable – usually within 72 hours of the breach – where there has been a data breach. To help us protect Personal Information, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.
The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers maintain facilities. Currently, we primarily use data centers in the United States. The storage location is chosen to operate efficiently and improve performance. We take steps designed to ensure that the data we collect under this statement is processed according to the provisions of this statement and applicable law wherever the data is located.
Location of Processing European Personal Data We transfer personal data from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use a variety of established transfer mechanisms such, as the Privacy Shield or contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal data protection, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers- outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
Privacy Shield Attayn Live participates in and has certified its compliance with both the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred to the United States from the European Union (EU), European Economic Area (EEA), and Switzerland. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield List.
We are committed to subjecting all personal data that we receive from the EU member countries, the EEA, and Switzerland to the Privacy Shield Framework Principles in the European Union Data Protection Rights section above. If third- party agents process personal data on our behalf in a manner inconsistent with the principles of either Privacy Shield Framework, they remain liable unless they prove we are responsible for the event giving rise to the damage. If there is any conflict between the terms of this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
Regarding personal data received or transferred pursuant to the Privacy Shield Frameworks, Attayn Live is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). Further, in certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have a question or complaint related to our participation in the EU-U.S. or Swiss-U.S. Privacy Shield, please contact us as indicated at the bottom of this privacy statement. For any complaints related to the Privacy Shield frameworks that cannot be resolved with us directly, you may refer the matter to your local Data Protection Authority or the Swiss Federal Data Protection and Information Commissioner (FDPIC) if you are located in Switzerland. Finally, under limited circumstances and after other available dispute resolution mechanisms have been exhausted, binding arbitration is available for EU and Swiss individuals to address certain residual complaints not resolved by other means.
We will update this privacy statement when necessary to reflect changes in our products, how we use Personal Information or the applicable law. When we post changes to the statement, we will change the "Last Updated" date at the top of the statement. If we make material changes to the statement, we will provide notice or obtain consent regarding such changes as may be required by law.
The Privacy Statement is subject to change at any time. If we make changes to this Privacy Statement, we will update the “Effective date” at the top of this page. Any changes we make to this Privacy Statement become effective immediately, so you should review this Privacy Statement regularly for changes.
In compliance with the Privacy Shield Principles, Attayn Live commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Attayn Live at: [email protected]
Attayn Live has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
Our address is: Attayn Live, 30 N Gould Street, Suite R, Sheridan WY 82801.