Privacy Policy

Last Updated: October 1, 2023

This Privacy Policy applies to all who (i) visit and use our website, www.avea-life.com, social media sites and other platforms, and online services; and (ii) purchase, use or access any products or services, the mobile apps, software, platform and all other relevant services and products provided and offered by us, our affiliates and our partners (collectively the “site”, “products”, or “services”).

This Privacy Policy explains how Avea Life Inc. (“Avea”, “we”, “our”, or “us”) collects, uses, processes, and discloses your information.

This Privacy Policy is incorporated into our Terms of Services, which also apply when you use our site or purchase our products. By visiting, accessing, or using the Site or accessing, purchasing or using the products, you agree to the terms in this Privacy Policy and consent to the collection, use, process, disclosure of your information as described in this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please cease visiting the site, do not provide us with your information, or otherwise interact with us or the site.

We reserve the right to modify this Privacy Policy at any time. If we make any material changes to our Privacy Policy, we will provide notice on this site or through other means. We encourage you to periodically review the privacy policy for any modifications. Your use and continued use of the site and any of our service after we post any amendments or modifications to this Privacy Policy will be deemed your acceptance of and consent to this Privacy Policy and its changes. You can determine when this Privacy Policy was last revised by referring to the date it was “last updated” above.

I. Information collection

What information do we collect?

When you visit and interact with our site (including when you make a purchase through our site), we may collect and you consent our collection of some or all of the following information directly from you and automatically as you use our sites or products:

• Account information. Such as name, address, telephone number, email address, date of birth, purchase and ordering history, payment information, and other information you provide during account registration or when purchasing the products.
• Test information. When you purchase, access, and use our at-home test or diagnostic products, its accompanying saliva or blood drop kit, and all the related platforms, applications and services, you agree to provide and consent that we may collect the following Test Information:
• Sample Information. To access or use any test, you must purchase, or receive as a gift, a testing kit, create an online account and register your kit, and ship your sample (such as a saliva sample) to our partner laboratory and third party service providers (“Laboratory”). “Sample Information” refers to your sample and your DNA and other data extracted by the laboratory from your sample for analysis.
• Genetic Information. “Genetic Information” refers to the genetic and/or epigenetic data including those generated through processing of your sample by us or by the Laboratory, our contractors, vendors, successors, or assignees, or otherwise processed by and/or contributed to us and includes the results reported to you as part of the products.
• Test Results. “Test Results” refer to the results and other data obtained and generated from using the test (e.g., biological age, system age scores, cumulative rate of ageing, etc.).
• Research information. From time to time, we may engage in a wide variety of research, study and observation internally or in collaboration with third parties and may collect or ask you to provide certain information for such research purposes via, for example, a survey or questionnaire. Such information may include: your ethnic origins, ancestry, demographics, personal traits, physical features such as eye colour, behavioural information such as exercise habits, health conditions or other health-related information, your family history of those conditions, medical history, known genetic mutations in you or your family members, lifestyle information, etc.
• Self-report information. Avea may ask you to provide various Information at various times and places (e.g., when you register for your quiz on the site), or you may voluntarily provide certain information to us (e.g., when you participate in our market campaign). In some cases, if you choose not to provide us with the requested information, you may not be able to access all of the site or participate in all of its features.
• User content. This includes information that you create or content that you post or upload on our site, social media, or public forums that relate to us, such as blogs, data, text, software, documents, audio, photographs, graphics, video, messages, discussions, comments, emails, or other materials that you create or provide to us through public or private transmissions.
• Web-behaviour information. It includes such things as data from cookies or pixel tags, or data about the device you use to access, use, or interact with our site, such as your IP address or the type of browser you are using. Normally, web-behaviour information alone cannot identify you and has not been associated with you.

All of the above are collectively referred to as “information.” The Information may or may not constitute your Personal Information under the law. “Personal information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you. For example, if your Information is aggregated, it can no longer be linked to you and thus does not constitute “Personal Information.” “Aggregate information” means information that relates to a group or category of consumers, from which your identity has been removed, that is not linked or reasonably linkable to you or your household. Certain Information may also constitute “Sensitive data” under the law. Sensitive data generally refers to a category of personal information that reveal racial or ethnic origin, or mental or physical health diagnoses. The processing of genetic data to personally identify an individual can be considered sensitive too.

For example, we may collect the above Information from you when you:

• Register, subscribe, or create an account with Avea;
• Purchase products/services from Avea through our site or via other means;
• Open or respond to our offers;
• Contact customer service, or otherwise make use of our customer support tools;
• Sign-up for our updates, notifications and newsletters;
• Respond to our or our partners’ surveys or polls;
• Use our referral program;
• Use or access to the functions, services and pages of our site;
• Connect, link, or “share” our site via social networking sites or other third-party sites or products;
• Provide ratings or reviews of our products and services;
• Apply for a job at Avea.

Web-behaviour information: We may use cookies, web beacons/pixel tags, and other technology (collectively “cookies”) to automatically collect information about you when you visit our site or interact with us. As mentioned, web-behaviour Information alone normally cannot identify you and has not been associated with you.

A “cookie” is a small text file that a website’s server places on a computer’s web browser. These cookies may be delivered in a first party or third party context. For example, we may collect information about your browser type and version, operating system, user language, ISP, viewed web pages, applications, links that are clicked, IP address, the presence or absence of “flash” plugs-ins, screen resolution, connection type, sites visited before and after visiting our site, details about items purchased, and emails we send that you open, forward, or click through to our site.

It is possible that one or more of our sites that link to the Privacy Policy utilise flash cookies, otherwise known as local shared objects, to store your preferences or display personalised content based upon what you view on our site. “Flash cookies” use technology to remember settings, preferences, and usage similar to browser cookies but these are managed through a different interface than your browser and are not disabled from your normal browser settings. Cookie management tools provided by your browser will not remove Flash cookies. Please see the last section under Cookies and Tracking for information on how to disable Flash cookies.

By collecting web-behaviour Information we can:

• Better understand how you interact with us or our site;
• Give you a more personal and optimised online experience by tracking your preferences;
• Provide you with cross-context behavioural or targeted advertising;
• Improve our site and products/services;
• Fulfil contracts with our business partners;
• Help confirm receipt of and response to our emails;
• Provide more effective customer service.

We may use web-behaviour information for the same purpose as your other Information set out below. We may also tie your web-behaviour information to your other Information. You can choose NOT to provide us with your Web-behaviour information by disabling cookies according to the section under cookies and tracking, but please be aware that certain portions of the site may not be available to you if you do so.

II. Information use

How do we use your information?

General Use: We use the Information we collect for various purposes, including to:

• Process online purchase orders and keep you informed about the status of your order;
• Provide customer service (for example, answering your questions or responding to a request);
• Verify your identity;
• Establish an online Avea account for you;
• Operate, perform, analyse, maintain and improve the site, our products and/or services;
• Develop new products and/or services;
• Process, analyse and deliver test result information of purchased tests and future applications;
• Conduct marketing campaigns and provide targeted advertising;
• Communicate and provide administrative messages, requested information, additional information that may be of interest to you (including updates and reminders to new research, future products, promotions and special opportunities);
• Validate your ability to access and/or use certain products or services that may only be intended for individuals meeting certain eligibility requirements or criteria, such as health care professionals;
• Establish your eligibility for special offers or discounts;
• Determine your qualification for external services from partners;
• Recruit you for internal or external research and allow us to use and share your Information for research purposes;
• Perform analytics and conduct customer research;
• Allow you to interact with third party sites, services and products (for example, you can link to or view content from third party sites within our Site, view our content on a third party site, or link to third party devices);
• Administer online surveys, polls or special offers from us or through our third party business partners;
• Obtain and post product reviews, testimonials, and comments;
• Enhance network and information safety, integrity, and security, including prevention of fraud and other unauthorised or illegal activities on our site;
• Manage our everyday business needs, such as administration of the site, fulfilment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and terms of services;
• Comply with our legal, licensing, and regulatory obligations;
• Determine whether you are a suitable candidate for any open jobs at Avea.

We may also use the Information with your consent or as otherwise required or permitted by law.

Use of test Information and research information: We understand your test results and health conditions may be sensitive to you, so we will handle such information with extra care. We have implemented strict access controls internally, including limiting access of your Test Information and Research Information to a select group of employees, maintaining an audit trail of any access.

We may use your Test Information and Research Information for the purposes described above, but with additional restrictions. Specifically, we will only use such information for research purposes with your consent if you participate in our research. For eligible customers, taking part in our research is completely voluntary, and you can change your mind any time. You may refer to our Research Consent Form for further details, including how your Test and Research Information may be used in research.

Based on our analysis of your Test Information, Avea may combine your Test Results with certain of your other Information for marketing purposes (including targeted advertising) and to make personalised supplement and lifestyle recommendations to you. These personalised recommendations are not medical decisions, diagnoses, or treatment recommendations.

Social networking: Certain social media features available on our site may be hosted by third party sites. For example, some social networking services allow you to share products and services from our site via your social networking profile. Our site also allows you to apply for available jobs at Avea through your LinkedIn account. If you choose to make use of third party social media services (such as Facebook, Twitter, or LinkedIn), we may receive Information about you, such as your name and email address that you have made available through those services. We encourage you to visit those third party social networking services’ privacy policies and review your privacy settings directly on those services. Any information we receive through third party social media services may be used as described in this policy.

Resume submission: Avea may post available jobs on the site and allow you to submit your resume to us. Avea may ask for your name, street address, phone number, e-mail address, position applied for, education, work experience, skills, etc. (“Personal recruitment information”). The personal recruitment Information and the resume you submit will be used by Avea. to determine whether you would be a good candidate for the requested job. The personal recruitment information may be saved in our files in case you would be a good candidate for a future job. The personal recruitment Information will be shared on a need-to-know basis, and will not be given to any third parties other than our service providers who process information on our behalf.

III. Information disclosure

Under which circumstances your information may be shared?

Avea is committed to keeping your personal information confidential as required by law. We do not sell to third parties your personal information collected on the site for monetary consideration. In addition, we do not disclose your personal information we collected to third parties for their own direct marketing purposes without your consent. We may share your Information as permitted by law or as follows:

• With any Avea affiliate, which may only use your Information for the purposes described in this Privacy Policy;
• With our vendors, contractors, business providers and partners (including Laboratory) as necessary for them to provide their services to us and help us perform, provide, analyse and improve our services and products, including without limitation processing and fulfilling orders, data analytics and storage;
• Assistance with our own marketing purposes (including targeted advertising);
• Assistance with our distribution of emails and other communications, fraud prevention services, delivery and logistics, site improvement and operation, and to accomplish the other purposes for information collection and use described above Sections I and II;
• When we include your de-identified or aggregate Information in the relevant research database or in relevant publications;
• In the event we or any of our affiliates file for bankruptcy, or where there is a transfer of ownership (or assets) in connection with proposed or consummated corporate reorganisations of Avea or any of our affiliates, such as mergers, acquisitions, or sales of business units;
• To comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;
• To combat fraud or criminal activity, and to protect our rights or those of our affiliates, users, and business partners, or as part of legal proceedings affecting Avea;
• In response to a subpoena, court order, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate;
• With your consent, we may share your Information with third party collaborators for research purposes. We may engage in research with third parties like universities, hospitals, health systems, government institutions, or private companies to develop new tests, applications, products or services, validate technologies, or improve existing technologies or processes.
• With your consent for other purposes.

We may also disclose web-behaviour information:

• For the same reasons for disclosure as listed above;
• With third party partners for their own research and analysis;
• With third-party advertisers or other vendors to place our advertisements on third-party sites, to facilitate targeted content, and to analyse the effectiveness of our advertisements.

We do not voluntarily share your Personal Information to third parties for their own direct marketing purposes without your consent. Our third party advertising and web analytics partners, however, may use cookies to collect information about your visit to our site and other sites or apps. These advertisers and web analytics service providers collect such information in order to, among other things, deliver ads that are targeted to your interests and to better understand the usage and visits to our site and other websites tracked by these third parties.

This Privacy Policy does not cover the collection methods or use of the information collected by any third party companies (including third party advertisers and web analytics service providers), and Avea is not responsible for cookies in third party ads. We encourage you to review the privacy policies or statements of these third party companies to learn more about their use of cookies and other similar technologies.

How will your test information be shared?

When we share your Test Information for research, we will de-identify such information by, for example, assigning a random ID. Without your express consent, we will NOT share any of your Test Information to any third parties for research purposes.

IV. Research consent form

As mentioned above, we may use and share your de-identified Information for internal and external research purposes with your consent. You may refer to the Research consent form by clicking here for details. If you consent to our use of your Information for research purposes, we may use and aggregate it and may further use and share such de-identified or aggregated Information for research purposes without separately obtaining your explicit consent.

V. Choices

Withdrawal of consent and deletion: You may withdraw the consent to this Privacy Policy or to the collection, use, and disclosure of your Information and request the deletion of your Information and your account by contacting us at any time. If your Information is deleted, you will no longer have access through the site or products to your Information. Your withdrawal will not affect the lawfulness of our collection, use, processing and disclosure based on consent before your withdrawal (e.g. your Information will not be removed from ongoing or completed research studies which started before we receive your request to delete your Information). If you wish to withdraw your consent to this Privacy Policy, please email support@avea-life.com.

Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated personal information is deleted and any stored samples are discarded, subject to the following limitations:

• Information previously included in research. The Test Information, Research Information and/or other information that you have previously provided and for which you have given consent to use in our research cannot be removed from completed studies that use that information. Your data will not be included in studies and research that start more than 30 business days after your account is closed (it may take up to 30 business days to withdraw your information after your account is closed).
• Legal retention requirements. Avea and our partners/vendors will retain your Information as required for compliance with applicable legal obligations. Avea will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, and record of legal agreements for a limited period of time as required by contractual obligations, and/or as necessary for the establishment, exercise or defence of legal claims and for audit and compliance purposes.
• Other legally allowed purposes. We may also maintain your Information in order to complete transactions for which your Information is collected, detect illegal activity, debug to identify and repair errors, exercise rights provided by law, or conduct any other activities permitted under the law.

Commercial emails: You may choose to opt-out of receiving commercial emails from us by following the instructions contained in any of the commercial emails we send. Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial emails related to your account and your transactions on the site. Also, please allow us 15 business days from when the request was received to complete the removal. You may update your account preferences at any time. If you wish to opt-out of receiving offers directly from our third-party business partners, you can follow the instructions in the emails that they send you.

Cookies and tracking: You can disable cookies at any time by adjusting your browser settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available.

To disable “flash cookies,” you can adjust the setting of your Flash player to block Flash cookies using the tools contained in your website storage settings panel. More information can be found on Adobe’s website.

Please be aware, however, that if you turn off cookies, you will not be able to take full advantage of all of our site features. For example, we will not be able to recognize you as a registered user to allow you access to your account information.

Access and Correction: If you wish to access, correct, modify or update any of your Information we have received, please contact support@avea-life.com. Also, if you are a registered user, you can access your account at any time to correct, modify or update your account information.

VI. Other sites

This Privacy Policy only addresses the collection, use, and disclosure of your Information by Avea through your visit, use and interaction with the site. However, our site may contain links to other sites that are not owned or controlled by us, such as social networking sites, third party devices, and links to retailers’ sites and e-commerce sites that sell our products or services. The Privacy Policy does not address nor do we control or have responsibility for the policies or practices of any third parties or any third-party sites to which this site links. If you provide any information to such third parties, different rules regarding the collection, use and disclosure of your personal information may apply.  We strongly suggest you review such third party's privacy policies before providing any data to them. These other sites may send their own cookies or clear GIFs to users, collect data or solicit personal information.  We cannot control this collection of information. You should contact these entities directly if you have any questions about their privacy practices.

VII. Security

Avea takes appropriate steps to manage the privacy of your Information and the security of the site. We have implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard your Information. Still, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, Avea cannot guarantee that your Information is under absolute security with the existing security technology. If you have any questions about the security of our site, or wish to report a breach of your Information, you can contact us at support@avea-life.com.

VIII. Retention policy

Avea retains your Information for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or to fulfil a legal obligation. Because these needs can vary for different data types in the context of different services, 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, and our legal or contractual obligations.

For customers purchasing, accessing, and using the DNA & Bioage Test, Avea and the laboratory stores de-identified raw data generated from your saliva samples for 3 months before the samples are destroyed (after we ensure quality control) and we will store your data (including your Test Information) permanently or as permitted by the law, but you may request deletion of your data as set forth under this Privacy Policy at any time. You consent to sample and data storage and additional analysis by us and our third party partners.

Avea will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, communications related to inquiries or complaints and legal agreements for a limited period of time as required by law, contractual obligations, and/or as necessary for the establishment, exercise or defence of legal claims and for audit and compliance purposes.

IX. Children privacy

Our site, services and products are designed and intended for adults. By using our site, you represent that you are at least 18 years old and understand that you must be at least 18 years old in order to create an account and purchase the products through our site. If we obtain actual knowledge that an account is associated with a registered user who is not at least 18 years old, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18 and believe he or she has disclosed personally identifiable information to us, please contact us at support@avea-life.com. A parent or guardian of a child under the age of 18 may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.

X. International users

If you reside in a country outside the United States, please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country. You are solely responsible for compliance with foreign laws, not Avea, when you provide your Personal Information and use the site from outside the United States. You agree that the laws of the United States will govern the processing of your personal information, including any obligations of security and third-party sharing.

XI. Contact us

If you have any questions, comments or complaints about our privacy practices or this Privacy Policy or wish to exercise your rights under the applicable law, please contact us via our contact form, by email at support@avea-life.com, or by direct mail at Avea Life Inc. at 3 Germay Dr, Wilmington, DE 19804.