OptimumU Health & Wellness Privacy Policy

---

OptimumU Privacy Policy

Last Updated: March 20, 2020

The following Privacy Policy governs the online information collection practices of OptimumU Health and Wellness, Inc. DBA OptimumU (“we” or "us"). Specifically, it outlines the types of information that we gather about you while you are using the www.optimumu.com website (the "Site") and OptimumU mobile application (the “Application”), collectively, the “Services”, and the ways in which we use this information. This Privacy Policy, including our children's privacy statement, does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, or through the mail).

Please read this Privacy Policy carefully. By visiting and using the Services, you agree that your use of our Services, and any dispute over privacy, is governed by this Privacy Policy. Because the Web and Mobile platforms are evolving media, we may need to change our Privacy Policy at some point in the future, in which case we'll post the changes to this Privacy Policy on the Site and Application and update the effective date of the policy to reflect the date of the changes. By continuing to use the Services after we post any such changes, you accept the Privacy Policy as modified.

You acknowledge that our operation of the Services does not constitute the practice of medicine, and specifically does not create a doctor-patient relationship between you and Company. The information provided through the Services is for educational purposes only.

Information We Collect

On Our App:

Except as otherwise set forth herein, we do not disclose your health-related data to third parties without your express permission.

We collect and store personal or other information that you voluntarily supply to us online while using the Services (e.g., while on the Services or in responding via email to a feature provided on the Services). Specifically, we collect personally identifying information from our users during online registration and online purchasing; this information includes, but is not limited to:

Personal Information 

Name

Age/Date of Birth

Sex

Email Address

Health

Height 

Weight

Blood test results

• Total Cholesterol, Cholesterol (HDL)
• Low Density Lipoproteins (LDL)
• Triglycerides
• Fasting Blood Glucose Levels
• Glycated Hemoglobin (A1C) test
• C-reactive protein (CRP) test
• Thyroid stimulating hormone (TSH) test

DNA information

Menstrual period tracking 

Body Fat Percentage

BMI

VO2 Max

Resting Heart Rate

Waist Circumference

Blood Pressure

Health Tracking

Workout and activity

Food and diet

Mood

Daily Steps

Exercise Minutes

Sleep Duration

Overall Food Quality

Alcohol Consumption

Tobacco Use

Push-Up Test

Body Squat Test

Our Application integrates with Apple HealthKit, and you may choose to share any HealthKit data with the application (which will get factored into your Health Score and Wellness trackers discussed below). 

How We Use Your Information 

The main way that we use the information that you provide is to generate your user-experience through the Application. We use information to generate your OptimumU Health Score and Wellness tracker. We may send you notifications through the Services based on the information that you provide, or make certain health-based recommendations. 

We only contact individuals who specifically request that we do so or in the event that they have signed up to receive our messaging, attended one of our events, or have purchased one of our products. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events or purchasing our products. All of this information is provided to us by you. If at anytime, you wish to be removed from our email lists, you can contact us at support@optimumu.com

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties, for example on the Tribes feature within the Application, that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

The Services also include links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Services, use of any information you provide is governed by the privacy policy of the operator of the Services you are visiting or the provider of such products or services.

Be aware that we may release information about our users when release is appropriate to comply with law or to protect the rights, property or safety of users of the Services or the public.

Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our Services is acquired by another company, your information, and information about our other users, may be among the transferred assets.

Tribes

The Tribes features within the Application allows you to connect with other users of the Services. You can communicate within the Application with other members of your tribe, who may be known or unknown to you. You are responsible for all information that you provide to other tribe members and do so at your own risk.

We may introduce functionality that allows Tribe leaders to access aggregated, de-personalized data about the collective group of members in their Tribe. We may also share your basic aggregated scores (such as composite fitness score), but will not share singular data points or inputs. 

Cookies

We also collect and store information that is generated automatically as you navigate online through the Services. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Services. We also may use a standard feature found in browser software called a "cookie" to enhance your experience with the Services. Cookies are small files that your web browser places on your hard drive or mobile device for record-keeping purposes. By showing how and when visitors use the Services, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Services where you may have entered preference information before. The Services also may use web beacons (single-pixel graphic files also known as "transparent GIFs") to access cookies and to count users who visit the Services or open HTML-formatted email messages. We may also collect certain information from your mobile device, such as device and usage information that may include information that is specific to your mobile device (e.g. make, model, operating system, advertising identifier and similar information; (ii) information about your use of features, functions or notifications on the device; and (iii) signal strength relating to Wi-Fi or Bluetooth functionality, temperature, battery level, and similar technical data.

Google Analytics

We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform integrations
• Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Services. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Services, and match the right audience with the right advertising message.

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/. Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because that page is not operated by OptimumU, we are unable to perform the opt-outs on your behalf.

Facebook

As advertisers on Facebook and through our Facebook page, we, (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Privacy Policy. You consent to our collection of such information.

We abide by Facebook’s Data Use Restrictions.

• Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
• We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
• We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
• We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

Children's Privacy Statement

This children's privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of sixteen and provides important information regarding their rights under federal law with respect to such information.

• The Services are not directed to children under the age of sixteen, and we do NOT knowingly collect personally identifiable information from children under the age of sixteen as part of the Services. We screen users who wish to provide personal information in order to prevent users under the age of sixteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of sixteen as part of the Services, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of sixteen as part of the Services.
• Because we do not collect any personally identifiable information from children under the age of sixteen as part of the Services, we also do NOT knowingly distribute such information to third parties.
• We do NOT knowingly allow children under the age of sixteen to publicly post or otherwise distribute personally identifiable contact information through the Services.
• Because we do not collect any personally identifiable information from children under the age of sixteen as part of the Services, we do NOT condition the participation of a child under sixteen in the Service's online activities on providing personally identifiable information.

The HIPAA Privacy Rule

The US Department of Health and Human Services provides: “The HIPAA Privacy Rule establishes national standards to protect individuals’ medical records and other personal health information and applies to health plans, health care clearinghouses, and those health care providers that conduct certain health care transactions electronically. The Rule requires appropriate safeguards to protect the privacy of personal health information, and sets limits and conditions on the uses and disclosures that may be made of such information without patient authorization. The Rule also gives patients rights over their health information, including rights to examine and obtain a copy of their health records, and to request corrections.”

Notwithstanding the fact that the Site and App do not create a doctor-patient relationship between you and Company, our preservation of your personal health information shall be HIPAA compliant if required.

How We Store Your Information

Your information is stored at the server that delivers our content and messaging through the Services. Your information can only be accessed by those who administer the Services.

All of the messaging or emails that are sent to you by us include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you.

How Long We Keep Information

We consider several factors to determine how long we keep personal information. We consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, the contractual requirements with our client organization, and the applicable legal requirements. Once we no longer have a legitimate business need for your personal information, we will securely destroy it in accordance with our standards and applicable laws and regulations.

Right To Examine Information

You have the right to examine any of your personal information that we collected over the previous twelve months. Should you wish to examine such information, please send us a written request to support@optimumu.com. We reserve the right to charge you a reasonable administrative fee to access your information, as permitted by applicable law. In certain cases we may not be able to provide you with access to all of your personal information. We may decline to process requests that are frivolous, relating to information also pertaining to the personal information of another Customer, are unreasonable, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier.

Withdrawal Of Consent 

You may withdraw your consent to the collection of personal information at any time by sending a written request to support@optimumu.com. Upon receiving notice that you have revoked your consent, we will stop using your personal information within a reasonable time, which will vary depending on what information we have collected and for what purpose. Please note that if you do choose to withdraw such consent, your experience of the Services may be diminished.

California

The California Consumer Privacy Act provides Customers located in California with specific access and deletion rights regarding the personal information about you that we collect, use, and disclose. You can exercise your rights by contacting us at support@accentushealth.com. If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from OptimumU.

Disclaimer

Although it is highly unlikely, this policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our Services.

If you have any questions or concerns regarding our privacy policy please direct them to:

support@accentushealth.com