Consumer Health Data Privacy Notice

Effective date: July 1, 2024

This Privacy Notice explains how Proactive Longevity Inc., 1 North Waukegan Rd., North Chicago, IL 60064, and its affiliates or subsidiaries that post a direct link to this Privacy Notice (collectively, “Proactive Longevity”) may process personal data about you through your online and off-line interactions with us through Proactive Longevity services, products, communications, and digital properties (including websites and mobile applications) that refer to this Privacy Notice and where Proactive Longevity may obtain and control your personal data from a third party (collectively, “Proactive Longevity Relationships”).

Proactive Longevity is an international company. This Privacy Notice may be supplemented or replaced by country level Proactive Longevity privacy notices that are applicable only to certain Proactive Longevity affiliates or subsidiaries located in those countries, or by privacy notices for specific activities, such as clinical research. Please refer to the privacy notice provided to you or linked on those Proactive Longevity websites for more information about applicable Proactive Longevity privacy practices. You may also visit our Privacy Center to access our global privacy notices available online.

· Your Personal Data We May Collect

· How we may use Personal Data

· How we may disclose Personal Data

· Cookies and similar tracking and data collection technologies

· Links to third-party sites and social media plug-ins

· Your privacy rights

· Additional information for job applicants

· Additional information for health care professionals

· Additional information for participants in patient and customer programs

· Consumer health data privacy notice

· Loyalty programs

· Privacy of children

· Our contact information

· Data security and retention

· International personal data transfers

· Accessing our sites globally

· Changes to our Privacy Notice

Your Personal Data We May Collect

This section describes the general categories of personal data that we may collect for the purposes described in this Privacy Notice. You can find additional information on the types of personal data (including sensitive personal data) we collect on job applicants, health care professionals, and patient and customer programs, by clicking on the relevant links. You can find additional information about how we collect and process consumer health data under Washington State’s “My Health My Data Act” in consumer health data privacy notice below. You can also find additional information on personal data we collect through cookies and similar technologies in the cookies and similar tracking and data collection technologies section below.

Personal Data we collect from you or from other sources, including sensitive personal data

Proactive Longevity may collect personal data from you directly that you choose to provide us, for example as part of a registration or in response to a questionnaire, as well as information about your Proactive Longevity Relationships. Proactive Longevity may also obtain personal data indirectly, such as from publicly available sources (e.g., websites or publicly accessible databases), third-party data vendors, health care providers and health insurance companies, and third-party partners and collaborators. We may combine personal data from multiple online and offline sources. he categories of personal data that Proactive Longevity may collect about you, some of which may be considered sensitive personal data, include:

Direct identifiers and contact information, including your name, address, phone number, or email address;
Registration information, such as your username and password;
Data relating to your participation in our programs, services, and offerings, including information about products and treatments and health conditions that are of interest to you or that you may have received;
Transaction data, including purchases and inquiries;
Financial account data, such as your credit card number;
Income information, such as when you request financial assistance for one of our products;
Demographic information, such as your age and gender;
Payment-related information if you provide a service to Proactive Longevity;
Geolocation data, such as if you provide your zip code to Proactive Longevity to search for services near you, your device location.
Personal data collected automatically, such as internet activity and other information from the devices and browsers that you use, including your device type, IP address, advertising identifiers, pages that you visit before and after using Proactive Longevity’s online services, search history, and information about the links you click, pages you view, and advertising you interact with on Proactive Longevity’s online services; and
Any inferences we may create about you based on the personal data described above.

We may also collect the following categories of personal data. Depending on the applicable privacy law, these categories may be considered sensitive personal data.

Health-related information, which may be considered sensitive personal data or consumer health data depending on the applicable privacy law, such as information about a physical or mental health condition, treatments you may have received, safety and health information in relation to any of our products or services, or health insurance information;
Demographic data, such as your race, ethnicity or sexual orientation;
Geolocation data that provides your precise location;
Biometric data, such as your face geometry;
Genetic data, such as through clinical trial participation;
Additional categories of sensitive data described in the job applicants, patient and customer programs, and consumer health privacy notice; and
Any inferences we may create about you based on the personal data and/or sensitive personal data described above.

How we may use Personal Data

We may use your personal data for the business and commercial purposes relating to your Proactive Longevity Relationships, communicating with you, improving Proactive Longevity Relationships and our products and services, and for other internal business purposes. You can find additional information on how we use personal data for job applicants, health care professionals, and patient and customer programs by clicking on the relevant links. You can find additional information about how we use consumer health data under Washington State’s “My Health My Data Act” in the consumer health data privacy notice below. You can also find additional information on how we use personal data we collect through cookies and similar technologies in the cookies and similar tracking and data collection technologies section below.

Administering programs, services, and other interactions with you

We may use your personal data for everyday business purposes, such as payment processing and financial account management, contract management, website administration, fulfilment, corporate governance, and reporting obligations. We may also use your personal data to provide you with the programs or services that you requested, or to administer Proactive Longevity services, such as direct purchasing, participating in a savings program or signing up to receive a rebate. This means that we may use your personal data to respond to your questions, provide you with your requested services, offer you optimal customer experience, perform our contractual obligations to you, or perform actions based on your consent.

Marketing communications and disease awareness

We provide marketing communications that promote the use of or offer participation in Proactive Longevity products, services, programs, research events or provide other information that may be of interest to you, such as information on certain health conditions. We will use your personal data to send you marketing communications and to determine the types of marketing communications to send. You can opt-out of marketing communications at any time. Marketing communication opt-out instructions are included in each marketing communication you receive, submit a request at Your Privacy Choices or you can email us at privacydsr@Proactive Longevity.com.

Customized experiences and improving relationships

Your personal data may be used to create customized offers, information, or services tailored to your interests and preferences. It may also be used to develop and improve your Proactive Longevity Relationships. In some cases, we collect your personal data with your consent. In other cases, we collect this information for our legitimate business interest to optimize and customize Proactive Longevity Relationships.

Business and product administration and improvement

To discover new facts that could help Proactive Longevity better understand customer needs and help improve, develop, and evaluate product services, materials, programs, and treatments, Proactive Longevity analyzes personal data for its legitimate interests in business and product improvement.

We may also aggregate and/or deidentify your personal data and use it for the above purposes. To the extent we deidentify any data originally based on your personal data, we will maintain and use such data only in de-identified fashion and will not attempt to reidentify the data.

Compliance with laws and regulations

We may process your personal data to comply with laws and regulations, including those related to pharmacovigilance. We may also use personal data to monitor compliance with our policies and procedures, for fraud prevention, and to investigate and prosecute users who violate our rules or who engage in behavior that is illegal or harmful to others or to others’ property.

How we may disclose personal data

We generally share personal data with third parties for the business and commercial purposes described below. We do not sell personal data to third parties, but we do disclose your personal data to third parties, or allow third parties to collect your personal data, for targeted advertising and analytics purposes. You can find additional information on how we share personal data for job applicants, health care professionals, and patient and customer programs by clicking on the relevant links. You can find additional information about how we share consumer health data in the consumer health privacy notice below. You can also find additional information on how we share personal data we collect through cookies and similar technologies in the cookies and similar tracking and data collection technologies section below.

Affiliates and vendors

We have relationships with various vendors, including our affiliated companies, that help us operate our business and for whom it may be required to have access to your personal data while providing services to Proactive Longevity. We require them to handle your personal data collected through the Proactive Longevity Relationships in accordance with appropriate contractual privacy and security provisions.

Business and research partners

We may partner with other companies and public and private organizations to provide you with products, content, or services on a joint or “co-branded” basis. You should be aware that this Privacy Notice and the collection, use, and disclosure of personal data described herein apply in such co-branded cases. For example, we may use and disclose your personal data as part of a joint or co-branded service or program for purposes described in this Privacy Notice, such as sharing with advertising partners for the benefit of the joint or co-branded service or adverse event reporting. In addition to this Privacy Notice, the relevant partner’s privacy notice may also apply, and, in limited cases, there may be a shared privacy notice.

For co-branded forms and sites, you may see displayed both the Proactive Longevity logo and the logo of the co-branding partner. To access co-branded services, you may have to complete a registration form, and this registration information may be shared with Proactive Longevity’s co-branding partners, and you should read the individual privacy policies of our co-branding partners, as they may differ in some respects from ours.

In addition, we may disclose personal data to our external auditors, attorneys, accountants, and similar professionals based on our legitimate interest in the operation of our business and our obligations to comply with applicable laws and regulations.

Disclosures for legal obligations, to authorities and for product safety

If you contact Proactive Longevity regarding your experience using our products, we may use the information you provide to us to submit our reports to the U.S. Food and Drug Administration, other similar health and medicine government agencies across the world, and as otherwise required of us by law. We also may use the information to contact your prescribing physician to follow up regarding an unexpected event involving the use of our product.

In certain limited circumstances, we may need to disclose your personal data to comply with a legal obligation, process, or demand and for reasons of public interest, such as to comply with reporting obligations to our governing regulatory authorities regarding the safety of our products, in response to a subpoena, or to meet national security or law enforcement requirements.

Disclosure to subsequent owner or operator

We may transfer your personal data to a successor entity upon a merger, consolidation or other corporate reorganization, to a purchaser of all or a portion of our assets, or pursuant to a financing arrangement or co-promotional agreement. The personal data we have about you may be transferred to parties to the transaction based on our legitimate interest in preparing for and completing the transaction. Any successor entity shall be bound by terms and conditions reasonably similar to this Privacy Notice.

Cookies and similar tracking and data collection technologies

We may share your personal data and/or your sensitive personal data, with our advertising and marketing partners so they can use it on our behalf to serve you advertisements that are relevant to you, based on your interests (“targeted advertising”). For example, when you interact with us online, we and our third-party advertising partners, including social media partners, advertising networks and exchanges and data analytics providers, may use cookies, web beacons, and other similar tracking technologies to collect personal data from your browser or device, as described in this section. We may also use, share, and disclose that personal data for the additional purposes described in this section. The categories of personal data collected and the purposes of use and disclosure described in this section are in addition to any other collection, use and disclosure of personal data practices described separately in this Privacy Notice.

Personal data that may be collected through cookies and similar tracking and data collection technologies through our websites and mobile applications

We may collect the following additional categories of personal data through your usage of our websites and mobile applications.

IP address

We may record the Internet Protocol (“IP”) address of your computer or other electronic device when you visit our website, which identifies the electronic device you use to access websites and allows us to customize content.

Other personal data from Cookies and Similar Tracking and Data Collection Technologies

We collect information automatically through your online interactions with us through tracking and data-collection technologies such as cookies, web beacons and pixels, APIs, web services, scripts, browser analysis tools, and server logs. A “cookie” is a small data file sent from a website’s server which is stored on your device’s hard drive, which can track your interests and preferences and recognize you as a return visitor. A “Web beacon” (also known as a pixel tag) is a small, transparent image embedded in a website, email, or application which can track user activity and site traffic, including data about the websites or applications you visited before or after coming to our website or application.

The following types of cookies are used on Proactive Longevity digital properties. Depending on the website, Functional Cookies and Analytics Cookies may be collectively described as Functional Cookies.

Required Cookies: These cookies are necessary for core features of a site to operate properly.
Functional Cookies: These cookies are used to provide a better user experience on the site, such as measuring interactions with particular content or remembering settings.
Analytics Cookies: These cookies allow us to analyze site usage to evaluate and improve its performance. They are used to track certain metrics, such as site response times, and measure interactions with particular content.
Advertising Cookies: These cookies are used to show you ads that are more relevant to you on Proactive Longevity digital properties and elsewhere online and across your devices. We may share this information with our marketing and advertising vendors for a number of purposes described in the sections below

To learn more about cookies and other tracking and data-collection technologies, please visit all about cookies. If you would like to see a detailed list of the cookies we use on our websites, including the third parties that place cookies on our websites, the specific cookie, and cookie lifespan, please click on cookie settings at the footer of this page. If the cookie lifespan is not disclosed in the cookie settings, we use a default life span of twelve (12) months for our own cookies, unless a shorter period is required by law.

Mobile tracking

Some Proactive Longevity Relationships are available as either mobile applications or mobile sites that you can use on your mobile device. If you use a mobile device to access and use the Proactive Longevity Relationships, we may collect mobile-specific information in addition to the other information described above, such as advertising ID, device type, location information, and your use of the Proactive Longevity Relationships.

How we may use personal data collected through cookies and similar data collection and tracking technologies

In addition to the uses described separately in this Privacy Notice, we may use your personal data collected online for the additional purposes as described in this section.

Customized user experiences

We may use your IP address and the personal data that we obtain automatically through the use of cookies or similar technologies to make our websites and mobile applications easier for you to use and navigate, to assist in your registrations and login, to personalize the content by anticipating the information and services that may be of interest to you, and to personalize and improve our interactions with you by making the information we provide more relevant to you. For example, we may use your IP address or other personal data, such as your zip code, in order to suggest clinics that may be near you.

We may also add your website usage data to the general profile we maintain about you so that our Proactive Longevity Relationships with you are a more personalized experience. When we send email communications, we may place a web beacon or similar technology in the email to know whether your device is capable of receiving HTML emails, or to collect data on whether the email or an attachment or link in the email has been opened. We use this data to help us determine and document if a particular part of our communication was more relevant to you.

In some cases, we collect this personal data with your consent. In other cases, we collect this information for our legitimate business interest to optimize and customize your user experience.

Digital analytics and improvement

We may use the personal data that you provide to us and the online information we collect automatically through cookies and similar technologies to monitor user traffic patterns and preferences. We may also track email communications through web beacons or similar technology in emails to create aggregated statistics and reports to analyze the effectiveness of and improve our marketing campaigns.

We collect this information for our legitimate business interests of security, improvement, analytics and optimization of Proactive Longevity Relationships

Targeted advertising

We may provide you with online advertisements for Proactive Longevity products and services on our own websites or third-party websites and mobile services that are tailored to you, which may be based on the personal data that you provide to us, your purchases or use of our products and services, or based on cookies and similar tracking and data collection technologies.

Social Media Analysis

Tell-A-Friend Functions

We may offer “tell-a-friend” functionality on our sites. If you choose to use this function, we will collect your friend’s contact information. We will automatically send your friend a one-time email with the information you specified or inviting your friend to visit the site. We use this personal data you provide us as part of the “tell-a-friend” functionality for the sole purposes of sending this one-time email.

How your personal data collected through cookies and similar data collection and tracking technologies may be shared

In addition to the types of disclosures of personal data described separately in this Privacy Notice, we may share personal data online for the additional purposes as described in this section.

Third-party analytics and measurement

We may share your personal data with our third-party analytics and measurement partners, such as to Google, in order to track and measure performance on our own website and digital properties, including metrics like session duration, session count, and page activity. We may also share your personal data in order to track and measure the performance of our advertisements across other websites and digital properties, such as ad impressions, clicks, and on-site activity.

Third-party targeted advertising

We may provide you with online advertisements for Proactive Longevity products and services on third-party websites and mobile services that are tailored to you, which may be based on the personal data that you provide to us or to a third-party website that you are visiting, or on your browsing activity, purchases, or interests. We may share some of your device information with our advertising partners that we have obtained from cookies and other data-collection and tracking technologies based on your Proactive Longevity Relationships. We may also serve you advertisements for Proactive Longevity products or services that you have previously viewed on Proactive Longevity digital properties. Our third-party advertising partners may also serve you advertisements based on your location information, such as if you are near a particular health conference.

Your Cookie and Location Choices

You can click on “cookie settings” at the footer of this page to opt out of a non-required cookie category.

Your browser also may have tools to disable cookies. Please note, however, that these tools only apply to the particular browser on that device and may not control all types of technologies. In addition, some cookies are essential to the functioning of our websites and deleting or disabling them on your browser will reduce the site’s functionality.

If you want to use your browser instead of our cookie settings feature to opt-out of the Google Analytics or Adobe Analytics tracking cookies, you can install the Google Analytics opt-out browser add-on, and you can opt-out of Adobe Analytics.

You may also opt out of certain targeted advertising on the Digital Advertising Alliance’s consumer choice tool, and the Network Advertising Initiative’s tool.

Due to differences between websites and mobile apps, you may need to take additional steps to opt out of cookie-based advertising for mobile applications. Please check your device settings and mobile app permissions for additional information n on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.

Separately, you also may be able to control the collection and use of your location information through your device’s operating system settings or through app settings.

Links to third-party sites and social media plug-ins

This Privacy Notice only applies to Proactive Longevity Relationships linked to this Privacy Notice and does not apply to third-party websites to which Proactive Longevity Relationships may link, including links to outside websites or advertisements from third parties. We encourage you to review the privacy statements provided by all third parties prior to providing them with personal data.

Proactive Longevity Relationships may use social media plug-ins (e.g., the Facebook “Like” button and the “Share to Twitter” button) to enable you to easily share information with others. When you visit our sites as part of an Proactive Longevity Relationship, the operator of the social plug-in and integrated social media platforms can place a cookie on your device that enables that operator to receive your personal data that allow the operator to recognize individuals who have previously visited our sites. If you are logged into the social media site while browsing on our site, the social media plug-in allows that social media site to receive information that you have visited our site. The social media plug-in also allows the social media site to share information about your activities on our site with other users of that social media site. These sharing settings are managed by the social media site, and you should refer to those sites’ privacy policies for information about their privacy and data-sharing practices.

Your privacy rights

Depending on the jurisdiction in which you live, you may have certain rights with respect to Proactive Longevity’s use and disclosure of your personal data.

Consistent with the collection practices described in this Privacy Notice, we may collect certain categories and specific pieces of personal data either from you or from other third parties. We collect, use, and disclose personal data for our business and commercial purposes described in this Privacy Notice.

We do not sell your personal data, but we do disclose your personal data to third parties, or allow third parties to collect your personal data, for targeted advertising and analytics purposes. If you live in certain jurisdictions within the United States, you may opt out of these disclosures, as described further below.

Furthermore, Proactive Longevity receives, and may further share with its collaborators and partners, as described in this Privacy Notice, deidentified health data from health care providers and health plans, subject to the Health Insurance Portability and Accountability Act of 1996, as amended, and implementing regulations (collectively, “HIPAA”). The health data received by Proactive Longevity was deidentified based on either HIPAA’s “safe harbor” method, which means that certain direct identifiers were removed from the health data, or HIPAA’s expert determination method, which means that a qualified statistician reviewed the health data shared with Proactive Longevity and confirmed that there is a very small risk that an individual could be identified from the remaining health data. When data is deidentified in accordance with either HIPAA’s expert determination or safe harbor method, there is a very small, but not zero, chance that the deidentified health data could be linked back to a specific individual. Deidentified data is not protected by HIPAA.

You may, depending on where you reside, have the right to request:

Information about the personal data that Proactive Longevity has collected, used, and disclosed about you. This includes:

the categories of personal data collected
the categories of sources from which your personal data was collected
the business or commercial purposes for which Proactive Longevity collected your personal data
the categories of your personal data that was disclosed for a business or commercial purpose
the categories of third parties with whom Proactive Longevity shared your personal data

The specific personal data that Proactive Longevity has collected about you.
To have your personal data deleted.
To have your personal data corrected.
To transmit personal data to another controller,
To withdraw your consent at any time (this will not affect the lawfulness of previous data-processing activities) or object to any use of your personal data.
To opt out of the use or disclosure of your personal data for purposes of targeted advertising.
To limit certain uses and disclosures of your sensitive personal data

To exercise your right to limit the use and disclosure of your sensitive personal data, you can click on the “Your Privacy Choices” link here or at the footer of some of our sites. Note that after you exercise this right, we may still continue to use your sensitive personal data for certain purposes, such as to provide you with services or goods that you have requested.

To exercise your right to opt out of the sharing of your personal data for targeted advertising, you can click the “Your Privacy Choices” link here or at the footer of some of our sites. You can also click on the “Cookie Settings” link at the footer of our sites to opt out of advertising and analytics cookies, as described further in Section IV above on “Advertising, cookies, and similar technologies.”

We also support the Global Privacy Control, which is a browser-based opt-out preference signal that communicates your privacy preferences to the websites you visit. For more information on the Global Privacy Control, please visit their website here. Note that because the Global Privacy Control is a browser-based mechanism, your opt-out preference will apply only to the browser from which you exercised that choice and only if that browser supports the Global Privacy Control. You are welcome, however, to enable the Global Privacy Control on all of your browsers and devices. Further, the Global Privacy Control will only opt you out of the disclosure of your cookie-based personal information. To opt-out of the disclosure of your non-cookie based personal information, you can click the “Your Privacy Choices” link or at the footer of some of our sites.

Note further that, as distinct from the Global Privacy Control, some web browsers may transmit “do-not-track” signals to web services with which your browser communicates. As of the effective date of this Privacy Notice, an industry standard has not yet been established on how to respond to these signals; therefore, Proactive Longevity does not currently respond to these signals. However, you can opt-out from advertisers that use your browsing history to deliver online behavioral advertisements via the mechanisms listed above.

To exercise your other privacy rights, such as to delete, access, or correct your personal data, you or your authorized representative can submit a request here. After you make your request, we will use the information we have to verify your identity (and if applicable, your authorized agent’s identity), and to match the personal data we have collected about you, if any, to your verified identity. Our verification process may include a request for additional information to confirm your identity or your authorized agent’s identity, or to obtain proof that you have given your authorized agent permission to act on your behalf. If our verification process is successful, we will respond to your request within the time and in the manner required by applicable law. If we cannot validate the identity of you and/or your authorized agent or obtain proof that you have given your authorized agent permission to act on your behalf, we will attempt to contact you to inform you.

If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. You may be entitled, however, to appeal our decisions and can do so by following the instructions provided in the correspondence we send to you communicating our decision. Under local law, you may also be entitled to lodge a complaint with your local data-protection authority.

Should you exercise any of your privacy rights, Proactive Longevity will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. However, certain Proactive Longevity Relationships may require your consent to have your personal data shared with Proactive Longevity to provide the service or to allow us to use and disclose your personal data to provide the Proactive Longevity Relationships. When you exercise your deletion right, you may lose access to certain aspects of Proactive Longevity Relationships that require your personal data to perform the service.

For California residents, click here to see the California consumer requests metrics for the previous calendar year.

Additional information for job applicants

If you have applied for employment with Proactive Longevity, the personal data submitted with your job application may include your resume; previous professional, education and other background information; driver’s license information; social security number or equivalent national identification (as required or permitted by local law); cover letter; licenses; permits and certifications held; reference information; and any other information that you choose to provide (e.g., employment preferences, willingness to relocate, awards or professional memberships). This information may come from you, a recruiter, your references, prior employers, or your educational institutions.

Consistent with applicable law, we may ask questions about race/ethnic origin, gender, veteran status, and disability status of our applicants, for the monitoring of equal employment opportunity compliance. Except as specifically requested or legally required, we ask that you avoid submitting information in your application that may qualify as sensitive information under applicable law. Sensitive information includes data about race, color, religion, ethnicity, nationality or national origin, age, gender identity or expression, sexual orientation, marital status, medical or health information (including physical or mental disabilities or pregnancy status), genetic or biometric information, political or philosophical beliefs, political party or trade union membership, veteran status, photographs, background check information, judicial data such as criminal records or information on other judicial or administrative proceedings, or any other legally protected status.

Personal data will be processed based on our legitimate interest in processing your job application and evaluating your candidacy and qualifications and to conduct reference checks. We may also inquire about criminal records and perform a background check following a conditional offer of employment, where permitted by applicable law. We may also process personal data from your job application for regulatory, compliance and legal purposes, consistent with this Privacy Notice. personal data may also be used for additional administrative purposes, including aggregate management reporting, internal training, and as generally required to operate our business.

We may share the data on your applications with recruiters, consultants, attorneys, preemployment background check services, and our affiliates.

Additional information for health care professionals

We may collect additional categories of personal data through your online and offline interactions with us, in addition to the categories described in the ”Your personal data we may collect” section above if you are a health care professional, as described in this section. We also use and disclose personal data about health care professionals for the additional purposes described in this section. We retain your personal data as described in the “Data Security and retention” section below. To understand how we may use and disclose your personal data for targeted advertising and to opt out, see the “Your Privacy Rights” section above. The categories of personal data collected and the purposes of use and disclosure described in this section are in addition any other collection, use and disclosure of personal data practices described separately in this Privacy Notice.

Additional personal data that Proactive Longevity may collect about health care professionals

If you are health care professional, we may collect personal data about you directly from you, or from third-party sources such as the organization where you work, publicly available sources, interactions with Proactive Longevity (including online available sources), and participation in Proactive Longevity-sponsored or -supported initiatives such as Proactive Longevity-sponsored clinical research and development activities, third-party databases, and reporters of pharmacovigilance events.

We may collect the following additional categories of personal data about health care professionals:

Professional details, such as resumes or other documents or forms provided directly to us, place of practice, job title, professional contact details, medical specialty, professional license number, professional qualifications and scientific activities (such as previous clinical trial experience, activity on social media platforms or other websites, and participation in past or pending research studies with us and other companies), organizational or institutional affiliations, publication of academic or scientific research and articles, and membership in associations and boards
Personal data provided to participate in our sponsored or -supported initiatives, such as our sponsored clinical research and development activities, online or in-person seminars regarding product information, educational events, and clinical information updates
Details of interactions with us, such as what kind of meetings we have held, topics discussed, your knowledge of and questions you have had about our business and products, what kind of material we have displayed to you, and any feedback that you have provided, as well as your opinions of and routines for prescribing, routines regarding your patients, diagnoses, and automatic tracking information in online interactions with us
Payment and other transfers of value details received from your interactions with Proactive Longevity, which may include your tax identification number or national identification number (where required or permitted by law), contributions to costs of educational events (such as registrations fees, travel and accommodation expenses) and fees for services, including consultancy services

Additional uses and disclosures of health care professional personal data

We use and disclose personal data of health care professionals for the following additional purposes.

For the performance of our contract with you if you or your institution entered into a consulting, professional services, or other type of agreement with us.
Based on our legitimate interests in developing and improving our services, we will use and disclose personal data about health care professionals for:

managing and improving our relationship with you, including planning, organizing and reviewing any collaboration with you, and for contacting you
helping ensure that we provide you with information that is relevant based on your expertise, interests and preferences
recruitment and evaluation of the suitability of health professionals for their participation in clinical trials and market research and other research studies
conducting market and research studies in the public and private sectors
communicating with you about our products and programs (subject to any additional marketing consent requirements), engage with you about scientific or educational programs, administer our patient-support programs and provide access to you where applicable, respond to product orders, and provide product samples
research and analytics purposes to develop and evaluate our products, services, materials and treatment
internal accounting and analysis in connection with our internal policies and rules, such as our Proactive Longevity Code of Business Conduct

Based on our legal obligations and for reasons of public interest, we will use and disclose personal data about health care professionals for:

safety monitoring, reporting and auditing and responding to inquiries or issues in relation to our products
complying with applicable laws and regulations, including requirements imposed by industry codes of conduct to collect payment and other transfer of value data of health care professionals and the public disclosure of such data, subject to applicable local consent requirements to publish such data in a manner that identifies the health care professional individually

Additional information for participants in patient and customer programs

We may collect additional categories of personal data through your online and offline interactions with us, in addition to the categories described in the “Your personal data we may collect” section above, about participants in Proactive Longevity’s patient and customer programs, as described in this section, including patient support programs and loyalty programs . We may also use and disclose personal data about participants in patient and customer programs for the additional purposes described in this section. We retain your personal data as described in the “Data Security and retention” section below. To understand how we may use and disclose your personal data for targeted advertising and to opt out, see the “Your Privacy Rights” section above. The categories of personal data collected and the purposes of use and disclosure described in this section are in addition any other collection, use and disclosure of personal data practices described separately in this Privacy Notice.

Additional personal data that Proactive Longevity collects for Patient and Customer Programs

If you are a participant in a patient or customer program, we may process the following additional categories of personal data about you, which we received from you directly, or from your health care professionals, health care insurers, and related third parties:

contact data such as address, phone number and other contact details
personal details such as name, date of birth and gender
data collected or created regarding your use of our programs and services
financial information related to qualification in certain income-based and financial support programs, including your social security number or national identification number (where permitted or required by law)
sensitive data such as identifiable health data relating to your disease or condition, medical history, treatments you may have received, reason for discontinuation, data on active management of the disease and insurance coverage and benefits related to your use of our products

Additional uses of data in the context of patient and customer programs

With your consent, we use and disclose your personal data as part of your program participation to administer and manage the program, including customization of the program to you, delivery of products and services, administering loyalty programs, reminding you to take your product as prescribed or to obtain a refill of your product, and to provide you with program support, communications, and materials relating to your treatment and the program. We may also contact your health care professional for drug safety information and to provide health care professional with information about your medicine and your participation in a program.

Based on our legal obligations and for reasons of public interest, we may use and disclose your personal data in our programs for safety monitoring, reporting and auditing, and responding to inquiries or issues in relation to our products, as well as to comply with applicable laws and regulations.

We will also use personal data that does not directly identify you for the compatible purposes of analytics, research and related publications, including to evaluate, develop and improve Proactive Longevity’s programs and related services, products and medicines.

Consumer health data privacy notice

In the event that personal data we process are “consumer health data” under Washington State’s “My Health My Data Act,” this section explains how we collect, use, and share such information. The categories of consumer health data collected and the purposes of use and disclosure described in this section are in addition to any other collection, use, and disclosure of personal data described separately in this Privacy Notice.

The categories of consumer health data we collect from you or other sources

Proactive Longevity may collect consumer health data from you directly that you choose to provide us, for example as part of a registration in a patient support program. Proactive Longevity may also obtain consumer health data indirectly, such as from health care providers and health insurance companies, and third-party partners and collaborators. We may combine consumer health data from multiple online and offline sources. In addition, Proactive Longevity may collect your personal data automatically through cookies and similar tracking and data collection technologies.

From these sources, we may collect the following categories of consumer health data:

Information about your individual physical or mental health conditions, treatment, procedures, diseases, or diagnoses, use or purchase of prescribed medications;
Health, genetic, or biometric data relating to your participation in our health-related programs, services, and offerings;
Precise location data, if you request geotargeted related health care services from us, and only if such geotargeting services are permitted by law;
Inferences about you based your personal data or other data, such as through your online activity through cookies and similar data collection technologies; and
Other personal data that identifies your past or present health status.

The purposes for which we use consumer health data

Proactive Longevity may use your consumer health data for business and commercial purposes as reasonably necessary to provide and maintain the products and services you request from us. This includes to administer and customize the programs and services we provide to you, as well as for business product and improvement.

We may use your consumer health data with your consent, such as for marketing purposes, and as otherwise permitted or required by law.

We may also aggregate and/or deidentify your consumer data and use it for our legitimate business purposes, including product and service development, improvement activities and for research and analytics. To the extent we deidentify any data originally based on your consumer health data, we will maintain and use such data only in de-identified fashion and will not attempt to reidentify the data.

How we may share consumer health data

Proactive Longevity may share your consumer health data described above as reasonably necessary to provide and maintain the products and services you request from us, including with our affiliates, service providers, vendors, financial institutions and payment processors, government agencies such as FDA, business and research partners or in connection with a sale, merger, or other business transfer. We may also share your consumer health data with your consent and as otherwise permitted or required by law.

Your rights

may be entitled, in accordance with applicable law, to submit a request to know, access, or delete the consumer health data we have collected about you or withdraw consent to our use of consumer health data. Please visit “Your Privacy Choices” here or at the footer of some of our sites to exercise these rights. You can also click the “Cookie Settings” link at the footer of our sites to control your cookie preferences. You may appeal any decision we have made about your request by following the instructions provided in the correspondence we send to you communicating our decision.

Loyalty programs

Some of our programs may offer discounts or other value to consumers that voluntarily participate and that involves the collection and sharing of consumer personal data as described in the “Your personal data we may collect” and “How we may disclose personal data” sections of this Privacy Notice. Based on our reasonable and good faith estimate, personal data we collect through such programs do not have monetary value. We receive value from such programs in increased customer loyalty and patronage. Because some of our programs involve tracking product usage and purchases, it is necessary to collect and process your health-related data from you as part of your participation. Participation in our programs is voluntary and you may withdraw by visiting Your Privacy Choices here. If you make a data subjects rights request by visiting Your Privacy Choices requesting the deletion of your personal data necessary for your participation in a program, then you may not be able to continue your participation.

Privacy of children

Proactive Longevity does not knowingly collect any personal data directly from anyone under the age of 16. All Proactive Longevity Relationships that support children are directed to and are communicated with parents and guardians only. If you are a parent or guardian and become aware that your child has provided us with personal data, please contact us using one of the methods in the Your privacy rights and choices section, and we will work with you to address this issue.

Our contact information

You may contact us or our Global Privacy Office, including our Data Protection Officer, at any time, using the contact information below if you have questions about this Privacy Notice or have any other privacy request or inquiry. You can also opt-out or unsubscribe from any of our programs or services.

Please submit your privacy requests or inquiries here. You can also contact us by visiting“Your Privacy Choices”, by using the contact information feature on our mobile application, by emailing us at privacyoffice@Proactive Longevity.com, or by calling us toll-free at 1-800-255-5162. Alternatively, you may send a letter to the following address:

Proactive Longevity Customer Service
Attn: Privacy
1 N. Waukegan Road
North Chicago, IL 60064-6163

In all communications to us, please include the email address used for registration (if applicable), the website address, mobile application, or the specific program to which you provided personal data (e.g., Proactive Longevity.com), and a detailed explanation of your request. We will respond to all reasonable requests in a timely manner, and we may need to further confirm your identity in order to process certain requests.

Data security and retention

Proactive Longevity maintains appropriate technical, administrative, and physical controls to reasonably safeguard any personal data collected through Proactive Longevity Relationships. However, there is always some risk that an unauthorized third party could intercept an Internet transmission, or that someone will find a way to thwart our security systems. We urge you to exercise caution when transmitting personal data over the Internet, especially your health-related information. We cannot guarantee that unauthorized third parties will not gain access to personal data about you; therefore, when submitting personal data to us, you must weigh both the benefits and the risks.

We will only keep personal data as long as necessary for the fulfillment of the purposes outlined in this Privacy Notice, except if otherwise required by applicable laws or legal orders. The criteria used to determine our retention periods include (i) the length of time we have an ongoing Proactive Longevity Relationship with you; (ii) whether there is a legal or best practice retention obligation to which we are subject; and (iii) whether retention is needed in light of litigation or regulatory investigations.

International personal data transfers

We may transfer personal data internationally as described in this section.

Intercompany transfers

Personal data may be transferred and processed by and among Proactive Longevity Inc. in the U.S., the parent company of Proactive Longevity, and its affiliates in other countries. For a full list of Proactive Longevity Inc.’s affiliates and their jurisdictions, please see our most recent SEC filing here. Our company maintains an inter-company data transfer agreement, which is based on EU data transfer agreement requirements as well as regional requirements where EU standards are not sufficient, and covers personal data transfers among Proactive Longevity Inc. and its affiliates worldwide to ensure the adequate protection of personal data. Copies of these agreements can be obtained by sending an email to privacyoffice@Proactive Longevity.com.

Transfers to vendors, suppliers, and business partners

Personal data may also be transferred and processed by our vendors, suppliers, and business partners in other countries. Any international transfer of personal data to third parties, including outside the EEA and other countries with cross border transfer restrictions, will be conducted in compliance with the international data-transfer restrictions and requirements that apply under data protection laws, including, where appropriate, using appropriate data transfer agreements for personal data transfers to data processors or data controllers.

Accessing our sites globally

This site is owned and operated by Proactive Longevity in the United States. If you are visiting this site from a country other than the United States, your communication with us will result in the transfer of personal data across international borders. We will only process your personal data with your consent, to perform a contract between you and us, to comply with legal obligations, or where we have a legitimate interest. These legitimate interests include administrative activities and complying with your requests.

Changes to our Privacy Notice

We will use personal data only in the manner described in the Privacy Notice in effect when the personal data was collected. However, and subject to any applicable consent requirements, we reserve the right to change the terms of this Privacy Notice at any time. Changes to this Privacy Notice will be promptly posted to this page and accompanied by a new effective date at the top of this page. We encourage you to review this Privacy Notice regularly for any changes. Any personal data collected upon your continued use of Proactive Longevity Relationships will be handled in accordance with the currently posted Privacy Notice.

Consumer Health Data Privacy Notice

Consumer Health Data Privacy Notice

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