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
·
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
·
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
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.
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.