Applicability & Acceptance of this Privacy Policy

This Privacy Policy (this “Privacy Policy” or this “Policy”) governs the manner in which Claya Inc. (“Rootine,” “we”, “our,” “us” and similar terms) collects, uses, maintains and discloses information collected from users (a “User”, as well as “you”, “your” and similar terms) to create and deliver personalized daily vitamins (“Personalized Vitamins”) to Users through the Rootine websites (the “Services”). This Privacy Policy applies to the Services only, and not to any other applications, websites, or to any other products or services offered by us.

This Policy forms part of and is incorporated into our Terms of Service, published at www.rootinevitamins.com/pages/terms-of-service the “Terms of Service”). By using the Services, you signify your acceptance of this Privacy Policy and the Terms of Service. If you do not agree to this Privacy Policy, please do not use the Services.

Changes to this Privacy Policy

We may, in our sole discretion, revise this Privacy Policy at any time and from time to time. Your continued use of the Services following the posting of revisions to this Privacy Policy will be deemed your acceptance of such revisions. We encourage Users frequently to check the email account that they use in connection with the Services, as well as this Privacy Policy, to stay informed about any changes to this Privacy Policy. You acknowledge and agree that it is your responsibility to review that email account and this Privacy Policy periodically. The date at the bottom of this Privacy Policy will be updated for each revision.

Information that We Collect

We may collect all or any of the following information in the course of providing the Services (collectively, “User Information”):

“Personal Information” is information you provide to us when registering for or using the Services, such as your name, billing and shipping addresses, email address, phone number, date of birth, height, weight, diet information, user ID and password, and payment information.

“Genetic Information” is all of the genetic information that can be derived from (i) the sample of your DNA contained in the cheek swab or the blood sample that you provide us for analysis in connection with the Services (the “Sample”), (ii) raw data or other results from genetic tests you have previously used (“Test Results”) or (iii) blood data from a recent blood test (“Blood Data”), in each case, provided by you as part of using the Services.

“Usage Information” is information such as the browser name, the type of computer or phone a User is using, technical information about a User’s means of connecting to the Rootine website, such as the operating system and the Internet or mobile service providers utilized, and other similar information.


How We Collect Information

We collect Genetic Information when you provide us with a Sample using a check swab or blood test kit, or when you send us your Test Results or Blood Data.

We collect Personal Information and Usage Information in a variety of ways, including but not limited to when Users visit or register with the Rootine website, fill out our questionnaire or a survey or other form, subscribe to a newsletter, mailing list or other communication tool, contact us via email, and in connection with other activities, services, features or resources we make available through the Services from time to time.

The Rootine website may use “cookies” to enhance User experience. A User’s web browser places cookies on a hard drive for record-keeping purposes and sometimes to track information. Users may choose to set their web browser to refuse cookies, or to alert the User when cookies are being sent. If a User does so, some parts of the Rootine website may not function properly.

How We Use the Information that We Collect

Personal Information. We use Personal Information for the purposes of providing the Services, including to create and deliver your Personalized Vitamins. We also use Personal Information for communications relating to the Services and for processing transactions related to the Services. We will not sell or use your Personal Information for any other reason without your consent.

If you make purchases on or through the Services, we may use any Personal Information you provide to fulfill your order and for one-time and recurring billing purposes according to the terms pertaining to such order. If we (or our payment processor) have trouble processing an order, such information may be used to contact you. Payment card information is sent in encrypted format and is used only to send to our payment card processor, for the purposes of collecting payment for products or services ordered. We never make this information visible to anyone other than our payment card processor and never communicate it over a non-encrypted connection. The full payment card number is never seen by anyone inside our company, once entered and submitted, except by the payment card processor for the purposes of authorizing, clearing and reversing charges to your payment card.

Genetic Information. We use Genetic Information for the purposes of providing the Services, including to create and deliver your Personalized Vitamins. Our Users are the sole owners of their Genetic Information, and have the sole right to determine how that information is used. We will not use your Genetic Information for any purpose other than to provide the Services, without your prior consent. By default, your Genetic Information will be kept private until such time, if any, as you consent to use of it in any manner, or you choose to share your information with others.

Usage Information. We use your Usage Information for a variety of purposes, such as to understand how our Users as a group use the Services, to improve the Services, to personalize the User experience, and to process transactions.

How We Disclose Information that We Collect

Rootine complies with this Policy and with applicable state and federal law regarding the privacy of health information in disclosing User Information that we collect.

We disclose the contents of a User’s Personalized Vitamins and a User’s Genetic Information and Personal Information only (1) to the User to whom the information relates, (2) to another individual with the express written consent of such User, or (3) as required by law.

We disclose User Information to third party service providers, including laboratory partners utilized by Rootine to create Personalized Vitamins. We require such third party service providers to handle User Information in a manner consistent with this Policy and with applicable federal and state law regarding the privacy of health information, and to maintain the confidentiality of all User Information. We provide only the User Information necessary for a third party service provider to deliver a service.

We may disclose User Information to our affiliates and to businesses that are legally part of the same group as Rootine, or that become part of that group, subject to appropriate protections to protect the confidentiality of all User Information.

We may be required by a valid order of a court or other governmental body to disclose User Information. No such disclosure shall be considered a breach of this Policy, nor shall Rootine be considered to be under an obligation to contest a valid order of a court or other governmental body to disclose User Information.

We may make disclosures of User Information in compliance with federal and state law to enforce the terms of this Policy or if we believe such disclosure is necessary or appropriate to protect the rights, property, or safety of Rootine, our Users, or others.

How We Protect Information that We Collect

We use commercially reasonable methods to protect all User Information. With respect to User Information such as Personal Information and Genetic Information that is subject to federal and state laws concerning the privacy of health information, Rootine employs physical, technical, and administrative safeguards as required by such federal and state laws. Genetic Information is stored separately from information that could be used to identify such Genetic Information. Access to such information is restricted to trained staff on a need-to-access basis.

Rootine is based in and operates in the United States. The laws of the United States apply to User Information stored by Rootine. If you choose to access the Services, you consent to the use and disclosure of information in accordance with this Policy and subject to such laws.

Information of Minor Children

The Services are not directed to Users under the age of 18. The Services do not knowingly collect personal information from children under the age of 13. If you are under 18, you are not permitted to use the Service or to send personal information to Rootine.

Retention of Genetic Information; Termination of User Account

In order to provide the Services (including to deliver Personalized Vitamins to you), we extract Genetic Information from Samples, Test Results and Blood Data you provide. We destroy all Samples after analyzing them and extracting Genetic Information from them, provided that we may retain your Genetic Information should you desire to purchase additional Personalized Vitamins or other Services at any time.

If you no longer wish to receive the Services, you may terminate your account by sending a request to hello@rootinevitamins.com. Subject to state and federal laws regarding the retention of records, we will remove all of your Genetic Information and Personal Information within 30 days of our receipt of your request.

Notwithstanding the foregoing, you understand and agree that we are entitled to retain User Information and Samples as may be required by law or legal process, to resolve disputes, to enforce our agreements (including this Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.

Transfer of User Information in the Event of Acquisition

Your agreement to this Privacy Policy includes your consent to the transfer of your User Information to any entity that may acquire Rootine or its assets, either directly or indirectly, and to any affiliate of Rootine.

Links

The Services may contain links to other websites. We are not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave the Services and review the privacy statements of each third-party website. This Policy applies solely to information collected by the Services. We encourage our Users to read the privacy policies of these other websites before proceeding to use them.

Third Party Beneficiaries

This Privacy Policy is between us and you, and does not grant any rights to third parties.

Governing Law; Dispute Resolution

This Privacy Policy will be governed by and construed in accordance with the laws of the State of New York, USA, without regarding to conflicts of law principles. All disputes arising out of or related to this Policy shall be resolved by arbitration administered by the American Arbitration Association (“AAA”) under the Federal Arbitration Act, exclusively in Nashville, Tennessee.

Contacting Us

If you have any questions about this Policy or the Services, please contact us at:

Claya Inc. (dba Rootine)
1212 Laurel Street, Unit 608
Nashville, TN 37203
hello@rootinevitamins.com


Last Updated: March 1, 2019