This Privacy Policy (“Privacy Policy”) describes how Inovo Biotech LLC, developer and owner of the proprietary products and services offered under the Autumn DNA family of brands (“Autumn DNA,” “we”, “us” or “our”) collects, uses and shares your information when you visit our Website or purchase our Products & Services.
This Privacy Policy applies to www.tryautumn.com and any sub domains thereof, affiliated websites, and mobile applications, and any content, features and functions made available through the Website (collectively, the “Website”). We refer to the product and services offered through the Website as “Products & Services.” We use the words “you” and “your” to mean you, the reader, and other visitors to our Website and purchasers of Product & Services who are, in all cases, over the age of 18. This age requirement is discussed in more detail later in this Privacy Policy.
By visiting the Website, you agree to the terms of this Privacy Policy, as they may be changed from time to time as described here. This Privacy Policy is incorporated into, and part of, the Terms and Conditions of Use and Sale which govern your use of this Website in general and purchase of Products & Services sold via the Website. As more fully described here, this Website is intended for users who are located in the United States of America. The Privacy Policy shall be interpreted under the laws of the United States. The English language version of this privacy statement is the controlling version regardless of any translation
This Privacy Policy is effective as of May 01, 2021.
You can use the links below to navigate to areas of this Privacy Policy that apply specifically to you, or which may otherwise be of interest:
Information about you is obtained when you visit the Website, or purchase our Products & Services. Please note that certain types of information are required in order to provide the Products & Services to you. If you do not provide such information, or if you ask that it be deleted, you may no longer be able to access or use all or part of the Website or receive our Products & Services.
Information is collected directly from you in a variety ways including:
The categories of general information collected directly from you:
Information collected directly from you to created tailored Products and Services:
Our goal is to tailor our Products & Services so they can help you meet some of your specific nutritional needs.
We attempt to accomplish this in two ways. First, we require you to complete a questionnaire (the “Lifestyle Questionnaire”). By responding to the Lifestyle Questionnaire you will be allowing us to collect information about your lifestyle and certain of your health habits. This information may or may not be personal information under applicable law.
Second, we analyze a subset of your DNA and combine that analysis with your responses to the Lifestyle Questionnaire to create tailored Products.
As such, to purchase our Products, you will be required to either obtain a DNA sample kit from us in order to collect your saliva or, alternatively, you may upload results you have previously obtained from a third party DNA extraction and screening service (“Third Party Sample”).
By submitting your DNA sample, whether it’s a new sample using our kit or a Third Party Sample, you’ll be allowing us (and as described below) our third party laboratory partners, to collect and analyze genetic information that, when combined with other information, will become personal information under most applicable laws.
The Website employs a variety of technologies to assist in collecting information about your use and the devices you use to obtain access.
Visitor Data. When you visit our Website, we collect information that will help us understand and analyze your experience interacting with its features. For example, we may collect information related to domain names, the type of browsers used, operating system software, browser plug-ins, cookie preferences, search engine keywords, the pages you viewed and amount of time spent on particular pages, terms you use in you searches, and similar information.
Location Information. We and our service providers may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device when you use the Website. This information allows us to enable access to content that varies based on a user’s general location (e.g., to provide you with accurate sales tax information and to deliver content customized to your location).
Cookies. “Cookies” are a feature in your browser software. If enabled, we, or our service providers, may write cookies that may store small amounts of data on your computer about your visit to any of the pages of the Website. Cookies assist us in tracking which of our features appeal the most to you and what content you may have viewed on past visits. When you visit this Website again, cookies can enable us to customize our content according to your preferences.
We may use cookies to:
You can disable cookies, although the Website may not function properly for you. Your browser preferences can be modified to accept or reject all cookies, or request a notification when a cookie is set. In order to use all of the features and functionality of Autumn DNA’s Website, you need to accept at least certain cookies.
Tracking Technologies. We may use certain technologies such as web beacons, sometimes also called tracking pixels or clear GIFs. These technologies operate as tags that record your visit to the Website or your viewing of a particular e-mail we may send you using an email address you provided to us. In some cases, these technologies can be combined with cookies and server logs to be used to produce profiles of users’ behavior as they navigate through our Website and from our Website to other sites. We use them for marketing purposes to determine Products & Services you may be interested in.
Other Online Tools. Autumn DNA may also use a web server log or an SDK. A webserver log is a file where website activity is stored. An SDK is a set of tools and/or code that we embed in our software to allow third parties to collect information about how people interact with our Website.
As we continue to develop the Website and our Products & Services, Autumn DNA may implement additional methods to gather information about the Autumn DNA community.
Autumn DNA maintains a presence on a variety of social media platforms. When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media platforms, we may collect some information about you. This information includes your name, email address, any comments or content you post that is relevant to Autumn DNA. We also collect your information if you sign up for a promotion and submit information to us through one of our social media accounts.
Company also maintains several blogs. When you comment or post content to any of our blogs, we will collect your name and email address.
The following paragraphs describe how Autumn DNA uses your information in connection with our Websites and purchases of our Products & Services.
General Use. Autumn DNA will use your information as necessary to carry out and manage the Websites and deliver and improve on our Products & Services. This includes, using your information to verify and administer your account, including processing payments and fulfilling orders (if applicable). Providing you with insights into your wellness. We will use your information to communicate with you about our Product & Services, including personalizing such Product & Services for you. Autumn DNA also will use your information to ensure that content from our Website is presented in an effective manner for you and for your computer or device, allow you to participate in interactive features (when you choose to do so), and as part of our efforts to keep our Website safe and secure.
Improvement. Autumn DNA continuously seeks to improve its Websites and Products & Services. To do so, we conduct research to understand their effectiveness and appeal and to better understand our community of Website and Products & Services users. If we publish the results of our research to others, such research will be presented in a de-identified and aggregate form such that individual users cannot be identified.
Promotional Communications. We will use your personal information to communicate with you by email, postal mail, phone, or text message about surveys, promotions, special events or our Products & Services and those of our affiliates or third-party partners, and any of their related businesses. By creating an account and using this Website, you are giving your express permission to Autumn DNA and their agents or vendors the right to contact you with targeted advertising materials by email, text message (SMS), telephone or cellphone, including the use of automated, predictive, programmable, or similar (“robodialers”) dialers or dialing software, or any other means of communication to provide promotional offers. To the extent applicable, you expressly acknowledge that you are solely responsible for all charges billed by your mobile service provider. If you no longer wish to receive promotional communications by email, please follow the unsubscribe link located at the end of the email message.
Marketing/Performance. We may use your information to measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you.
Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Website and otherwise from your purchase of our Products & Services, with information that we receive from other sources, both online and offline, and use and share such combined information in accordance with this Privacy Policy.
Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected through the Website or as the result of your purchase of our Products & Services, so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any lawful purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.
Genetic Information. We do not make direct use of your DNA sample. Instead, as described below, when you submit a sample using our test kit, we instruct you to share it with one of our approved laboratory partners. That partner will then extract the relevant portion of your DNA from your sample, turn it into machine-readable data and send only that data back to us, which we will use to create tailored Products & Services for you. If you use a Third Party Sample, we will receive only the machine-readable data and our laboratory partner will not be involved.
We may use third-party web analytics services (such as those of Google Analytics (including Google Signals, Google User-ID, and other Google Analytics features) and MixPanel) on our Website to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; try to locate the same unique users across multiple browsers or devices to better tailor services and features; and provide certain features to you. If you have a Google account with personalized advertising enabled, through Google Signals, Google will also be able to gather for us analytics and engagement information from across the various devices you use to access the Websites. To prevent Google from using your information for analytics (including cross-device tracking for personalization purposes), you may install the Google Analytics Opt-out Browser Add-on by clicking here. And to opt out of Google Signals, please open your “Settings” app, locate and tap “Google,” select “Ads,” and turn ON “Opt out of Ads Personalization.” You may also be able to disable cross-device tracking through your Android or Apple device-based settings.
If you use a third party mail service (such as Google’s Gmail, Yahoo! Mail and the like) on your mobile device, you may have activated a setting that allows us to use certain technologies such as application programming interfaces, to automatically access (sometimes referred to as “parse”) your mail as it relates to your use of the Websites. If you did activate the setting allowing us to do so, our use of any information we receive from those technologies will adhere to their requirements of the publisher of the applicable technology. This includes, if we use Google APIs, adhering to the Google API Services User Data Policy and its Limited Use requirements.
The Websites may integrate third-party advertising technologies (e.g., ad networks and ad servers such as Facebook, Google Ad Words, Criteo and others) that use cookies and other technologies to deliver relevant content and advertising for products on the Websites, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services.
We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.
We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device by non-affiliated third-party advertising network services. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or the Your Online Choices link to opt-out of receiving tailored advertising from companies that participate in those programs. If you are interested in more information about Criteo’s privacy practices or opting-out of Criteo’s advertising services, you may view their Privacy Policy. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
Please note that if you exercise the opt-out choices above, you will still see advertising when you use the Websites, but it will not be tailored to you based on your online behavior over time.
When using mobile applications from us or others, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.
By submitting your email address through the Website, you are expressly consenting to receive emails from Autumn DNA, including from Autumn DNA’s affiliates, and from third parties concerning offers and advertisements unrelated to Autumn DNA. To opt-out of receiving email messages from us, from our affiliates or from other third parties, click on the “Unsubscribe” link contained in each email. Please allow up to 10 business days for us to process your request. Please note if you decide not to receive marketing emails from us, you may still receive transactional email messages regarding your order(s) (i.e., order confirmation, shipping information, etc.). If you have questions or concerns regarding this provision, please contact us at support@tryautumn.com.
The Website and email messages that you receive from Autumn DNA may sometimes contain hypertext links to the websites of third parties. Autumn DNA is not responsible for the privacy practices or the content of such other websites. Linked websites may contain links to websites maintained by third parties. Such links are provided for your convenience and reference only. Autumn DNA does not operate or control in any respect any information, software, products or services available on such third-party websites. The inclusion of a link to a website does not imply any endorsement of the services or the site, its contents, or its sponsoring organization.
Do Not Track is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated Do Not Track signals. To learn more about Do Not Track, you can do so here.
We have adopted, implemented and maintain an information security and privacy program that includes technical, organizational, administrative, and other security measures designed to protect, as required by applicable law, against reasonably anticipated or actual threats to the security of your personal information (the “Security Program”). Our Security Program was created with reference to recognized industry standards such as those published by the International Standards Organization and the National Institute of Standards and Technology. It includes, among many other things, procedures for assessing the need for and employing encryption and multi-factor authentication as appropriate, or using equivalent compensating controls. We therefore have every reason to believe our Security Program is reasonable and appropriate for our business and the nature of foreseeable risks to the personal information we collect. We further periodically review and update our Security Program, including as required by applicable law.
Despite the significant investment we’ve made in, and our commitment to, the Security Program including enforcement of third party oversight procedures, we cannot guarantee that your personal information, whether during transmission or while stored on our systems, otherwise in our care, or the care of our vendors and business partners, will be free from either failed or successful attempts at unauthorized access or that loss or accidental destruction will never occur. Except for our duty under applicable law to maintain the Security Program, we necessarily disclaim, to the maximum extent the law allows, any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information.
All that said, as part of our Security Program, we have specific incident response and management procedures that are activated whenever we become aware that your personal information was likely to have been compromised, including where our vendors and business partners are required under applicable law to notify us in the event of an incident adversely affecting personal information we provided to them has occurred. Those procedures include mechanisms to provide, when circumstances and/or our legal obligations warrant, notice to all affected data subjects within the timeframes required by law, as well as to give them such other mitigation and protection services (such as the credit monitoring and identity theft insurance) as may be required by applicable law.
Privacy and data protection laws vary around the world and among the individual United States. Our obligations arising under the majority of the world’s privacy laws, including U.S. federal and most state laws, are satisfied by individual risk assessments conducted by us to ensure we act reasonably and responsibly when processing your personal information. We refer to these as, “General Privacy Laws”. In some jurisdictions, however, privacy laws grant you, the data subject, certain specific rights regarding your personal information. We refer to these types of privacy laws as data subject rights-based laws or “DSR Privacy Laws.” Examples of DSR Privacy Laws include the European Union’s General Data Protection Regulation or “GDPR”, U.S. State of California’s Consumer Privacy Protection Act or “CCPA”, and the U.S. Commonwealth of Virginia’s Consumer Data Protection Act. Further still, the laws of some jurisdictions, such as Illinois’ Biometric Information Privacy Act. give you specific rights regarding your biometric information (“BIP Laws”).
The nature and locations of our business activities do not subject us to any DSR Privacy Laws or BIP Laws. Although we do not actively block or monitor visitors from jurisdictions having DSR Privacy Laws, we make no attempt to target our online and mobile resources at, or uniquely direct our sales and marketing activities toward data subjects located in those jurisdictions. Similarly, the screening and analysis activities we engage in using your DNA sample are excluded from the “biometric identifiers” regulated by all BIP Laws we are aware of. As such, this Privacy Policy is designed to comply only with General Privacy Laws in the United States.
We invite concerned data subjects and regulators to contact us using the contact information found in this Privacy Policy if they have questions about the analysis we conducted to conclude that DSR Privacy Laws or BIP Laws do not apply to us.
Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from children under the age of 13. We take those age-related requirements very seriously, and, consistent with them, do not intend for our Website or Products & Services to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to us via our Website, we will delete that information and not use it for any purpose whatsoever. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.
We reserve the right to change or update this Privacy Policy from time to time. Please check our Website periodically for such changes since all information collected is subject to the Privacy Policy in place at the time of collection. Typically, we will indicate the effective/amendment date at the beginning of this Privacy Policy. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new Privacy Policy.
If you have questions about this Privacy Policy or Autumn DNA’s privacy practices, please contact us at:
Autumn DNA
3960 West Point Loma Blvd, Suite H #5099
San Diego, California 92110
Tel: 1-866-728-8866
Email: support@tryautumn.com
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