Privacy Policy

This Privacy Policy explains how Lilac Health, Inc. (“Company,” “Lilac Health,” “we,” “us,” and “our”) collects, stores, uses, transfers and shares personal data from our platform users (“you” or “User(s)”). This Privacy Policy also describes which choices you have with regards to the information we collect, including ways in which you can update, manage, or request to delete it. Any of the policies contained herein are incorporated into our Terms of Use (located here), which also apply throughout.

Below are additional key terms and their definitions as used throughout this document:

• “Personal Data:” Any information relating to an identified or identifiable individual and any information listed here.
• “App(s):” Our website joinlilac.com, domain sub pages, and Lilac Health mobile applications.
• “Products:” Any supplements, tests, accessories, or other products available to purchase through our Apps.
• “Services:” Any services provided through our Apps.
• “Platform:” Collectively, the Company’s business offerings, support systems, Apps, Products, Services, and Features.
• “Account:” a digital account for the Platform that requires a User to provide certain personal information, which may include a given name and e-mail address.

READ THIS PRIVACY POLICY CAREFULLY AS IT GOVERNS YOUR ACCESS TO AND USE OF OUR PLATFORM. BY USING THE PLATFORM IN ANY MANNER, YOU AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF USE. IF YOU DO NOT AGREE TO THESE POLICIES, YOU MAY NOT ACCESS OR USE THE PLATFORM.

WE MAY MODIFY THIS PRIVACY POLICY FROM TIME TO TIME. WHEN WE DO, WE WILL NOTIFY YOU VIA EMAIL OR THROUGH THE PLATFORM. YOUR CONTINUED USE OF THE PLATFORM AFTER THE EFFECTIVE DATE OF ANY UPDATED VERSION OF THE PRIVACY POLICY WILL INDICATE YOUR ACCEPTANCE OF THE PRIVACY POLICY AS MODIFIED.

THE COMPANY IS NOT A LICENSED HEALTHCARE OR MEDICAL PROVIDER, AND THE PLATFORM IS NOT INTENDED TO REPLACE PROFESSIONAL MEDICAL ADVICE MEANT TO DIAGNOSE, TREAT, OR MANAGE ANY ILLNESS, SYMPTOM, OR MEDICAL CONDITION. PLEASE CONSULT WITH A LICENSED PRACTITIONER, PHYSICIAN, OR QUALIFIED HEALTHCARE PROVIDER BEFORE TAKING ANY ACTION OR MAKING ANY DECISION THAT MAY AFFECT YOUR HEALTH.

OUR PLATFORM IS NOT INTENDED TO BE USED FOR MEDICAL EMERGENCIES OR URGENT SITUATIONS. IF YOU BELIEVE YOU HAVE A MEDICAL EMERGENCY, PLEASE SEEK IMMEDIATE EMERGENCY MEDICAL CARE. YOU SHOULD NOT DISREGARD OR DELAY SEEKING MEDICAL ADVICE BASED ON ANY INFORMATION THAT APPEARS OR DOES NOT APPEAR ON OUR PLATFORM. IF YOU HAVE ANY QUESTION OR CONCERN ABOUT YOUR HEALTH OR IF YOU HAPPEN TO EXPERIENCE ANY CHANGES IN YOUR OVERALL HEALTH, CONSULT WITH A HEALTHCARE PROFESSIONAL.

In order to access the Platform, you represent and warrant that you are 18 years old or older. If you are under the age of 18, please do not attempt to register with us on the Platform or provide any personal information about yourself to us. If we learn that we have collected personal information from someone under the age of 18, we have full authority to delete that information. If you believe we have collected personal information from someone under the age of 18, please contact us.

When you use the Platform, you may provide us with Personal Data such as:

(a) identifiable data, such as a given name, email address, year of birth, account password, location zip-code, or preferred language (if available);

(b) health and well-being data, such as recent symptoms, medication and supplementation usage, past medical diagnoses, day-to-day experiences, physical details or metrics, mental and social well-being, or food and diet details; and

(c) third-party data, such as those you allow us to connect to that may provide us with Personal Data about your health and activities. When you allow us to have this data imported, you are subject to the privacy policies and practices of the third-party services. It is your sole responsibility to familiarize yourself with the third-party services policies as it pertains to your personal data.

We collect personal Data directly from you in the Platform via surveys, daily check-ins, in-app chats, forms, checklists, questionnaires, text message, or emails. Given the personalized nature of the Platform, not all Users may be allowed or asked to provide the same Personal Data. Many parts of the Platform will require you to provide Personal Data in order to use or continue to use such parts.

When you make a purchase for Services, Products, or Features in the Platform, we do not store financial account information, but we may receive or use transaction identifiers and summary information that omits any financial details, such as credit card or bank details.

When you access or use the Services, we may automatically collect Personal Data, including, among others:

(a) device data, such as model, unique identifiers, operating system, accessibility features, mobile carrier, internet network information, storage data, IP address, or time zone;

(b) usage data, such as frequency of use, areas of the Apps, Features, and Services that you visit or use, or Features or Services conversion; and

(c) third-party Personal Data, such as supplementation to existing user information.

In order to automatically collect Personal Data and other information, we and our service providers may use session cookies, “persistent” cookies, tracking pixels, and other similar technologies to receive, temporarily store, permanently store, and process certain types of information whenever you interact with our Platform through a computer or mobile device.

Certain devices or software may allow you to block, refuse, or interfere with technologies that we use to process Personal Data by activating an appropriate setting (”Refusal Setting(s)”). We do not take any responsibility for the performance of a Refusal Setting while using our Platform or make any claim that the Refusal Setting’s will perform as intended or advertised when you use our Platform. If you choose any Refusal Setting, you may be unable to access or use certain parts of our Platform.

Depending on which part of the Platform you use, we may use, process, manipulate, aggregate, create, store, delete, or modify your Personal Data in order to:

(a) provide you with access to the Platform or its Products, Services, and Features;

(b) to fulfill any and all activities needed for the safe and proper use the Platform or its Products, Services, and Features;

(c) communicate with, notify, remind, contact, provide insights or reports, or respond to you with regards to the Platform and its related parts;

(d) provide, promote, suggest, or market various offerings within the Platform that may be relevant or personalized to you, such relevance or personalization being the Company’s sole discretion;

(e) abide by, respond to, or comply with any law enforcement or regulatory request and legal or contractual obligation; and

(f) fulfill the transfer of assets as part of a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets;

(g) maintain the security and integrity of the Platform or protect any User’s security, consistent with applicable laws;

(g) any other purpose not included herein that is covered under our Terms of Use or this Privacy Policy.

We will never sell or rent your Personal Data to anyone. With that said, we use third parties to run the Platform as detailed in the Terms of Use and this Privacy Policy. We may share, disclose, or transfer your Personal Data with the following third parties:

(a) service providers, data hosting and data storage providers, security and compliance providers, technology services, or other third-party providers we deem necessary for providing you with access to our Platform and fulfilling any and all activities needed for the safe and proper use of the Platform;

(b) your healthcare provider, your health practitioner, or your family, with your prior consent and designation;

(c) law enforcement agencies, regulatory agencies, or judicial institutions, as applicable by law or when under any obligations thereunder;

(d) a buyer or other successor in the event of a transfer of assets as part of a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets

(e) affiliates or vendors, in order to provide, promote, suggest, or market various offerings within the Platform;

(f) analytics, marketing, and data insight providers in order to help us improve the Platform;

When it comes to your Personal Data, you have the following rights:

(a) to request that your Personal Data be corrected if inaccurate;

(b) to request that the processing of the Personal Data be restricted in some cases;

(c) to request information about what Personal Data we process about you,

(d) to access all your Personal Data, and receive a copy of it, including in a structured and portable form;

(e) to ****opt out of receiving any form of communication (emails, popups, push notification) by contacting us, adjusting the settings on your device or, when applicable, choosing the opt-out feature for such communication type — with the understanding that important Platform communications that are necessary will remain;

(e) to deactivate your account so that your data may not be viewable by any device when being accessed via your Account (the Personal Data will still remain unmodified); and

(f) to delete your Account and erase your Personal Data, with the understanding that your data will be anonymized or otherwise de-identified when possible, and, for some of your Personal Data, we may have to keep it as necessary to comply with legal and compliance obligations, resolve disputes, and enforce our agreements.

You may contact us at support@joinlilac.com in order to exercise your privacy rights. We will address your request within 30 days after receipt, but it may take us longer in some cases. In the case that we feel a request is vague or incomplete, we may need to contact you to better understand the request. We may also refuse to comply with a request that is manifestly unfounded and with excessive (repetitive) requests.

We may require you to prove your identity in some cases or to send us the request from the same email as the one provided when registering.

We may aggregate, de-identify, or anonymize your Personal Data in a way that it cannot reasonably be used to identify you in any way (”Aggregate Data”). The Aggregate Data shall no longer be considered Personal Data. By definition, the Aggregate Data belongs solely to the Company and does not benefit from the rights and protections granted to Personal Data as described in this Privacy Policy.

We may use, modify, recompute, distribute, delete such data as we wish without any notice to Users. The Aggregate Data will be used gather insights on User behavior, App analytics, or Platform performance and may be shared with partners or research institutions for statistical purposes that may lead to internal analytics, published papers, or external reports. Sharing this data may contribute significantly to the advancement of digestive health, and, as such, serves a legitimate interest to all involved.

We implement technical and organizational measures designed to protect Personal Data from the risk of accidental, intentional, unlawful, or unauthorized access, destruction, transfer, alteration, disclosure, or use. For example, we have protocols in place to ensure that only employees in charge of data management can have access to your Personal Data and only for limited purposes required for the operation of the Platform.

The sending or receiving of information via the internet is never completely secure; while our goal is to use best practices and industry-standard security tools to protect your data, we do not guarantee the security of Personal Data transmitted from, to, on, or through our Platform and are not responsible for any successful circumvention of the Platform’s security measures or the security measures contained within the devices or software you may use to access the Platform.

The most important thing you can do as a User for the security of your account is to keep your Account information confidential. Whether we provided you with a password or you provided one on Account creation, it is your responsibility to keep your Account login details private from anyone or anywhere. If there is any form of security breach in our Platform, we may post a notice or notify you via the App or email. In such cases, we will take appropriate actions to remedy the breach, which may impact the Platform for you or other Users. If you have knowledge of a security incident within the Platform, please contact us to report it.