Prevention Pods™ Privacy Policy.
Last Modified: August 25, 2020
What information do we Collect?
How do we use your information?
When do we share your information?
What choices do you have about how we use and share your information?
How do you access, correct or remove your information?
How do we keep your information secure?
Changes to our Privacy Policy
Questions or comments
We care about your privacy. Prevention Pods™ recognizes the importance of keeping your Personal Information secure and confidential. Privacy of your information matters, and in particular your Personal Information, as that term is defined below. This Privacy Policy describes the types of information we collect, and how we use, maintain, protect, and disclose this data. We are committed to protecting your information as disclosed in this Privacy Policy.
By using our Services, or transmitting information to us by email or other electronic means, you acknowledge and consent to the practices listed in this Privacy Policy. You can choose not to access our Services or transmit information to Prevention Pods™. Capitalized terms not defined in this Privacy Policy have the same meaning as in Prevention Pods™ Terms of Service.
What information do we collect?
We collect several types of information from and about users of our Services. When you contact us, create a Prevention Pods™ account, access or use our Services, make a purchase, or register to receive alerts or other information, we may collect Personal information that you provide to us. We may also collect information from you, our Product Partners, our Research Partners, or our service providers in connection with our website, products, Services, and research initiatives in ways that we describe at the time of collection or otherwise with your consent.
Account and personal demographic information and identifiers.
Account Information. You must provide certain information when you create an account or make a purchase on the Prevention Pods™ Platform in order to receive its Services (“Account Information”). This information, and information that may be collected during use of the Services after an account is created, includes:
identifiers such as your name, email address, username and password, address, and phone number and other information you provide to us during registration or use of the Services;
commercial information such as credit card or other payment information (we do not store credit card information and use a secure third party payment processor for credit card transactions);
demographic information (such as date of birth and gender) for identity verification of patient by Prevention Pods™ staff; and,
records and copies of any correspondence with you and details of any transactions you carry out through our Services.
Self-Reported Information. Prevention Pods™ or our Partners may ask you to provide data about yourself (your “Self-Reported Information”), including identifiers, demographic information, communication preferences, or self-declared ethnicity.
Information related to your use of the Services
Health Information. You may provide us with one or more swab samples, using FDA approved COVID-19 test kits, to allow us to isolate viral RNA and perform RT-PCR Analysis. In connection with our Services, you understand and agree that Prevention Pods™ Partners may perform Analysis on your sample to determine your COVID-19 infection status.
Computer, Device and Browsing Information. As you interact with our Services online (including the Site and Prevention Pods™ Platform), we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and usage patterns, which can include identifiers, internet or other electronic network activity information, or preferences. This data may include:
Details of your visits to our Services, which could include:
the resources that you access and use on the Services;
the external sites that referred you to our Services; and
the external sites that you visit by clicking on a link on Prevention Pods™.com.
Information about your computer or device and internet connection, which could include:
your IP address or other device ID;
your operating system; and
your browser or device type.
The information we collect helps us to improve our Services. It also helps us to deliver better and more personalized features to you by enabling us to recognize you when you return to our Services, by storing information about your preferences, and customizing our Services according to your individual interests.
Minors. Our Services are not intended for anyone under 18 years of age. By using our Site or Platform you represent that you are 18 years of age or older. We do not knowingly collect Personal Information from or on behalf of someone under 18. If you are under 18, do not register on our website or provide any information about yourself to us. If we learn we have collected or received Personal Information from or on behalf of someone under 18, we will make commercially reasonable efforts to remove the information and/or user account and not make future use of that information to contact a minor. We do not sell the Personal Information of minors. If you believe we might have any information from or about someone under 18, please contact us.
How do we use your information?
Prevention Pods™ will use information that we collect about you for the following purposes:
To present, provide, and improve our Services. We primarily use your identifiers, demographic, commercial, internet or other electronic network activity information and preferences to present and provide our Services to you. This includes the following:
providing you appropriate search results and personalized content;
processing your purchases;
verifying your identity;
recognizing you when you return to our Services;
providing you notices about your account;
notifying you about updates or changes to our Products Services or any Product Partner or other third party services we offer or provide through the Prevention Pods™ Platform; and
providing you with information or services that you otherwise request from us.
To improve our Services or to develop and provide new products and services, we may use your Self-Reported Information, identifiers, demographic information, commercial information, and internet or other electronic network activity information and preferences as follows:
to monitor your usage of our Services;
to administer a survey;
to perform quality control and quality improvement activities;
to conduct data analysis about users of our Services, our audience size, and usage trends;
to conduct marketing campaigns and targeted online advertising; and
to monitor the success of our marketing activities.
To improve our Services or to develop and provide new products and services, we may also use your biological sample and genetic information, stripped of direct identifiers, as follows:
to perform quality control and quality improvement activities;
to conduct aggregated data analysis about users of our Services; and
to improve and optimize our genomic sequencing, lab, processes, and Services.
With your consent to receive COVID-19 testing as part of the Services we provide to you, we do the following (as applicable to you):
collect and process nasal and oral swab(s) to isolate viral protein;
collect and process sample (blood draw or blood spot) for antibody testing;
store your Test Result;
store swab(s) and samples in a CLIA certified facility;
discard swab(s) and samples upon completion;
consistent with standard clinical laboratory practices, share your swab(s) or blood sample with a Product or Research Partner when necessary to enable the partner to validate the test finding (known as confirmatory testing) before returning any results that may impact your health.
In the following three subsections, we describe how we use your Biological Sample, and Self-Reported Information in particular:
Biological Samples. You allow Prevention Pods™ to isolate protein from any swab(s) and/or blood sample(s) you submit for COVID-19 testing. Any Biological Samples remaining after processing is complete will be discarded in accordance with applicable regulations.
Self-Reported Information. Your symptom status and body temperature will be used to ensure you can proceed with testing. We do not share your Self-Reported Information with any third party organizations.
Prevention Pods™ may use this information for quality, regulatory, and internal business purposes, such as to improve our products, data quality, and laboratory processes. We do not use personally identifiable information or personal health information in any way not permitted by applicable law.
Do we share your information?
Prevention Pods™ does not share your personal information or test results with anyone at any time. We share the testing result with the you directly using a HIPAA-secure SSO service. We may, however, share aggregated, anonymized information, including aggregate health statistics, with others, as permitted by or required by applicable law or regulation.
What choices do you have about how we use and share your information?
Promotional Offers from Prevention Pods™. You may opt out of receiving promotional offers at any time by clicking “unsubscribe” in any promotional offer email you receive.
We strive to provide you with choices about the information you provide to us. We have the following mechanisms to give you the following controls over your information:
Google Analytics. Google Analytics uses cookies to analyze how individuals use the Site. The information generated by a cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on individuals’ activity on the Site, and providing other services relating to Site activity. You can learn more about Google Analytics’ privacy choices or opt-out at any time (https://tools.google.com/dlpage/gaoptout).
Sharing Information with Partners. With your consent, we will provide your Biological Sample to a CLIA certified lab for processing and result delivery. When you order a COVID infection test from us as part of our Services, you are consenting for us to share your Biological Sample and other information with a relevant CLIA certified lab for processing. The information shared with the lab will be coded to de-identify any Personal Information. You may choose to stop sharing your information or close your Prevention Pods™ account at any time.
Sharing Health Information with Others. Prevention Pods™ does not share your information with anyone else, even if the patient wishes to provide consent. We deliver the results to the patient through a secure portal. However, you may also choose to share your Test Results with others yourself. You should be careful about doing so.
How do you access, correct or remove your information?
In General. You may contact Customer Success to request access to, correct, or remove any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Information that has already been de-identified and/or aggregated (including Aggregated Genetic Information) may not be retrievable or traced back for correction or removal from any database.
Account Closure. You may also close your Prevention Pods™ Account through your account settings. If you close your Prevention Pods™ Account, you will no longer have access through the Site or Services to your Test Results. After closure of your account, you will not be able to purchase any products or services from Prevention Pods™ without creating a new account.
After you close your Prevention Pods™ Account, we retain some Account Information in your account related to your purchase history. This enables us to provide you with ongoing support regarding your prior purchases, and is also necessary for accounting, audit, and compliance purposes. We may also retain limited backup copies and archival files of your information to satisfy our state and federal legal obligations or regulatory requirements, including those set by the Clinical Laboratory Improvement Amendments (CLIA).
Data Deletion. You may request that your data be deleted by contacting Customer Service. In general, we fulfill requests for removal of information within 30-45 days of receiving and verifying the request, as required by applicable law.
If you delete your Prevention Pods™ data, you will no longer have access through the Site or Services to your Test Results. After deletion of your data you will not be able to purchase any COVID-19 Products from the Prevention Pods™ without creating a new account
After you delete your data, we retain some Account Information related to your purchase history. This enables us to provide you with ongoing support regarding your prior purchases, and is also necessary for accounting, audit, and compliance purposes. We may also retain limited backup copies and archival files of your information to satisfy our state and federal legal obligations or regulatory requirements, including those set by the Clinical Laboratory Improvement Amendments (CLIA) and the College of American Pathologists (CAP) accreditation requirements.
How do we keep your information secure?
We limit access to your information to Prevention Pods™’s employees and contractors who we believe need access to it to provide Services to you or to do their jobs. In addition, we put in place industry standard physical, technical, and procedural safeguards designed to secure your Account Information, Self-Reported Information, Test Results any other Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. You can find additional information about our security practices on our Privacy & Policy Highlights page.
The transmission of information via the internet including by email cannot be guaranteed to be 100% secure. We continue to evaluate and identify improved security techniques to protect your Personal Information. However, we cannot guarantee that your information will not be accessed, altered, or lost through a breach of any of our physical and technical safeguards.
Information for California residents
If you are a California resident, the following section details your rights under the California Consumer Privacy Act of 2018 (“CCPA”) and how you may exercise them. In the event of a conflict between your rights, as described in this section, and any rights further described in this privacy policy, the terms of this section shall prevail.
California Consumer Rights. If you are a California resident, California law permits you to request information regarding the:
Categories of Personal Information (as defined by applicable California law) collected, sold or disclosed by us;
The business or commercial purpose(s) for which categories of Personal Information collected by us are used;
Sources of information from which we collect Personal Information; and
Specific pieces of Personal Information we have collected about you.
Additionally, if you are a California resident, you may:
Request that we disclose information about the Personal Information that we have collected about you in the 12 months preceding your request (including the categories of Personal Information collected, the source of that information, the business or commercial purpose of that collection, the categories of third parties with whom that information is shared, and the specific pieces of Personal Information collected about you);
Receive requested information in a readily-usable format if provided electronically;
Request that we delete any Personal Information about you that we have collected (although we may be entitled to retain some information for certain purposes such as to comply with other regulatory requirements); and
Opt-out of “sales” of Personal Information to third parties, if applicable.
Non-discrimination. Prevention Pods™ will not discriminate against you for exercising any of your privacy rights under the CCPA.
Requests. Requests related to your privacy rights under California law can be submitted using the following links:
Access My Personal Information
Delete My Personal Information
Do Not Sell My Personal Information
We cannot respond to your request to access or delete your Personal Information unless we are able to both verify your identity or authority to make the request and confirm the Personal Information relates to you and/or your household. If you have a Prevention Pods™ account, we will verify your identity by having you log in to your account. If you do not have an account, we will attempt to verify your request by asking you to provide identifying information that we will match to information in our files, such as your name, email or phone number. We will only use information you provide in your request for the purpose of verifying your identity or authority to make the request. You can also designate an authorized agent to make a request on your behalf. Your agent will need to provide a Power of Attorney authorizing the agent to act on your behalf, or will need to complete the same verification procedures that would be required for a request submitted by you directly, and provide information that allows us to verify your authorization. Please note in some circumstances we may not honor your request, as permitted under the law.
Categories and Sources of Personal Information. The categories of Personal Information Prevention Pods™ collected about consumers in the preceding 12 months and the categories of sources from which Personal Information is collected are described in the “What Information Do We Collect?” section of this policy.
Business Purpose for Collecting and Disclosing Personal Information. Prevention Pods™’s business purpose(s) for collecting and disclosing Personal Information are described in the “How Do We Use Your Information?” and the “When Do We Share Your Information?” sections of this policy.
Sale of Personal Information. In the past 12 months, we have not sold Personal Information to third parties. We do not sell or share the Personal Information we collect with unaffiliated third parties for their own marketing purposes.
Questions. If you have additional questions or requests related to your rights under the CCPA, please contact Prevention Pods™’s Privacy Department at privacy@preventionpods.com.
Changes to our Privacy Policy
We post any changes we make to our Privacy Policy on this page. If we make material changes to our Privacy Policy, we will take reasonable steps to notify you, such as sending an email to the email address specified in your account or posting a notice on our website. You are responsible for ensuring we have an up-to-date, active and deliverable email address for you. You are also responsible for visiting our Services and this Privacy Policy from time to time to check for any changes. All changes are effective immediately when we post them, and they apply to all access to and use of the Services from that point onward. If you use our Services after we make changes to our Privacy Policy, you acknowledge and agree to the current version of the Privacy Policy.
Questions or comments
To ask questions or comment about this Privacy Policy and our privacy practices, or request assistance accessing this Privacy Policy in an alternative format, you may contact Prevention Pods™ Customer Service or call 1-512-337-2913. Please do not include any protected health information or other sensitive information when you contact Customer Service. If you have questions or concerns about Prevention Pods™’s use or disclosure of protected health information specifically, please contact Prevention Pods™ Privacy Department at privacy@preventionpods.com. Note that inquiries sent through the Customer Service portal, or emails sent to privacy@preventionpods.com. (unless you have an email encryption service) are not encrypted or secure. You may choose to send your questions or concerns about Prevention Pods™’s use or disclosure of protected health information to the following address instead:
Prevention Pods™
Service of todreamalife, LLC
Attn: Privacy Department
29 Orinda Way #154
Orinda CA, 94563