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Ellume COVID-19 Home Test Privacy Policy

Ellume, Ltd. (“Ellume” “we,” “our,” and/or “us”) values the privacy of individuals who use our platform and related services specifically related to our COVID-19 Home Test Services (collectively, our “Services”). This privacy policy (the “COVID-19 Privacy Policy”) explains how we collect, use, and share information from users of our Services (“Users”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond this COVID-19 Privacy Policy, your use of our Services is also subject to our general Privacy Policy (www.ellumehealth.com/privacy-policy) and our Terms of Use (www.ellumecovidtest.com/terms).

1. Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us.

Registration Information. If you register to take the COVID-19 Home Test, we collect the information below listed in the “Public Health Authority Required Information.”

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you choose to receive a result report via email, an email containing your name, date and time of test, result and information about your result will be emailed to you. If you subscribe to our newsletter or email marketing communications, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Payment Information. If you make a payment through our Services, your payment-related information, such as credit card or other financial information, will be collected by our third-party payment processor on our behalf.

Public Health Authority Required Information. Due to the need to respond to the COVID-19 public health emergency, we are required to collect and share certain information about you with Public Health Authorities. We will collect and share the following information solely with public health authorities in compliance with applicable law:

  • Test result
  • Test result date
  • Residential Zip Code
  • State of Residence
  • Age
  • Date of birth

In addition to the data above, we may ask you to provide your:

  • Full Name
  • Phone Number
  • Email Address
  • Race
  • Ethnicity
  • This is you first test
  • The date and type of the most recent test (if not your first
  • You are employed in the health care field
  • You are symptomatic
  • You are a resident in a congregate care or living setting
  • You are pregnant

This information is only used to meet our legal reporting requirements and is only shared with the applicable public health authority based on the residential address you provide to us and the Federal Department of Health and Human Services (HHS).

B. Information We Collect When You Use Our Services.

Location Information. When you use our Services on your mobile device, we may receive your precise location information. However, we do not use your precise location to perform the Services or for any other reason. We do not share your precise location information. We also infer your general location information.

Device Information. We receive information about the device and software you use to access our Services, operating system version, phone carrier and manufacturer, application version and diagnostic device identifiers.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, and the dates and times of your visits.

2. How We Use the Information We Collect

If we are providing the Services on behalf of a third-party partner (such as your employer, health care provider or school) who has paid (in whole or in part) for you to use the Services, we will abide by the terms of our agreement with that third-party partner related to the use of the information we collect. Otherwise, we use the information we collect:

  • To provide, maintain, improve, and enhance our Services;
  • For public health reporting purposes, as described in this COVID-19 Privacy Policy;
  • To share information you direct us to share with another User of the Services, such as an event organizer or venue;
  • To personalize your experience on our Services;
  • To understand and analyze how you use our Services and develop new products, services, features, and functionality;
  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
  • To facilitate the connection of third-party services or applications for authentication purposes;
  • To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use for internal research, development and product improvement;
  • To find and prevent fraud, and respond to trust and safety issues that may arise;
  • For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
  • For other purposes for which we provide specific notice at the time the information is collected.
  • For required public health data reporting responsibilities.

3. How We Share the Information We Collect

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

Customer Partners. If we are providing the Services on behalf of a third-party partner (such as your employer, health care provider or school) who has paid (in whole or in part) for you to use the Services, you acknowledge and agree that your information, including your Covid test result, may be shared with the third-party customer or its designee.

As Directed by You. At your direction, we will share your information, such as your name and evidence of your Covid test result, with another designated User of the Services, such as an event organizer or venue.

Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes, unless we have your permission.

Analytics Partners. We use analytics services such as Google Analytics and Microsoft App Center Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/ and Microsoft’s practices by visiting https://privacy.microsoft.com/en-ca/privacystatement. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, and the dates and times of your visits.

As Required By Law and Similar Disclosures. We disclose information about you as described in Section 1 in compliance with the Centers of Disease Control and Prevention requirements and state law public health requirements. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

4. Your Choices

Location Information. There is currently no way to prevent certain devices from sharing precise location information. However, if your device shares precise location data, we will not store, share or otherwise use this precise location data.

Marketing Communications. If you subscribe to our promotional emails, you can unsubscribe via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

5. Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

6. Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

7. Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@ellumehealth.com.

8. International Visitors

Our Services are hosted in the United States and intended for Users located within the United States. If you choose to use Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

9. Update Your Information or Pose a Question

If you have questions about your privacy on Services or this privacy policy, please contact us at privacy@ellumehealth.com.

10. Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through Services, we will notify you through Services, by email, or other communication.

11. Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@ellumehealth.com or write to us at:

24766 2nd St, Hayward, California, USA 94541

Last Updated: May 17, 2021

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