Privacy Statement
Last Updated: October 1, 2024
My Trillions (“My Trillions”), values and is committed to protecting user privacy. This privacy statement applies to all the data collected by My Trillions through its websites, blood or saliva analysis, and mobile applications (collectively the “Services”).
By using the My Trillions websites, the My Trillions Services, or interacting with My Trillions, you are agreeing to this Privacy Notice. Please read the following carefully to understand how we collect, use, and maintain your personal information. In addition, it describes your choices for use, access, and correction of your personal information.
Contents
I. What data do we collect?
II. How do we use your information?
III. Will your information be shared with anyone?
IV. How do we keep your information safe?
V. Your access and choices
VI. Sample Collection and Data Usage
VII. How long do we keep your information?
VIII. What are your rights?
IX. Use by children/ minors
X. Changes to our privacy policy
XI. Enforcement of this privacy policy
XII. How to contact us
I. What information do we collect?
The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:
Registration Information: Personal information you voluntarily provide during account creation or during the ordering process such as user ID, password, name, date of birth, e-mail address, address, shipping address, postal code, phone number, gender, country/region, contact preferences, contact or authentication data, billing addresses, debit/credit card numbers, and other similar information.
Self-Reported Information: information you provide to My Trillions including your gender, disease conditions, health-related information, traits, ethnicity, family history, or anything else you provide to us within our Services.
RNA Information: information derived from our analysis of your RNA and blood or saliva sample. RNA Information includes My Trillions data and reports provided to you as part of our Services.
Sample Information: information regarding any sample, such as a blood or saliva sample, that you submit for processing to be analyzed to provide you with RNA Information, laboratory values or other data provided through our Services.
User Content: information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials, other than RNA Information and Self-Reported Information, generated by users of My Trillions Services and transmitted, whether publicly or privately, to or through My Trillions. For example, User Content includes comments posted on our Blog, or similar service, or messages you send through our Services.
Web-Behavior Information: information on how you use our Services or about the way your devices use our Services is collected through log files, cookies, web beacons, and similar technologies (e.g., device information, device identifiers, IP address, browser type, location, domains, page views).
Third-Party Information: in order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. This information may include mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we may receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.
Inferred Information: we may infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. For example, we use your RNA Information to predict certain health predispositions, or we may infer your location (such as city, state, and country) based on your IP address.
II. How do we use your information?
We use personal information collected through the Services, including health information, in the Services, and for a variety of business purposes as described in this Privacy Statement. We do not use or disclose users' information except as described in this privacy statement. Our purposes for using personal information include:
To facilitate account creation and logon process.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To send administrative information to you.
To provide users with important information about the Services, including critical updates and notifications. We may use your personal information to send you the product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
To protect our Services. We may use your information as part of our efforts to keep our websites safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with agreements between you and us.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To deliver and facilitate the delivery of services to you. We may use your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
To allow third-party contractors to perform services for My Trillions directly related to the Services that an individual user requests, such as a blood lab.
To send you an My Trillions newsletter, if the user opts in.
For marketing or promotional purposes. We will not disclose any information that could be used to personally identify a user.
Aggregated data for site usage statistics.
As reasonably necessary and as directly related to providing the Services that an individual user requests, including coordination with insurance, enforcing users’ rights, protecting against fraud, resolving disputes, etc.
Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
We may use your personal information for Research Purposes. We will only use your personal information stripped of Registration Information, except for year of birth, gender, country/region, city, state, and zip code (“Research Personal Information”). Research Purposes includes allowing My Trillions, non-profit organizations, pharmaceutical companies, or academic institutions to use your Research Personal Information to study a wide variety of research topics. We may share summaries of research results with qualified research collaborators and in scientific publications. Results of our research may be used to help develop new ways to diagnose and treat disease, or new reports and features for the My Trillions Services.
My Trillions will not share any personal information in such a way that it can be used to personally identify a user. Decisions based on data are made by natural persons and are never automated.
Personal information stored in the Services may be processed in the United States or any other country in which My Trillions or its affiliates, subsidiaries, or service providers maintain facilities.
We may process information relating to transactions, including purchase services, that you enter into our website. The transaction data may include your contact details, your card details, and the transaction details. The transaction data may be processed for the purpose of keeping proper records of those transactions.
III. Will your information be shared with anyone?
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
Consent: We may process your data only if you have given us specific consent to use your personal information for a specific purpose.
If you use the Services, then we will share your with personal information with a lab, but they will be restricted to use the data only for the analysis of your specimen and for no other purposes.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information only where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
At Your Option: Other than as set out above, you will receive notice when personal information about you might be shared with third parties, and you will have an opportunity to choose not to share the information.
More specifically, we may need to process your data or share your personal information in the following situations:
Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Authorized Vendors, Service Providers, and Other Third-Party Service Providers: We may share your information with third-party vendors and service providers that help us with specialized services, including billing, payment processing, data analysis, email delivery, lab services, and medical image management services. These third-party vendors and service providers may not use your information for purposes other than those related to the services they are providing to us. Further, they must process that information in accordance with this Privacy Statement and as permitted by applicable data protection law.
Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Statement. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
This website may include links to social media on other third-party sites. If you choose to engage in public activities on third-party sites, you should be aware that any information you share there can be read, collected, or used by other users of these sites and forums. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in public areas.
IV. How do we keep your information safe?
At My Trillions, security is our highest priority. We design our systems with your security and privacy in mind. We maintain a variety of compliance programs that validate our security controls periodically. We protect the security of your information during transmission to or from our website, applications, products, or services by using encryption protocols. We maintain strict physical, electronic, and administrative safeguards in connection with the collection, storage, and disclosure of personal information whether the data is collected from you or other sources.
My Trillions securely stores all your data electronically with measures to protect your Personal Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. And we have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we process. However, despite our safeguards and efforts to secure your Personal Information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, the transmission of personal information to and from our websites is at your own risk. You should only access the websites within a secure environment.
V. Your access and choices
You can view, update, and delete certain information about your account and your interactions with My Trillions. You can access all information regarding your account on the platform itself. To delete or update information yourself, you can always contact us for assistance in the contact methods given in Section 11.
You have choices about the collection and use of your personal information. You will be provided with the option to consent to My Trillions privacy practices before we start collecting your information. You can choose not to provide certain information or disagree with our privacy practices, but then you might not be able to take advantage of certain My Trillions Services to the fullest. My Trillions will not collect your personal information unless you consent to do so.
Account Information: If you want to add, update, or delete information related to your account, please use your preferred method provided in Section 11 to contact us. When you update or delete any information, we usually keep a copy of the prior version for our records.
Communications: If you do not want to receive promotional messages from us, please unsubscribe or adjust your communication preferences using the link provided in the marketing emails itself.
VI. Sample Collection and Data Usage
1. RNA and DNA Data Collection
My Trillions collects RNA or DNA data from blood samples and/or DNA data from saliva samples for genome sequencing and analysis. By submitting a sample to My Trillions, you are agreeing to the collection, processing, and analysis of your biological material (RNA and/or DNA) for the purposes of delivering the results and insights associated with our Services.
2. Blood Collection via Tasso
For RNA analysis, blood samples are collected using a third-party blood collection system provided by our partner, Tasso. This system ensures that your sample is safely and efficiently gathered for analysis. While Tasso handles the collection process, My Trillions remains fully responsible for the subsequent sequencing and analysis of the RNA data extracted from your blood sample.
3. Data Retention and Usage
Retention of Biological Data: My Trillions will retain your RNA and/or DNA data for the duration necessary to fulfill our Services, as well as for scientific research purposes. This data may be retained indefinitely in anonymized form to support ongoing research and development efforts.
Research and Development: My Trillions may use anonymized and aggregated genetic data to advance scientific research, which could include collaboration with third-party researchers in the pharmaceutical or academic sectors. This data will not be shared in any form that can personally identify you unless you have provided explicit consent.
Data Sharing: Anonymized genetic information may be shared with third-party partners (e.g., research institutions or pharmaceutical companies) for research and commercial purposes. This sharing helps facilitate advancements in healthcare and personalized medicine. We will not share any identifiable personal information without your explicit consent.
4. Opting Out of Data Sharing
You have the right to opt out of sharing your anonymized genetic data with third-party researchers. However, opting out may limit the Services we can offer, especially where certain research initiatives are integral to the functioning of our platform. To opt out or manage your data preferences, please contact our support team at [Insert Contact Information].
5. Your Consent
By using My Trillions’ Services and submitting your biological samples, you are consenting to:
- The collection, processing, and analysis of your RNA and/or DNA data.
- The retention of your biological data for scientific and research purposes.
- The sharing of your anonymized data with third parties for research, with the ability to opt out at any time.
VII. How long do we keep your information?
If you close your account, we may retain your Personal Information:
For as long as necessary to comply with any legal requirement;
On our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
For as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies.
Users can close their My Trillions account at any time by signing into the Services and editing their account profile. My Trillions waits 180 days before permanently deleting account information in order to help avoid accidental or malicious removal of users’ information. A user should contact customer service if they want to reopen an account. Users should consider deletion carefully because My Trillions will not be able to reopen it. Upon account closure, My Trillions will retain only anonymized data and genomic information indefinitely for research and development purposes.
VIII. What are your rights?
You have the right to review, change, or terminate your account at any time.
If you are resident of the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.
You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you have questions or comments about your privacy rights, you may email us at: team@mytrillions.com.
Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:
Contact us to update your user account.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. Contact us to opt out.
Rights under GDPR
Under GDPR you have the right to request access and obtain information about your personal data; update, correct or delete your personal data; restrict or oppose (for legitimate reasons) the processing of your personal data by contacting the Data Protection Officer (DPO). Please note, My Trillions collects and stores data in the United States of America. My Trillions will reasonably oppose the collection of your data by the U.S. government through standard data collection mechanisms. However, you accept the risk that there is a lack of adequate safeguards to prevent the US government from accessing your data through one of its covert domestic surveillance programs, hackers, cybercriminals, or other unauthorized third parties from improperly collecting, accessing, stealing, or modifying your information.
California Residents Privacy Rights
California Civil Code Section 1798.83, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents." If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.
What categories of personal information may we collect?
| Category | Examples |
|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history and financial information |
| C. Protected classification characteristics under California or federal law | Gender and date of birth |
| D. Commercial information | Transaction information, purchase history, financial details and payment information |
| E. Biometric information | Fingerprints and voiceprints |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements |
| G. Geolocation data | Device location |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities |
| I. Professional or employment-related information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us |
| J. Education Information | Student records and directory information |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:
Receiving help through our customer support channels
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at team@mytrillions.com or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between each service provider and us. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal data.
My Trillions has disclosed the following categories or personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
- Not applicable.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to request information on:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information de-identified in response to a consumer request or re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person with whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
To exercise these rights, you can contact us by email at team@mytrillions.com or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: team@mytrillions.com.
IX. Use by Children/Minors
We do not knowingly allow individuals under the age of 18 to create accounts that allow access to our Services. Individuals under the age of 18 must obtain the authorization of a responsible adult (parent or legal guardian) before using or accessing our Website. If we become aware of individuals who have provided us with personal data and are under the age of 18, we will take steps to deactivate the account and delete the personal data. If you become aware of information from individuals under the age of 18 which has been provided to My Trillions, please contact us at team@mytrillions.com.
X. Changes to our privacy policy
We update this privacy statement annually. When we do, we will also revise the "last updated" date at the top of the privacy statement. For material changes to this privacy statement, we will notify users either by placing a prominent notice on the homepage of the My Trillions website or by sending users a notification directly. We encourage users to review this privacy statement periodically to stay informed about how we are helping to protect the personal information we collect. A user’s continued use of the Apps constitutes a user’s agreement to this privacy statement and any updates.
XI. Enforcement of this Privacy Statement
By choosing to visit this website and use the Services, a user agrees that any dispute over the terms of this Agreement is governed by Idaho law, excluding Idaho’s choice-of-law rules, and the user agrees to abide by the limitation on damages contained in our terms of service or other agreements with MORE Health. THE EXCLUSIVE VENUE FOR ANY DISPUTE RELATING TO THIS AGREEMENT IS TETON COUNTY, IDAHO. A USER AND US CONSENT TO THE PERSONAL JURISDICTION OF THESE COURTS. Nothing in this Agreement limits either party's ability to seek equitable relief.
XII. How to contact us
If you have any questions about Our Company’s privacy policy, the data we hold on you, or if you would like to exercise one of your data protection rights, please do not hesitate to contact us.
Email us at: team@mytrillions.com