How we handle your data, and the terms of using our services.
Welcome to Immunaeon. We are dedicated to providing you outstanding service, improving options and advancing inquiry for a better future.
To provide and improve our client sample collection process, sample analyses, storage services, future advancements and collaboration, our offices, our website, our mobile applications, and customer services (collectively our “Services”), we collect, process, and store “Personal Information.” Personal information is information that can identify you directly or indirectly. As further described in Section 3, this is information such as your name, address, email address, and information carrying your name, including your samples and any reports generated about it that carry your name, including Genetic Information. This Terms of Service & Privacy Policy describes our practices for collecting, analyzing, communicating, storing, and processing your Personal Information. It also describes the steps we take to keep it private and secure. Finally, it explains your rights to control and manage your own Personal Information. Please note: Information about deceased persons is not Personal Information under this Statement.
You may become an Immunaeon Client if you are of legal age to form a binding contract with Immunaeon, and are not a person otherwise barred from receiving the Services under the laws of the jurisdiction in which you are resident or from which you use the Services. You must be eighteen (18) years of age or older to contribute biologic material, and agree to this Terms of Service and Privacy Statement on behalf of yourself or on behalf of another for whom you have legal authority to agree.
When you create an account with Immunaeon, you provide certain Personal Information to us, including your name, email address, street address, billing information, completion of a baseline medical history questionnaire, and creation of a password.
By creating an account with Immunaeon, you are telling us that you understand Immunaeon will collect, process, and share your Personal Information (including your Genetic Information) as described in this Privacy Statement.
Access to Immunaeon storage and analytics services includes a blood draw from you, from which we will isolate biologic material for initial analysis, cytometry testing and storage. We store your cells according to our storage agreement with you, and we make a reservation of your biologic material for our potential future analyses. During the course of our Services, we will process your biometric data that may contain your Genetic Information. These services listed above contain your individually identified personal protected health information.
We will also de-identify your data results and the remainder of your biologic material for potential use with third parties. De-identifying is also called anonymization, and both words mean the information and materials no longer include your name, address, or other individually identifiable items of contact information. De-identified data and materials are not Personal Information under this Statement.
You retain rights of control over your Personal Information, material and data. At any time, you can request that Immunaeon delete Personal Information you have provided to us. You can also delete your entire account and terminate your storage services with us.
Immunaeon is not a health provider. We do not diagnose or treat any health conditions. Immunaeon enables individuals to have a sample of their body's blood, including cells from their own immune system, drawn, analyzed, and stored for their potential future use. We keep you informed about your Personal Information and about immunotherapy news, opportunities, and resources.
Immunaeon also reserves a portion of your sample for potential future analyses and use.
When your individual biologic material, biomedical data, or genetic material is maintained separately and distinctly, and bears marks and labels that can personally identify you as a unique individual, it is your Personal Information. Immunaeon protects your Personal Information and maintains its Privacy and Security as required by law. Immunaeon requires all of its partners, collaborators and business associates to follow the law as well.
Your Personal Information as described above will never be used or sold to third parties without your prior written consent.
When biologic material, biomedical data, or genetic material is no longer separate, distinct, and/or bears no marks or labels that can personally identify a unique individual, it is no longer Personal Information. Immunaeon may de-identify, anonymize, aggregate and subsequently use or sell this material or data with or to third parties for lawful purposes including research and development, and research studies as permitted by law. Some of these purposes may lead to commercial products or services and income. Immunaeon clients do not have property rights in commercial income.
Identified Human Research Opportunities may arise. You can decide in advance whether or not you want to be notified of such opportunities. You can decide either in advance or at the time whether or not you will participate and/or your Personal Information will be included in that research. Your Personal Information will never be used or sold for Human Research without your prior written consent.
Below is a summary of Information and Uses with respect to Immunaeon and our business.
When you open an Immunaeon Account with us, your Account Information may contain your name, your street address, your email address, and your telephone number.
When you make a payment to us, your Payment Information may contain your credit card number, your billing and shipping addresses, and the dates when you made purchases.
When we obtain your blood sample, your Personal Information may contain your Basic Medical History, including medications taken and past diagnoses and treatments, your assigned sex at birth, and the year of your birth.
When you communicate with us, the information you provide may include responses to our surveys or health questionnaires available.
When we process, isolate, and analyze your blood cells, the information we gather includes your biometric data and biological material, for example: immune cells present, their percentages, viability, T cells, B cells, Monocytes, Dendric Cells, and NK cells. DNA data may also be included.
Note About Health-Related Information: Immunaeon does not provide medical care and is not a health provider. We are not a covered entity under the Health Insurance Portability and Accountability Act (“HIPAA”). However, we may communicate, partner, or collaborate with covered entities regarding protected health information. As a result, Immunaeon uses reasonable care as a business associate to maintain the Privacy and Security of all individually identifiable health information about you that we may receive.
When we host and maintain your communications with us on our platforms and within Immunaeon, the information may contain your communications with our Member Services and Service Support teams, including audio and visual information, recordings of calls with Immunaeon, or information voluntarily shared when communicating with us.
When you volunteer to take our surveys and promotions, information may contain your responses to special consumer insights surveys or promotions we run or sponsor.
When you use our websites, please refer to our Term & Conditions of Website & Cookie Policy, located on our websites, to learn about how we and our technical integration partners use technology for analytics and preference purposes, and about the controls we provide you.
When you use and interact with social media platforms, for example if you “Share,” “Post,” “Tweet,” “Pin,” or “Follow Us” through links to sites such as Meta/Facebook, Twitter, Pinterest, Instagram, or YouTube, your interactions with these features are governed by the privacy statement of the applicable third-party company. Immunaeon may collect these interactions and whatever account information these services make available to us, dependent on your privacy settings with that third party.
Immunaeon may review and collect records and verification information from various Public and Historic Records, including news, records of birth, death, and marriage, which may contain Personal Information relating to you. Public and historical records may also contain Personal Information relating to non-Immunaeon users. Your rights are governed by the applicable third-party source.
We may also receive information about you from other third parties. For example, we may supplement the data we collect with information licensed from third parties in order to personalize the Services and our offers to you. For example, if you purchase a gift, or subscription, we will collect Personal Information, such as the recipient's name, shipping address, email address, and the necessary purchase information to complete the gift and notify the recipient.
Immunaeon protects the Privacy and Security of your Personal Information that exists in our platforms and within our business operation networks according to law. We also require our partners, collaborators, and business associates with whom we interact, to follow the laws on Privacy and Security as well.
Upon your request, Immunaeon will disclose to you all your Personal Information that we see, gather, collect, store and delete, and we give you control over the use and disclosure of your Personal Information by us.
Upon your request, Immunaeon will disclose to you the purpose for the use of your Personal Information that exists within our Services, on our platforms, and in our business operations.
Immunaeon will obtain your prior written consent for uses of your Personal Information outside of our Services, and will not make unauthorized releases of your Personal Information.
Immunaeon will keep and maintain your Personal Information and your requested preferences with the privacy and security protections in place that are required by law.
We keep and maintain your Personal Information unless and until you tell us you want to close your account with us, terminate services, want your materials destroyed, and/or want your data deleted.
Immunaeon responsibly de-identifies, randomizes, and anonymizes biologic material and biometric data whenever possible for all applications outside of our Services.
Immunaeon follows the minimum necessary rule to reduce the flow of information regarding Clients even within our secure networks.
We notify you in advance about the protections we place over the information that you may voluntarily choose to share with us about yourself.
You remain in control of your Personal information with Immunaeon.
Services. We use your Personal Information to provide, personalize, improve, update and expand our Services. This includes:
Communications. We use your Personal Information to communicate with you about the Services, such as when we:
Market Products and Offers from Us or Our Business Partners. We may use some Personal Information based on your interests. For example, demographic information available from third-party sources or from us, to identify offers from us or from our business partners.
Genetic Information Explicit Consent. Please note, Immunaeon does not share your identifiable Genetic Information with third-party marketers, insurance companies, or employers. We will not use your identifiable Genetic Information for marketing or personalized advertising without first obtaining your prior written consent.
Your Account Privacy Controls and Preferences. You can control how we contact you and market to you by changing the privacy controls and preferences under your account on our websites. You may also use the unsubscribe link in any marketing email you receive, or by following the instructions in marketing communications you receive. For more information, please see our Term & Conditions of Website & Cookie Policy.
Biologic Material, Biometric Data, and Genetic Information. Immunaeon may use your biologic material, biometric data and Genetic Information for the analyses we perform as part of our Services to you, to help you learn more about your sample and how it may assist you in the future, or to provide you with other insights into what your data including your DNA may reveal about traits, and wellness. We may also use it to: studying aggregated Genetic Information to better understand population and health, wellness, aging, or physical conditions; conduct scientific, statistical, and historical analyses and research; improve features and functionality in our existing products; enhance the customer experience; improve the quality of our processes and technology, and build new products and services, including services related to personal wellness.
Immunaeon retains Client identified biologic material, biometric data and Genetic Information in user accounts and through our systems, until our Client informs us of their desire to close their account, destroy their identifiable samples, and/or delete their identifiable data.
You may request that Immunaeon destroy your biologic material, biometric data and Genetic Information by contacting Member Services. At our discretion, we may destroy biologic material that does not meet our quality assurance requirements.
Account and Profile. Immunaeon will retain the Personal Information you provide while creating your account and your profile until such time as you delete your account.
Identified Biologic Material, Biometric Data, and DNA. Immunaeon may retain your individually identifiable biologic material, biometric data, and DNA to provide our Services to you, and to expand future features and functionality, until you close your account, and tell us to destroy your identifiable samples, and/or delete your identifiable data.
De-identified Biologic Material, Biometric Data and DNA. De-identified material and data cannot be used to identify you and is not considered your Personal Information. Immunaeon may use or sell de-identified, materials and data.
Storage Law. If your samples are stored at a laboratory partner that is required to retain your sample and data for a period of at least seven years, or as required by state law and the Clinical Laboratory Improvements Act (CLIA) and the guidelines that apply to laboratories certified by the College of American Pathologists (CAP), then it will be retained according to law.
Usage Information. We retain usage information, for example, visits to sites, in a de-identified or aggregated form. Once aggregated, this information ceases to be personal and will not be subject to user deletion requests.
Immunaeon does not share or sell your individually identifiable Information, including your Genetic Information, with third parties without your prior written informed consent except as described in this Statement and as follows:
We do not voluntarily share your information with law enforcement.
Immunaeon does not share your Genetic Information with insurance companies, employers, or third-party marketers without your express consent.
The circumstances described below explain when sharing might occur:
Immunaeon Partners, Associates, Collaborators. We may share your information within Immunaeon's partners, associates, and collaborators in order to provide our Services to you and to improve our Services.
Others With Whom You May Choose to Share. As part of your use of the Services, you have the option to add or share information with others, including your health providers. If you choose to share any of your information to anyone outside Immunaeon Services, you do so at your own risk.
Service Providers. We work with other companies when providing the Services. As a result, these companies will have access to or have some of your information, including some of your materials and data, with your Personal Information, in their systems. These companies are subject to contractual obligations governing privacy, data security, and confidentiality consistent with applicable laws.
These companies include our:
Analytics and Advertising Partners. We may work with third-party partners for analytics and advertising purposes. If we do, we may collect certain information to help us better personalize content including ads to match your interests. It also helps us to measure the effectiveness of our personalization and ad campaigns and is used to serve you with advertising that is more relevant to you.
Future testing of your Personal Information is at your option. You may consent to other tests and analytics. You may agree to our Informed Consent to Research.
Research Partners. We may share your individually identifiable Genetic Information with research partners, but only when you provide us with your express consent to do so by signing our Research Consent Form. Unless you agree to the Informed Consent to Research, your individually identifiable biologic material, biometric data and DNA will not be made available by Immunaeon to third parties including researchers.
Research partners include commercial, educational, independent, or non-profit organizations that conduct or support scientific research, the development of therapeutics, medical devices, or related material to treat, diagnose or predict health conditions. In some circumstances, a research partner or Immunaeon may have a financial interest in the research arrangement. Immunaeon may use or sell de-identified or anonymized biological material or biometric data with third parties.
Law Enforcement. Immunaeon does not voluntarily cooperate with law enforcement. We do not voluntarily allow law enforcement to use Immunaeon's services to investigate crimes or to identify human remains. To provide our Clients with the greatest protection under the law, we require all government authorities seeking access to Immunaeon customers' individually identifiable material or data to follow valid legal processes.
If we are compelled to disclose your Personal Information to law enforcement by valid legal processes such as a court Order or Subpoena, we will do our best to provide you with advance notice, unless we are prohibited under the law from doing so.
In the interest of transparency, Immunaeon documents all valid law enforcement requests for Client material or data in our List of Disclosures.
Other Legal or Regulatory Processes. We may share your Personal Information if we believe it is reasonably necessary to:
If Immunaeon is Acquired. If Immunaeon or its businesses are acquired or transferred, including in connection with bankruptcy or similar proceedings, we may share your Personal Information with the acquiring or receiving entity. The promises in this Privacy Statement will continue to apply to your Personal Information that is transferred to the new entity.
Future Testing or Studies. Immunaeon may disclose de-identified user information as part of the Services or our processes, or in scientific publications published by us or our research partners. For example, we might note the aggregate percentage viability of certain types of cells in persons with certain diagnoses. Such disclosure will never include Personal Information.
You have rights and choices upon your request to Immunaeon. In general, Immunaeon does not make third party disclosures of your Personal Information without your written permission.
Right of Access/To Know – You may have a right to request access to your Personal Information with us and to know what it contains.
Right of Correction – You may have the right to request that we correct inaccurate Personal Information about you.
Right to Copies – You may have the right to be provided with a copy of certain information including the categories of your Personal Information we collect and disclose.
Right to Data Portability – You may have the right to receive certain of your Personal Information that we have in a format that can be transmitted to another data controller.
Right to a List of Disclosures – You may have the right to receive a copy of any third party entity, such as a law enforcement official or court, that requested release of your Personal Information from us, and the authority on which they based their request.
Right of Erasure/Deletion – You have the right, in certain cases, to request that we delete your Personal Information, provided there are valid grounds for doing so and subject to applicable law.
To exercise any of these above listed rights, please contact our Immunaeon Data Privacy Officer.
You can request that we delete your Personal Information by contacting our Member Services. We will consider all requests on an individual basis and in accordance with law. If you have shared information with others, Immunaeon will not be able to remove any copies of information that others may have retained.
To access, update, or delete the Personal Information such as your email address, username, etc. that you provided to Immunaeon, please visit your account page on our Website, or contact Member Services.
How to Delete Genetic Information. To request that Immunaeon delete your Genetic Information and DNA Data, please contact Member Services. We will delete all Genetic Information and DNA Data about you from our Services, analytics, production, research and development, and systems within 30 days.
How to Request Destruction of your Biological Material and/or Biometric Data. To request that Immunaeon destroy your Biologic Material and/or Biometric data, you must contact Member Services.
Please note that if you have agreed to our Informed Consent to Research, we will not be able to remove your Materials or Data, including Genetic Data or DNA, from active or completed research projects, but we will not use it for any new research projects.
How to Manage and Delete Your Personal information from our Partners. You can contact Immunaeon or our partners to request that your Personal Information be deleted from that service. Some services may also have an online request form accessible from their website viewable there.
To discontinue your Services with Immunaeon, please contact Member Services.
To request that your Personal Information be deleted, your contract for services terminated, or your biologic material destroyed, Immunaeon will follow our Customer Renewal and Cancellation Policies. We will obtain your written request and effectuate your wishes within 30 days of our receipt thereof by our Member Services office. We will not terminate until we confirm the identity of the requesting party and if not you personally, their authority for so requesting, such as next of kin when a Client is deceased. It is normal for there to be some delay in deleting your Personal Information upon request from our backup systems after it has been deleted from our production, development, analytics, and research systems.
If you have not received confirmation of our receipt of your request to terminate services, or delete information, or destroy samples, then we did not receive it, and you are asked to call our Member Services.
Immunaeon may retain certain information as reasonably necessary to comply with our legal obligations, including law enforcement requests, to resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.
Also, our laboratory partners may retain certain information they receive from us in order for them to comply with laws or regulations that may require them to do so such as the Clinical Laboratory Improvements Amendments (CLIA) regulations and the U.S. Food and Drug Administration.
Immunaeon may Change this Terms of Service & Privacy Statement at any time. If we do, we will provide prominent advance notice of any material changes, such as posting a notice through the Services on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using our Services.
We will also notify you of non-material changes to this Statement as of their effective date by posting a notice through the Services, on our websites, or sending you an email.
If you object to any changes, you may delete your account as described above.
Data Controller, Privacy Officer: Michael John, (716) 336-6543
Acting Security Officer: Adam Utley, (336) 847-4725