ABS Health Privacy Policy

Your privacy matters to ABS Health. This Privacy Policy explains the categories of Personal Information we gather, how it is gathered, why we gather it, and how we may share or use it. It also outlines the choices available to you with respect to your Personal Information, including how you can review, update, or request the deletion of that information.

Please take a few minutes to read through this policy. You can scroll the page or jump using the section headings below. By accessing or using our Platform, you agree to the practices outlined here. If anything is unclear or you have questions, please reach out to us using the Contact information at the end of this page.

If a disability prevents you from accessing this Privacy Policy, please contact us and we will provide it in an alternative format.

I. Who is ABS Health?

ABS Health was created on a simple premise: getting older shouldn't mean settling for less. Rather than chasing some idealized version of a younger self, our focus is on helping people live and perform at the level that matters most to them today — whether that's keeping pace with their kids, staying sharp at work, or pursuing a goal they once thought was out of reach.

ABS Health is not a medical practice and is not a healthcare provider. Through the Platform, we offer access to laboratory testing and related results, along with telehealth consultations delivered by independent, licensed clinicians made available through Beluga Health (the "Medical Group") — an independent, physician-owned clinical organization whose network of United States–based practitioners is licensed across all 50 states (each a "Provider"). The Medical Group (or your own clinician, if you do not see a Medical Group Provider) — not ABS Health — is responsible for furnishing you with a Notice of Privacy Practices that addresses the collection and use of your health information.

II. Key Terms & Definitions and Scope of This Policy

A few definitions will make the rest of this document easier to follow.

When this Privacy Policy applies

This Privacy Policy describes the categories of Personal Information we may collect when:

• You browse, access, or use the Platform — including when you order a test kit, register for an account, or join our online community;
• We exchange messages with you by email, text message, or other electronic means; and
• We speak with you in person, by phone, or through a telehealth consultation.

When this Privacy Policy does not apply

This Privacy Policy does not apply to information collected by any other website operated by us or by a third party, unless that website appears in the list above or links to this Privacy Policy. It likewise does not extend to third-party websites we may link to or that you reach through our Platform.

This Privacy Policy also does not govern information collected from users who sign in to the password-protected, secure portion of our Platform (the "Secure Platform"). The Secure Platform is the place where users who have purchased Services ("Customers") carry out functions or obtain Services such as telehealth visits with the Medical Group or its Providers. Information collected, stored, or contributed within the Secure Platform is treated as personal health information and/or medical information and is governed by the federal and state laws that apply to that information. The use and disclosure of that personal health information are addressed in the Notice of Privacy Practices furnished by the Medical Group. Information drawn from the Secure Platform or received from the Medical Group or your Provider is not used by us for advertising or marketing purposes.

Relationship between this Privacy Policy and the Terms of Use

This Privacy Policy is incorporated into our Terms of Use, which also apply when you use the Platform.

III. Personal Information We Collect, Use, and Disclose

What categories of Personal Information do we collect?

We may collect and use the following categories of Personal Information (collectively, "Personal Information").

Health Information

Some of the Personal Information we receive may qualify as personal health information under various state privacy statutes. As noted earlier, your Provider — not ABS Health — will furnish you with a Notice of Privacy Practices that addresses the collection and use of your health information. We collect and use personal health information solely for the purpose of providing the Services, and we limit our collection to the minimum necessary to deliver the Services through our Platform. We may combine your personal health information with other Personal Information we have obtained directly from you or from a third party such as your Provider or another healthcare professional.

How do we collect your Personal Information?

We obtain Personal Information directly from you, automatically through your use of the Website, and from third parties, in the following ways:

• When you provide it through the Website. For example, when you order a test kit or register for our online community.
• From third-party laboratories, when results from your laboratory testing are returned to us.
• When you subscribe to our Services. If you opt in to a premium offering, we collect additional Personal Information related to that offering. Some premium features are paid Services.
• When you make payments through the Platform. We do not collect or store financial account credentials, though we may receive transaction identifiers and summary information that does not include card or bank account numbers.
• When you contact us. When you reach out — for example, to our Care Team — we receive the contents of your message, any attachments you send, and any additional Personal Information you choose to share.

We also collect Personal Information automatically when you use our Website, using the technologies below:

• Cookies. We and our service providers may use cookies, web beacons, and similar technologies to receive and store certain Personal Information whenever you interact with our Platform or Services through your computer or mobile device. A "cookie" is a small data file delivered from a website and stored on your device. Some cookies are "session" cookies, which are removed automatically when you close your browser at the end of a session — these are used to optimize Website performance and reduce redundant data transfers. Others are "persistent" cookies, which remain on your device until you (or your browser settings) delete them. We may use persistent cookies for purposes such as analyzing performance to maintain the quality of the Platform and Services. We and third parties may use both types of cookies for analytics and advertising. You can configure your browser to reject cookies or to alert you when one is being set; doing so, however, may make some areas of the Platform or Services unavailable to you. Unless you have configured your browser or operating system to refuse them, our system will deliver cookies when you direct your browser to our Platform.
• Facebook (Meta) Pixel and Instagram. We use the Facebook Pixel and Instagram, a web analytics and advertising service offered by Meta Platforms, Inc. ("Meta"), on our Platform. With these tools, we and our partners can monitor what users do after seeing or clicking on a Facebook or Instagram advertisement, identify users who reach our Platform or advertisements from different devices, and improve targeting of advertising to relevant audiences. Data captured through the Pixel and Instagram is also stored and processed by Meta, which may associate it with your Facebook or Instagram account and use it for advertising purposes consistent with Meta's data policy. To withdraw consent for use of your data with Facebook Pixel, visit Meta's ad settings.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), to collect certain Personal Information about how the Platform is used. Google Analytics relies on cookies to help analyze usage patterns.
• Other third-party tools. We use additional third-party tools to track Platform performance, including error reporting and other technical diagnostics that help us improve the Platform and Services.

How do we use your Personal Information?

We may use your Personal Information for purposes including the following:

• To operate, maintain, supervise, administer, and enhance the Platform and Services — including monitoring the effectiveness of content, analyzing aggregated usage, supporting registration, and assisting Providers in delivering the Services through tools that may include generative artificial intelligence.
• To make our Products and Services available to you in a customized, user-friendly way.
• To deliver information, Products, or Services that you request or that may be relevant to you.
• To promote and market the Platform and Services, including newsletters, special offers, and tailored advertising on third-party sites. You may opt out of marketing emails at any time as described below.
• To send you account notices.
• To respond to your inquiries.
• To inform you of changes to the Platform, the Services, or any Products offered through them.
• To carry out any other purpose for which you provided the information.
• To perform our obligations and enforce our rights under any contract between us, including for billing and collection.
• To anonymize and aggregate Personal Information for reporting and analytics.
• To respond to law-enforcement requests, court orders, and subpoenas, and to satisfy legal or contractual obligations.
• To authenticate use, detect fraud, and otherwise maintain the security of the Platform and the safety of others.
• To administer surveys and questionnaires.
• To inform you about goods and services that may interest you, including via newsletters.
• For any other purpose to which you consent.

How do we disclose your Personal Information?

We may share Personal Information with third parties in certain situations, including:

• Business operations. Affiliates, vendors, service providers, and business partners — including hosting and storage providers, analytics and advertising vendors, technology and support providers, data security advisors, and professional advisors such as auditors, law firms, and accounting firms.
• Your healthcare providers or family. With your consent, we may share Personal Information with your healthcare providers and/or with family members or friends you designate.
• Other health-focused mobile apps. With your consent, we may share your profile information and connected-device data with other health-focused applications you have installed on your device. Once shared, that information will be governed by those apps' privacy policies, not this one.
• With your consent. We may disclose your Personal Information whenever you direct us to do so.
• Compliance with law. To comply with applicable law and obligations under it, including cooperating with law enforcement, judicial orders, and regulatory inquiries.
• Business transfers. To a buyer or successor in connection with a merger, divestiture, restructuring, reorganization, dissolution, sale, or other transfer of any portion of our assets — including in a bankruptcy or similar proceeding.
• To enforce our rights. To enforce our terms and conditions and Terms of Use, and to maintain the safety and security of the Services and our users.
• De-identified information. We may share de-identified information that cannot reasonably be used to identify any individual with third parties for marketing, advertising, research, or similar purposes.
• To improve the Platform. Internal testing, research, analysis, and product development — including to develop and improve the Website, Products, and Services. We may use Personal Information to train generative artificial intelligence tools.
• To market our Products and Services. With affiliates and third parties to market our Products and Services.
• To market third-party products and services. With affiliates and third parties to market their products or services to you, unless you have opted out.
• Third-party analytics. We use Google Analytics and Microsoft Clarity to understand and evaluate how visitors interact with the Platform and Services.

Your choices about how we share your Personal Information

This section explains the choices available to you and how to exercise them. You can opt out of our use of tracking technology, our sharing of your Personal Information for advertising to you, and other targeted advertising. To opt out of third-party collection of your Personal Information for targeted advertising in the United States, visit the National Advertising Initiative (NAI) opt-out page and the Digital Advertising Alliance (DAA) opt-out page.

Each web browser provides settings to restrict and delete cookies. Browser manufacturers publish guidance on managing cookies — please consult the documentation for your specific browser.

If you do not want your email address used by ABS Health to promote our Products and Services, you may opt out at any time by clicking the unsubscribe link at the foot of any marketing email or other marketing communication you receive from us. This opt-out does not apply to Personal Information we collect because of a Product purchase or your use of the Platform or Services. The Platform may also offer additional preferences for marketing and communications.

You may also encounter advertisements on other websites because we participate in advertising networks. These networks let us target our messaging to users using demographic, interest-based, and contextual information.

How do I access and correct my Personal Information?

You can review and modify your Personal Information by signing in to your account. You may also Contact Us to flag changes or errors in any Personal Information we have, so that it can be kept accurate, complete, and up to date, or to delete your account. We can only delete your Personal Information by also closing your account with us. We may not be able to honor a request if doing so would violate any law or legal requirement, or would cause the information to become inaccurate.

IV. Who May Use Our Services

This Privacy Policy applies to personal use of our Platform and is available only to users in the United States, and only in the states where the Medical Group operates and its Providers are appropriately licensed. You should not use the Platform or the Services if you do not agree with this Privacy Policy or the Terms of Use.

ABS Health operates subject to state and federal regulations, and the Platform and/or Services may not be available in your state. You represent that you are not barred from enrolling in or receiving the Services under the laws of the United States or any other jurisdiction in which you may be located. Access to and use of the Platform and/or Services is limited exclusively to users located in U.S. states where the Platform and/or Services are available. The Platform and Services are not available to users located outside the United States.

V. Children's Privacy

Protecting children's privacy in online environments is important to ABS Health. The Platform is not designed for, or directed at, children 18 years of age or younger. It is not our policy to knowingly collect or maintain Personal Information about anyone under 18. No one under 18 should submit any Personal Information to the Platform. If we learn that we have collected or received Personal Information from a child under 18, we will delete that information. If you believe a child under 18 may have provided us with Personal Information, please Contact Us.

VI. Data Security

We have put in place reasonable administrative, technical, and physical safeguards designed to protect against accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use of Personal Information. The internet, however, is not 100% secure, and we cannot guarantee the security of information transmitted over it. Where you have been given or chosen a password, keeping it confidential is your responsibility.

Sharing and transmitting information online is never completely secure. We work to apply best practices and industry-standard security tools to protect your data. Even so, we cannot guarantee the security of Personal Information sent to, hosted on, or transmitted through our Services. Any transmission of Personal Information is made at your own risk. We are not responsible for the circumvention of any privacy settings or security controls included in the Platform, your operating system, or your mobile device.

VII. California Privacy Rights — Notice to California Residents

California residents should also review our California Privacy Notice.

California Civil Code § 1798.83 (California's "Shine the Light" law) permits users of the Platform and/or Services who are California residents and who have provided Personal Information in obtaining Products and Services for personal, family, or household use to request information about our disclosure of Personal Information to third parties for those third parties' direct marketing purposes. Where applicable, this disclosure would include the categories of Personal Information shared and the names and addresses of the businesses with which we shared your Personal Information for the immediately preceding calendar year (e.g., requests made in 2027 will receive information regarding such activities in 2026). You may submit one request per calendar year. To make a request, please Contact Us using the information below.

VIII. Updates to This Privacy Policy

We may update this Privacy Policy from time to time, in our sole discretion, to reflect changes in our practices, in applicable law, or in industry best practices. Updates will be posted on this page. If we make material changes to how we treat the Personal Information we collect, we will notify you by email at the address listed in your account and/or through a notice posted on the Platform. The "Last Updated" date at the top of this page identifies when the Privacy Policy was most recently revised. You are responsible for keeping your email address current and active with us, and for revisiting the Platform and reviewing this Privacy Policy periodically to check for changes.

IX. How to Contact Us

If you wish to reach us regarding this Privacy Policy or for any other reason, you may contact us at:

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