Color Health Privacy Notice

New Terms Updated: May 20, 2025

 

Click here for a PDF version of this policy >

This Privacy Notice is designed to help you understand how Color Health, Inc. and its affiliates (collectively, “Color,” “we,” “us,” or “our”) collect, use, and share your personal information (“Personal Information”), and to help you understand and exercise your privacy rights. 

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
11. SUPPLEMENTAL NOTICE FOR CERTAIN INTERNATIONAL COUNTRIES
12. CHILDREN’S INFORMATION
13. OTHER PROVISIONS
14. CONTACT US

 

1. SCOPE AND UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice applies to personal information processed by us, including through our Site, App, and Services, as those terms are defined in the Terms of Service.

 Supplemental Notices. Color may provide additional privacy notices to individuals at the time we collect their Personal Information. These additional privacy notices may supplement this Privacy Notice or may apply in lieu of this Privacy Notice. If you are a California resident, please see our Supplemental California Privacy Notice below.

HIPAA Notice of Privacy Practices. This Privacy Notice does not apply to our processing of “Protected Health Information” as a “Covered Entity” or “Business Associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Where we act as a “Covered Entity” or “Business Associate”, our processing of “Protected Health Information” is governed by our HIPAA Notice of Privacy Practices. 

Notice Regarding Organizational Customer Data. In some cases, our organizational customer or partner (e.g., an employer, public health organization, educational institution, laboratory, or clinician) may enter into a written agreement with us where we process Personal Information on their behalf through their use of our Services (“Organizational Customer Data”). In that event, the organizational customers’ respective privacy policies govern their collection and use of Organizational Customer Data. 

Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

This Privacy Notice should be read in conjunction with our Terms of Service, HIPAA Notice of Privacy Practices, and any other document or agreement that governs your relationship with us.  By using our Services, you consent to our Terms of Service and the privacy practices disclosed in this Privacy Notice.  Please do not use our Services if you do not consent.

2. PERSONAL INFORMATION WE COLLECT

The categories of Personal Information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources as described below.

A. Personal Information You Provide to Us Directly

We may collect Personal Information that you provide to us in the following circumstances:

• Account Creation. When you create an account we may collect Personal Information, such as name, email address, address, phone number, race, ethnicity, professional details, birth date, sex, and any other information you provide.
• Provision of Services. For some Services that do not require an account, we may collect Personal Information when you participate in the Service, such as name, email address, address, phone number, race, ethnicity, professional details, birth date, sex, and any other information you provide.
• Testing Information and Biological Samples. We may collect Personal Information and biological samples in connection with any testing Services we provide to you. 
• Health Information. In providing Services to you, we may collect Personal Information that relates to your health or medical treatment that you have received, including information about your healthcare providers. 
• Telehealth. If we connect you with clinicians via telehealth, you will need to provide access to your camera and microphone. We and others with whom you video chat (e.g., Medical Providers) may collect the content and information you make available.
• Purchases. We may collect Personal Information and details associated with your purchases, including payment and address information. Any payments made via our Services are processed by third-party payment processors according to their privacy policies. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details). Any items ordered for delivery from Color will be sent to you via U.S. mail or a reputable courier pursuant to their privacy policies. 
• Your Communications with Us. We may collect Personal Information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect Personal Information from you in connection with the survey.
• Interactive Features. We and others who use our Services may collect Personal Information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, sharing features, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
• Conferences, Trade Shows, and Other Events. We may collect Personal Information from individuals when we attend or host conferences, trade shows, and other events. 
• Business Development and Strategic Partnerships. We may collect Personal Information from individuals and third parties to assess and pursue potential business opportunities. 
• Job Applications. We may post job openings and opportunities on our Services. If you respond to one of these postings, we may collect your Personal Information, such as your application, curriculum vitae, cover letter, and/or any other information you provide to us.

B. Cookie Policy and Other Personal Information Collected Automatically

We may collect Personal Information automatically when you use our Services.

• Automatic Collection of Personal Information. We may collect certain information automatically when you use our Services, such as your internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. 
• Cookies and Other Technologies. We, as well as vendors that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Services. 
• Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories: 

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party digital properties. We do not use these Technologies on our App.

See Your Privacy Choices and Rights below to understand your choices regarding these Technologies.

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
• Google Analytics. Google Analytics may use cookies and other tracking technologies to perform its services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. You may exercise choices regarding the use of cookies from Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
• LinkedIn Analytics. For more information about how LinkedIn uses your Personal Information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

C. Personal Information Collected from Other Sources

Vendors and Sources. We may obtain Personal Information about you from vendors and other sources. For example, if you access our Services through a vendor application, such as an app store, a vendor login service, or a social networking site, we may collect Personal Information about you from that third-party application that you have made available via your privacy settings.

Customers or Other Organizations. We may receive your Personal Information from Color’s customers or other organizations, such as your employer or healthcare provider, in connection with one or more business purposes, including to make our Services available to you.

Other Individuals. Our Services may allow individuals to share Personal Information about other people. For example, an individual may be able to share Personal Information about their family member in connection with testing or other Services. In order to share any health information about other individuals with Color in connection with receipt of the Services, individuals sharing health information must have the full and express consent of the other individual.  Color reserves the right to require proof of such consent.

Referrals and Sharing Features. Our Services may offer various tools and functionalities that allow you to provide Personal Information about your friends through our referral service. Our referral services may also allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend, neighbor, or co-worker).

3. HOW WE USE YOUR PERSONAL INFORMATION

​​Please note that our use of your Protected Health Information is governed by our HIPAA Notice of Privacy Practices, not this section.

We use your Personal Information for a variety of business purposes, including to provide our Services, for administrative purposes, for research as detailed below, to de-identify and aggregate information, and to market our products and Services, as described below.  

A. Provide Our Services

We use your information to provide you with  Services, such as:

• Providing you with testing and counseling services; 
• Providing you with a platform that may connect you with clinicians; 
• Providing you with a platform that may connect you with pharmacy services;
• Reporting certain test results and/or vaccination status to your program sponsor or other parties, with your authorization;
• Managing your information and accounts;
• Providing access to certain areas, functionalities, and features of our Services;
• Answering requests for customer or technical support; 
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing your financial information and other payment methods for products or Services purchased;
• Facilitate delivery of ordered or purchased Services;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for products, Services and events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
• Contacting you in connection with potential future events, promotions, research and studies; 
• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services; 
• Improving, upgrading, or enhancing our Services; 
• Developing new products and services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions, and other compliance activities;
• Sharing Personal Information with third parties as needed to provide the Services;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

C. Research

We may use your Personal Information to determine your eligibility for research, including medical, clinical, and public health research, and/or to contact you to seek your consent to use or share your Personal Information for research.  You will not be paid for this use. 

D. To Create De-Identified and/or Aggregated Information

We may use your Personal Information to create de-identified and/or aggregated information, such as demographic information, information about health or wellness, or other analyses we create. De-identified and/or aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, publications, making de-identified and/or aggregated information available to third parties, and any other legally permissible purposes.  We make available a research database that contains anonymized, aggregated genomic, phenotypic, diagnostic, clinical and/or other information.  It is intended for research use only, and any use for commercial or other non-research purposes is prohibited. To protect participating individuals’ identities, information is de-identified.

E. Marketing and Advertising our Products and Services

We may use Personal Information to tailor and provide you with content, promotions, and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, text messages, custom audiences advertising, and “interest-based” or “personalized advertising” including through cross-device tracking. Please note that we do not engage in this type of marketing activity when you access the App. If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below. 

F. With Your Consent

We may use Personal Information for other purposes that will be clearly disclosed to you at the time you provide Personal Information or with your consent.

G. Other Purposes

We may use your Personal Information for other purposes as requested by you or as permitted by applicable law.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

Please note that disclosure of Protected Health Information is governed by our HIPAA Notice of Privacy Practices, not this section.

We may disclose Personal Information to other parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.  

A. Disclosures to Provide our Services

The categories of recipients with whom we may share your Personal Information are described below. 

• Authorized Third Parties and Service Providers. We may disclose your Personal Information to our service providers and vendors that assist us with the provision of our Services. These entities include but are not limited to vendors that provide us with healthcare services, testing services, telehealth services, pharmacy services, IT support, hosting, billing, payment processing, customer service, fulfilling orders, delivering packages, sending postal mail, marketing efforts and cooperatives, web analytics, and related services.
• Medical Providers. If you seek care, treatment, testing, counseling or other services from a provider available through our Services or partners (each a “Medical Provider”), your Medical Provider may have access to your personal information in order to provide you with their services. Your personal information may also be subject to the Medical Provider’s privacy policy. We are not responsible for the Medical Provider’s processing of your personal information.
• Public Health Authorities. We may share your Personal Information and results with federal, state, and local public health authorities as required by applicable laws and regulations for public health purposes (e.g., to prevent the spread of COVID-19).  We may also share certain information about your vaccine and vaccination status with state immunization registries and other public health authorities in compliance with applicable laws and regulations.  
• Color Organizational Customers and Authorized Users of Organizational Customers. Color’s Organizational Customers (e.g., enterprises, unions, trusts, employers, public sector organizations, educational institutions, and others) purchase our Services for their authorized users (e.g., employees, staff, students, dependents, and other specified persons). If you access our Services as an authorized user of one of Color’s Organizational Customers, that Color Organizational Customer may access or receive certain information associated with your use of the Services including Personal Information, eligibility, usage data, the contents of communications, files associated with your account, and, where applicable, testing results. We are not responsible for the Organizational Customer’s processing of your Personal Information.
• Other Parties with Whom You Interact. As described above in “Personal Information We Collect,” our Services may allow you to disclose Personal Information or interact with other parties. If you disclose or interact with another party, your Personal Information may also be subject to the other party’s privacy policy. We are not responsible for that party’s processing of your Personal Information.
• Business Partners. We may disclose your Personal Information with business partners to provide you with a product or service you have requested. We may also share your Personal Information with business partners with whom we jointly offer products or services.
• Affiliates and Subsidiaries. We may disclose your Personal Information with our company affiliates and subsidiaries. 
• APIs/SDKs. We may use  application program interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose to external parties, any information we store associated with you if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your Personal Information are determined by applicable law and are described below. 

• Email Communications. If you no longer wish to receive emails from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you other communications regarding the Services for which you will not be able to opt out while you are using the Services (e.g., communications regarding our Services or updates to our Terms or this Privacy Notice). 
• Text Messages. If you no longer wish to receive text messages from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below. 
• Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• Phone Calls. If you no longer wish to receive phone calls from us, you may opt out of receiving future phone calls from us by following the instructions which may be available on the call or by otherwise contacting us as set forth in “Contact Us” below.
• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Personalized Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs may not be effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. 

Please note you must separately opt out in each browser and on each device. 

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access to and Portability of Your Personal Information, including: (i) confirming whether we are processing your Personal Information; (ii) obtaining access to or a copy of your Personal Information; and (iii) receiving an electronic copy of Personal Information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
• Request Correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information;
• Request Deletion of your Personal Information, subject to applicable data & record retention laws and requirements; 
• Request Restriction of or Object to our processing of your Personal Information; 
• Opt out of Targeted Advertising of your Personal Information. In addition to the methods described herein, you may choose to use the Global Privacy Control (“GPC”) browser signal to opt out of targeted advertising. You will need to turn it on for each browser you use;
• Opt out of Sales of your Personal Information. Some jurisdictions may consider targeted advertising a “sale” of personal information. You may request that we not “sell” your personal information. If you use the GPC signal, you will only be opted out of online sales of Personal Information, and will need to turn it on for each browser you use. To submit a request to opt out of offline sales that would not otherwise be controlled by GPC, please contact us as provided below;
• Withdraw your Consent to our processing of your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and
• Request Deactivation of your account, which will unsubscribe you from all marketing emails, and your sample and personal health information will no longer be shared for research.  Please note that deactivating your account means that we will not provide you with any Services going forward including but not limited to any results that have not yet been reported or any updates or changes to your results.   

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below or as otherwise instructed in the additional privacy notices provided at the time we collect your Personal Information. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of Personal Information.

By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information you provide will be stored or hosted on servers in the United States, but you acknowledge that all information processed by us may be accessed outside of the United States. You acknowledge that other countries outside of the United States may have data protection laws that are different from U.S. laws. We endeavor to safeguard your information consistent with the requirements of applicable laws and regulations. 

You agree that by providing your biological sample or any information you share with us, you are not violating any export ban or other legal restriction in the country of your residence. 

If we transfer Personal Information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, we may use various  safeguards to support such transfer including, but not limited to,  EU Standard Contractual Clauses. 

For more information about the safeguards we use for international transfers of your Personal Information, please contact us as set forth below. 

8. RETENTION OF PERSONAL INFORMATION

We store the Personal Information we collect as described in this Privacy Notice for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue business purposes, enforce our agreements, and comply with applicable laws. 

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice (“California Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”), and supplements our Privacy Policy. This California Notice applies only to information governed by the CCPA.

This California Notice also does not cover Personal Information that may be collected about you as a California job applicant or employee. 

Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Last Updated date, as well as our current practices.

A. How and Why We Collect, Use, and Disclose Your Personal Information 

 

We may collect, use, and disclose Personal Information for valid purposes consistent with applicable laws as identified below. Where we transfer applicable Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us. 

Category of Personal Information	Purposes for Collection, Use, and/or Disclosure	Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose
Identifiers, including real name, alias, account name, username, signature, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers	·  To provide and deliver our Services ·  For administrative purposes ·  Research ·  To create de-identified and/or aggregated information ·  Marketing and advertising ·  With your consent	·  Service providers ·  Affiliates ·  Data analytics providers
Personal information described in Cal. Civ. Code § 1798.80(e), including name, address, telephone number, and financial payment information	·  To provide and deliver our Services ·  For administrative purposes ·  Research ·  To create de-identified and/or aggregated information ·  Marketing and advertising ·  With your consent	·  Service providers ·  Affiliates ·  Data analytics providers
Characteristics of protected classifications under California or federal law, including age and date of birth, gender, languages spoken, marital status, and racial or ethnic origin	·  To provide and deliver our Services ·  For administrative purposes ·  Research ·  To create de-identified and/or aggregated information ·  Marketing and advertising ·  With your consent	·  Service providers ·  Affiliates ·  Data analytics providers
Internet or other electronic network activity information, including Internet or other similar activity, MAC address, cookie identifiers, mobile carrier, browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, social media account information or advertisement	·  To provide and deliver our Services ·  For administrative purposes ·  Research ·  To create de-identified and/or aggregated information ·  Marketing and advertising	·  Service providers ·  Affiliates ·  Data analytics providers
Geolocation data	·  To provide and deliver our Services ·  For administrative purposes ·  Research ·  Marketing and advertising of our Services	·  Service providers ·  Affiliates ·  Data analytics providers
Commercial information, such as products or services purchased or considered, purchase history, transactional and marketing data, etc.	·  To provide and deliver our Services ·  For administrative purposes ·  Marketing and advertising of our Services ·  With your consent	·  Advertising partners ·  Business partners ·  Service providers ·  Affiliates ·  Data analytics providers
Other information, such as information that does not directly fit within one of the categories defined by the CCPA, including the contents of communications you send to us by phone, email, text, online chat, etc.	·  To provide our Services ·  For administrative purposes ·  Research ·  Marketing and advertising ·  With your consent	·  Service providers ·  Affiliates  ·  Data analytics providers

 

B. Sensitive Personal Information

 

We may collect, use, and disclose sensitive Personal Information for business purposes consistent with applicable laws, as identified below.  Where we transfer applicable sensitive Personal Information to recipients, such as our service providers, we do so for the same business purposes described below.  These examples may vary depending on the nature of your interactions with us.

Category of Sensitive Personal Information	Purposes for Collection, Use, or Disclosure	Categories of Recipients to Whom Sensitive Personal Information Is Disclosed for a Business Purpose
Social security, driver’s license, state identification card, or passport number(s)	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Precise geolocation (location within a radius of 1,850 feet)	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Personal Information that reveals a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Contents of mail, email, and text messages except those for which we are the intended recipient	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Personal Information that reveals a consumer’s genetic data	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
The processing of biometric information for the purpose of uniquely identifying a consumer’s health	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Personal Information collected and analyzed concerning a consumer’s health	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation	·  To provide our Services ·  For administrative purposes ·  To create de-identified and/or aggregated information ·  With your consent	·  Service providers ·  Affiliates

C. Disclosing Your Personal Information 

Please see “How We Disclose Your Personal Information” above.

D. Sources of Personal Information 

Please see “Personal Information We Collect” above.

E. How Long We Keep Your Personal Information 

Please see “How We Disclose Your Personal Information” above.

F. Sharing of Personal Information 

We may share or sell the following categories of Personal Information with third parties for the purposes of cross-context behavioral or targeted advertising:

•       Identifiers
•       Internet or other electronic network activity
•       Geolocation data
•       Commercial information

The third parties to whom this Personal Information was shared or sold are advertisers and analytics vendors.  

We offer you the ability to opt out of sales and sharing of your Personal Information as set forth in the “Right to Opt Out of Sales and Sharing of Personal Information” section below.  

We do not have actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age. 

G. California Privacy Rights

If you are a California resident, you are entitled to the following rights. To exercise any of these rights, please submit a request by email to suport@color.com. Please note that if you submit a request to know, request to delete, or request to correct, you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.  

Right to Know. You have the right to know what Personal Information we have collected about you, which includes: 

•     The categories of Personal Information we have collected about you, including: 
  •     The categories of sources from which the Personal Information was collected;
  •     Our business purposes or commercial for collecting, selling, or sharing Personal Information;
  •     The categories of recipients to which we disclose Personal Information;
  •     The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information; 
  •     The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.
• The specific pieces of Personal Information we have collected about you.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. 

Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out of cookie-based sales and sharing, please contact support@color.com.

If you choose to use the GPC browser signal, you will only be opted out of online sales or sharing of Personal Information, and will need to turn it on for each browser you use. To submit a request to opt out of offline sales and sharing which would not otherwise be controlled by GPC, please contact us as provided below.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA. 

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.

H. Notice of Incentive Programs

We may offer referral programs or other incentivized data collection programs in compliance with applicable laws. For example, we may offer incentives to you such as gift cards in connection with these programs, wherein you provide your Personal Information in exchange for a reward, or provide Personal Information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary.

I. California “Shine the Light” 

We do not share Personal Information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. California residents may request information about our compliance with this law by contacting us at privacy@color.com. 

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

We do not sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

11. SUPPLEMENTAL NOTICE FOR CERTAIN INTERNATIONAL COUNTRIES

A. Supplemental Notice for Canada

This Supplemental Notice for Canada only applies to our processing of personal information that is subject to the applicable data protection laws of Canada.

• Security of Your Information. The files and records containing your personal information will be kept in our offices and/or on our servers or those of our service providers, and only those employees that require it for the purposes of their duties will have access to these files.
  

• International Transfers and Access. Personal information may be accessible to the courts and the law enforcement and national security authorities of the United States. To obtain more information about Color’s policies and practices with respect to service providers outside of Canada, please contact us as set forth in Contact Us below.

12. CHILDREN’S PRIVACY

The Site and collection of Personal Information are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children without parent/guardian consent.

If you are a parent or guardian and believe your child has uploaded Personal Information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child under 13 (or other age as required by law) has provided us with Personal Information in violation of applicable law, we will take measures which may include deletion of any Personal Information, unless we have a legal obligation to keep all or a portion of it, and terminate the child’s account, if applicable.

13. OTHER PROVISIONS

Vendor Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing Personal Information to other websites or applications is at your own risk. 

Supervisory Authority. If your Personal Information is subject to the applicable data protection laws of the European Economic Area, Switzerland, the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your Personal Information violates applicable law.

• EEA Data Protection Authorities (DPAs)
• Swiss Federal Data Protection and Information Commissioner (FDPIC)
• UK Information Commissioner’s Office (ICO)

14. CONTACT US

Color is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Color Health, Inc.
Attention: Legal Department
831 Mitten Rd.
Burlingame, CA U.S.A., 94010
Email: privacy@color.com