Kit Privacy Policy

Last Updated: 08/15/2020

INTRODUCTION 

At The Kit Company (“Kit”), we value our relationship with you and are committed to protecting your Internet privacy through our compliance with this privacy statement (“Privacy Statement”). In this Privacy Statement, we want to tell you what data we collect, what we use it for, and when this data may be disclosed. 

This Privacy Policy applies to all personal information (“Personal Information”) collected during any written, electronic, and oral or written communications or collected online which include: 

● The website located at www.kit.com, and all corresponding webpages and websites that link to this Privacy Statement (the “Site”); 
● Any mobile, web, console, desktop and other applications you download from this Site, which provide dedicated non-browser-based interaction between you and this Site (the “Applications”);
 ● When you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Statement; and 
● Via our Health Consultants and Labs; 

The Site and the Mobile Applications, and the aforementioned interactions, support the provision of laboratory services to users based in the United States (the “Services”). 

The availability of the Services is based on your request for an insurance evaluation from a life insurance company (the “Company”).

Before using our Services, please carefully read our Terms of Use, which you can view here: https://www.kit.com/terms-of-use/ and this Privacy Statement. By using the Site, you consent to the collection and use of the Personal Information in accordance with this Privacy Statement and our Terms of Use. If you do not feel comfortable with any part of this Privacy Statement or our Terms of Use, you should not use or access our Services. If there is a conflict between the terms of this Privacy Statement and the Terms of Use, this Privacy Statement will prevail. 

We may modify this Privacy Statement at any time, without prior notice, and changes may apply to any Personal Information we hold about you, as well as any new Personal Information collected after the Privacy Policy is modified. If we make changes, we will notify you by revising the date at the top of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this Privacy Statement to check for any changes. If you continue to access or use our Services after we update this Privacy Statement, you acknowledge your acceptance of the updated Privacy Policy. 

We also may provide additional "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your Personal Information. 

1. PERSONAL INFORMATION WE COLLECT 

We collect Personal Information when you use our Services. Personal information is any information that means any information that may be used to identify yourself. Personal Information is information that relates to you, identifies you personally or could be used to identify you including, but not limited to: your name, mailing address, email address, date of birth, or any other information defined as “Protected Health Information” under HIPAA/HITECH laws and regulations. In many cases, you will be asked to enter this information directly. In other cases, that information may be pre-filled if we have received that information from the Company.

I. Information You Provide to Us 

The Personal Information we collect on or through our Services may include: 

● Information that you provide in order to use the Services on our Site. This includes information provided at the time of registering to use our Site, posting or asking questions, or requesting further services. You may also provide further information when you report a problem with our Site. 
● Kit records and maintains certain communications (such as emails, phone calls, and virtual video consultations). These communications are personal and private, and unless you explicitly agree to the use and disclosure of such communications, we will not use or disclose these communications except as provided for in this Privacy Statement. 

II. Information Collected from the Company

To enable your use of the Services, you authorized the Company to provide us with your Personal Information so we can verify your eligibility to use and provide you with the Services. 

III. Information Collected Automatically
 
Device, OS Version and Computer: When you download and use our mobile apps, we may collect information on the type of device you use, device identifiers, and operating system version. When you use the Site on your computer, we may also collect hardware information about your computer. 

Log Files: As with most websites, we collect and store in log files the Internet Protocol address of the computer you are using and other system characteristics (for example, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access the Site and Services, and the Internet address of the website from which you directly linked to the Sites.) We may combine this automatically collected log information with other information we collect about you. We may use all of this information to analyze trends, administer the Services, and monitor service traffic and usage patterns for internal security purposes and to help make the Service most useful to you and other users.

Location Based Information: We may also collect your location based information for the purpose of enforcing our Terms of Use and to provide you with the Services. 

IV. How Your Information May Be Used and Disclosed 

Surveys: Your Personal Information may be used and disclosed so that we can survey you to evaluate and improve the Services. Your participation in any surveys and the provision of any requested Personal Information is completely voluntary. Such third-party service providers may not use or disclose your Personal Information other than to provide survey related data to us. 

Service Providers: Kit may work with trusted service providers in making the Services available to you. When you sign up for the Services, we may share your Personal Information only as necessary for the Service Provider to provide us with related services, and subcontracted services for Kit. These Service Providers are not allowed to use your personal Information except for the purpose of providing services to us, and are obligated to protect your Personal Information. 

To Company: We will provide results from your laboratory tests and any other Personal Information provided to us to the Company, for the purposes of your insurance evaluation. 

Your Personal Information may also be used and disclosed to: 
● Operate, provide, improve, administer, monitory any services or products that are requested by you or Company in connection with the Services.
● Help us decide what services will meet our users’ needs.
 ● Communicate with you about support or service issues. 
● Enforce our Terms of Use. 
● Diagnose problems, administer the Sites or Applications and to detect and protect against error. 
● Comply with laws (e.g., if we are required to comply with a subpoena or similar legal process). 
● Notifying you about changes to our Site, our Terms of Use, terms or any products or services we offer or provide though it. 
● Sending you emails about new services we offer.
● Saving your user account, registration and profile data or other Personal Information (so you do not have to re-enter it each time you visit or use the Services). 
● Tracking your return visits to and use of the Services. 
● For research purposes, for marketing/promotional purposes and to provide anonymous reporting for internal and external clients and business partners. 
● Accumulating and reporting aggregate, statistical information in connection with the Services and user activity.
● Keeping you secure and safe while using our Services, which requires us to process your Personal Information to combat spam, malware, malicious activities or security risks. 
● Maintaining legal and regulatory compliance. 
● Protecting you, others and our business, including, without limitation, using information for fraud prevention. 
● Facilitate a merger, acquisition, or sale of all or a portion of our assets, You will be notified by email and/or a prominent notice on the Sites of any change in our current ownership, uses of your Personal Information, and choices you may have regarding your Personal Information. 
● For any other purpose disclosed to you prior to you providing us your Personal Information or which are reasonably necessary to provide the Services or other related products and/or services requested. We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please email us at privacy@kit.com to opt out. 

V. Your Choices and Access to Personal Information 

● Update or Correct Personal Information: You can update or correct some of your Personal Information through your account profile. To the extent that you require additional assistance updating or modifying your Personal Information, you may email privacy@kit.com, and we will respond in a reasonable time frame.
● Remove Personal Information and Account Deactivation: You may request that we remove all your Personal Information and deactivate your account by emailing privacy@kit.com, and we will respond in a reasonable time frame. 
● Storage of Personal Information: Your Personal Information will be maintained and stored in accordance with the requirements agreed to by Kit and the Insurance Company, unless you request Kit to Remove (as defined below) your Personal Information by contacting privacy@kit.com. We will retain your Personal Information for as long as your account is active, as needed to provide you with services, and as necessary to comply with legal obligations, resolve disputes, and enforce our agreements. 
            ○ For the purposes of this Privacy Statement, "Removed" shall mean that your data has been de-identified in accordance with the HIPAA Privacy Rule, so the data is no longer associated with any identifier of you and cannot be re-identified in accordance with the HIPAA Privacy Rule. For more information on the specific requirements that Kit, you may contact Kit at privacy@kit.com . 

2. TRACKING TECHNOLOGIES AND ANALYTICS 

In relation to providing the Services, we may use technologies such as cookies, web beacons, tags, scripts and other storage technologies to automatically collect or receive information (“Tracking Technologies”) as you interact with the Services and to personalize your experience with our Services. 

I. Cookies 

Cookies are small data files that we transfer to your device to collect information about your use of the Sites or Applications. Cookies can be recognized by the website that downloaded them or other websites that use the same cookies. We use first-party and third-party cookies for the following purposes: to make our Services function properly, to improve our Services, to make login to our Services easier (such as by rememberingyour User ID), to recognize you when you return to our Site, to track your interaction with the Services, to enhance your experience with the Services, to remember information you have already provided, to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Services. The length of time a cookie will stay on your browsing device depends on whether it is a "persistent" or "session" cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted (i.e. after you have finished browsing). We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from Kit. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party's website for more information on how they use cookies. The following types of cookies are used on our Services:

 ● Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some Services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled. 
Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services. 
Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies. 
Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below. 

II. Analytics 

We may use third-party Service Providers to monitor and analyze the use of our Service. Presently we use Google Analytics and Amplitude and Amazon Web Services.

III. Other Tracking Technologies 

We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Services, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Services for the same purposes. 

Pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

IV. Managing Cookies via Browser Settings 

You can control the use of cookies at the individual browser level. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. If you reject the use of cookies, you may not be able to use some or all portions of functionalities of the Sites. You can exercise your preferences in relation to cookies served on our Sites by taking the steps outlined below. 

First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org

Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies go to http://www.aboutads.info/choices. Once you click the link you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networksand similar entities that use these technologies, please see http://www.aboutads.info/consumers. 

Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Site. If you do not want Flash Cookies stored on your computer, you can adjust the settings of your Flash player to block Flash Cookies storage. Flash cookies are not managed by the same browser settings as are used for browser cookies, but may be managed here: http://www.macromedia.com/support/documentation/en/flashplayer/help/setting s_manager07.html. 

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by adjusting your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending an email stating your request to privacy@kit.com You can also opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance (http://optout.aboutads.info/) or the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1). In addition, on your iPhone, iPad or Android, you can change your device settings to control whether you see online interest-based ads. 

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences.

More information may be found for the following browsers here: 
Google Chrome
Internet Explorer
Mozilla Firefox 
Safari (Desktop) 
Safari (Mobile)
Android Browser
Opera (Desktop)
Opera (Mobile)

V. Do Not Track 

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Sites do not currently process or respond to “DNT” signals.

 3. MARKETING COMMUNICATIONS 

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

If you do not wish to have your email address or other contact information used by us to promote our own or third parties’ products or services, you can opt-out by logging into the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending an email stating your request to privacy@kit.com. You may also choose to stop receiving our promotional or marketing communications by following the “unsubscribe” instructions included in these messages. This opt out does not apply to information provided by us as a result of a product purchase, warranty registration, product service experience or other transactions. 

Please note that "opt-out" and "unsubscribe" requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your Information shall remain subject to the prior privacy settings. Additionally, you should be aware that any Information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law.

4. YOUR CALIFORNIA PRIVACY RIGHTS

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), below is a summary of the “Personal Information” categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect your Personal Information, where we obtain the Personal Information, and the third parties with whom we may share your Personal Information. We do not generally sell information as the term “sell” is traditionally understood. However, if and to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those implemented specifically for interest-based advertising, we will comply with applicable law as to such activity.

We generally collect the following categories of Personal Information about your when you use our Site or services:

● identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, software, and identification numbers associated with your devices
● protected classifications, such as gender
● commercial information such as records of products or services purchased, obtained, or considered by you
● health information
● internet or other electronic information regarding you browsing history, search history, the webpage visited before you came to our Site, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information
● your geolocation, to the extent you have configured your device to permit us to collect such information
●audio recordings of your voice to the extent you call us, as permitted under applicable law
● inferences about your preferences, characteristics, behavior and attitudes.

For more information about the Personal Information we collect and how we collect it, please refer to Sections 1 and 2, above.

We collect your Personal Information for the business purposes described in Section 1, above. The CCPA defines a “business purpose” as the use of Personal Information for the business’s operational purposes, or other notified purposes, provided the use of Personal Information is reasonably necessary and proportionate to achieve the operational purpose for which the Personal Information was collected or another operational purpose that is compatible with the context in which the Personal Information was collected.

The categories of third parties with whom we may share your Personal Information are listed in Section 1, above.

Privacy Rights

If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our network systems.

● Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
● Right to Know. You have the right to request in writing: (i) a list of the categories of personal information, such as name, address, email address, that a business has disclosed to third parties during the immediately preceding calendar year for the third parties' direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, you have the right to request: (i) the categories of personal information we have collected about you, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual. You have the right to request a copy of the specific Personal Information we collected about you during the 12 months before your request.
● Right to Delete. You have the right to request us delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.

To assert your right to know or your right to delete your Personal Information, please contact according to the “Contact Information” section below. To verify your identity, we may ask you to verify Personal Information we already have on file for you. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

● Right to Opt-Out of Selling. As described in this Privacy Policy, in certain situations we may share your Personal Information with our partners, third parties or affiliates for our marketing or other purposes. To the extent such sharing is considered a “sale” under the CCPA, as a California resident you have the right to opt-out of such sharing. If you would like us to no longer share your Personal Information in this way, please email privacy@kit.com.. If you opt-out, we may be unable to offer you some of our Services which require sharing of Personal Information.

In addition, California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes (if applicable). To make such a request, please send an email or write to us (see Contact Information below). 

5. DATA SECURITY

The security of your Personal Information is important to us. All communication between you and our servers are encrypted. We take commercially reasonable measures to secure your personal Information once it is on our services. Our data centers are both physically and electronically secured. Access to your Personal Information is encrypted and limited to business needs. 

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. You should not share your password with anyone. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site.

Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

6. INTEGRATION OF THIRD-PARTY PLATFORMS AND SERVICES

The Services may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies, including Third-Party Services. The Services may also feature advertisements from these companies. We are not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Services or for the privacy practices of third party advertising companies. Once you leave this Services via a link, access a third-party service or click on an advertisement, you should check applicable privacy policies to determine, among other things, how related companies process Personal Information they may collect about you. This Privacy Policy applies solely to information collected by Kit.

7. NO CHILDREN’S PERSONAL INFORMATION 

You must be at least eighteen (18) years of age to use the Sites. We do not knowingly request or collect Personal Information from any individual under the age of 18. If we obtain actual knowledge that a user is under 18 years old, we will use our best efforts to require the user to close his or her account and to remove that user’s information from our database. Please notify us if you know of any individuals under the age of 18 using the Sites so we can take action to prevent such access. 

8. CONTACT INFORMATION

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: privacy@kit.com.