Aavia Privacy Principles
Last Updated: March 1, 2021
At Aavia, we believe your body is your business. This should be the norm, not an exception.
We take your privacy seriously and want you to understand how we use, collect and share your personal information. Your personal information includes health information about your body and state of mind that you provide to Aavia while using our services, such as information about your birth control pills and your menstrual cycle. We have invested heavily, and will continue to invest, in features and security to protect the privacy and security of your health information and other personal information. We continually evaluate our privacy practices to ensure that we treat your personal information in compliance with applicable privacy laws.
- AAVIA MEMBERS CONTROL THEIR PERSONAL INFORMATION
We believe you should be in control of your personal information. Consistent with this belief:
- We will delete your personal information if you ask us to, including if asked when you cancel your membership.
- We will provide you with access to your personal information if you ask us to, including if asked if you cancel your membership.
- We will NOT share your identifiable health information with others except to the extent necessary to provide our services. Our service providers are contractually bound to only use your health information to provide services to us and are prohibited from sharing your health information with third parties. For example, we may use a cloud service provider to store health information you provide while using our app.
- AAVIA DOES NOT SELL MEMBER PERSONAL INFORMATION
Our business model is to provide highly valuable product experiences and services to our members in exchange for membership fees. As such, we do not sell your health information or other personal information. This is our promise.
We may use personal information other than health information to help us identify and connect with other people who may be interested in becoming members.
- AAVIA MAY SHARE AGGREGATED OR DE-IDENTIFIED HEALTH INFORMATION TO CREATE BETTER EXPERIENCES FOR OUR MEMBERS
We may share aggregated, de-identified, or pseudonymized personal information, including health information, that does not identify particular individuals for research, to understand trends and habits, for advertising, and for other purposes. We believe we have a responsibility to create an ever-better experience for our members by identifying and sharing cutting edge insights. We will always look to provide new content and product features, improve and customize our services, and develop thought leadership in the area of hormone health without identifying you.
We know privacy and security are important to you and that you are trusting us with intimate health information. We are committed to making Aavia the best platform to understand and optimize your health based on your hormone cycle. We will continue to be transparent about our privacy and security practices as we grow alongside our membership.
Last Updated: March 1, 2021
- PERSONAL INFORMATION WE COLLECT
- HOW WE USE YOUR INFORMATION
- HOW WE DISCLOSE YOUR INFORMATION
- YOUR PRIVACY CHOICES AND RIGHTS
- SECURITY OF YOUR INFORMATION
- INTERNATIONAL DATA TRANSFERS
- RETENTION OF PERSONAL INFORMATION
- SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
- SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
- CHILDREN’S INFORMATION
- OTHER PROVISIONS
- CONTACT US
2. PERSONAL INFORMATION WE COLLECT
We may collect the following personal information that you provide to us.
- Account Creation. If you create an Account, we will ask you for your name and email address. In addition, to access certain features of the Services, we may ask you to provide your address and user profile information.
- Health Information Collected in Connection with Your Use of the Services. When you use the Services, we may collect personal information related to your health including, but not limited to, the brand of birth control pill prescribed to you, the time of day each pill is taken, the number and nature of pills in each pack or packet of birth control pills, the refill schedule of your prescription, and information about your body and state of mind, such as your menstrual cycle and mood (collectively, your “Health Information”).
- Purchases. If you make a purchase with Aavia, we will record the personal information and details associated with the transaction. For example, if you place an order through the Services, we will collect the items you purchase, your billing and shipping address, phone number, and payment information. Please note that we use a third-party service provider to collect and process payment card information. Aavia does not directly collect or store any payment card information, but it may receive information associated with your payment card information (e.g., your billing details).
- 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, apply for a job, or otherwise communicate with us.
- Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
- 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, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) 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.
- Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
- Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
- Campus Brand Ambassadors Program. We may collect personal information from individuals who sign up to serve as our Campus Brand Ambassadors, including name, email, shipping address, phone number, birth date, graduation year, university name and/or picture. We may also collect names, emails, phone numbers, school names, graduation year and Health Information from individuals who choose to participate in our campus health sessions hosted by our Campus Brand Ambassadors.
- 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 reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
We may collect personal information automatically when you use our Services:
- Automatic Data Collection. 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. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they refer you to our services or tag you on social media.
The information we collect automatically when you use the smart pill case and related Services may also include Health Information such as your pill-taking habits and the number of pills remaining in the smart pill case.
- Location Information. We may collect mobile device location information to help connect your mobile device to the smart pill case.
- 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 and improve security or that 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 websites.
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:
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
3. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below. However, we believe that your body is your business. This is why we put policies and procedures in place designed to limit the use of your Health Information only to provide you with the Services.
A. Provide Our Services or Products
We use your information to fulfil our contract with you and provide you with our Services, such as:
- 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;
- Processing applications if you apply for a job we post on our Services; and
- Managing and fulfilling orders.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- 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;
- Short-term, transient use, such as contextual customization of ads;
- 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 policy;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We do not use any identifiable Health Information for advertising or marketing purposes. Your Health Information is yours. We may use personal information other than your Health Information (such as your email address), or de-identified and/or aggregated Health Information, to tailor and provide you with content 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, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
- De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified Health Information, demographic information, information about the device from which you access our Services, or other analyses we create. This de-identified and aggregated information will not identify you and may be used for marketing and advertising purposes, and/or for research purposes.
- Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services or through our Campus Brand Ambassador Program. Our referral services may 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).
4. HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third 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 third parties with whom we may share your information are described below.
- Service Providers. We may share your personal information, including your Health Information, with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
- Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services. We do not share your Health Information with our business partners.
- Affiliates. We may share your personal information, including your Health Information, with our company affiliates.
- Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities when you visit our website and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” To be clear, we do not share your identifiable Health Information with any third-party advertising partners. If you prefer not to share any of your personal information with third party advertising partners, you may follow the instructions below.
- APIs/SDKs. We may use third-party 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 any information we store associated with you to external parties 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.
We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.
- Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.
- 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 approximate location-based information about your mobile device via our mobile application to help connect your mobile device to the smart pill case. You may opt out of this collection by changing the settings on your mobile device.
- “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 Interest-Based 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 are not 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 Personal Information about you, 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 (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;
- Request Restriction of or Object to our processing of your personal information; and
- Withdraw your Consent to our processing of your personal information.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
6. SECURITY OF YOUR 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 processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Aavia has collected about them and whether Aavia disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Aavia
Category of Third Parties Information is Disclosed to for a Business Purpose
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: A name, address, telephone number, insurance policy number, education, employment, employment history, payment information.
Protected classification characteristics under California or federal law
Examples: Age (40 years or older), citizenship, marital status provided by job applicants and employees.
Examples: Records of services or products purchased.
Examples: Health Information collected by Aavia during your use of the Services.
Internet or other electronic network activity
Examples: Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
Examples: Coarse location information inferred from your IP address and mobile device location collected to connect your mobile device to the smart pill case.
Examples: Electronic data describing your use of the smart pill case or other Services.
Professional or employment-related information
Examples: Current or past job histories provided by job applicants.
Inferences drawn from other personal information to create a profile about a consumer
Examples: Inferences about your menstrual cycle derived from your Health Information.
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, Aavia does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Financial Incentives / Refer-a-Friend Programs. As described above in How We Use Your Personal Information (“Share Content with Friends or Colleagues”), we may offer referral programs, such as our Campus Brand Ambassador Program. We may offer incentives to you such as discounts or promotional credit in connection with these programs, wherein you 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 referral programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of the referred party’s data to us depends on whether the referred party ultimately uses our Services. Said value will be reflected in the incentive offered for each referral.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in Contact Us below.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as set forth in Contact Us below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently 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 below.
11. CHILDREN’S INFORMATION
General Age Limitation. The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 years old. If you learn that anyone under 13 is using the Services, you may contact us as set forth in Contact Us below and we will promptly take steps to delete such information and/or delete her account.
Age Limitation for European Union Residents. If you are a resident of the European Union, due to legal requirements, you must be at least 16 years old to use the Services. We do not allow the use of the Services by European Union residents younger than 16 years old. If you are aware of anyone under 16 years old using the Services, you may contact us as set forth in Contact Us below and we will promptly take steps to delete such information and/or delete her account.
12. OTHER PROVISIONS
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party 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 third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
13. CONTACT US
111 Lawrence St.
Brooklyn, NY 11205