Privacy Policy


Last Updated: May 2021


This Privacy Policy (“Policy”) is part of the Phyla privacy program and describes how we collect, use, and disclose your personal information and how your personal information can be reviewed and corrected when necessary. Phyla reviews this Policy annually, or as needed in response to changing circumstances. Please check the “Last Updated” date above to know when this Policy was updated.


Contents


Who We Are and What We Do
What Information Do We Collect?
How Do We Collect Personal Data?
Cookies and Other Tracking Technologies
What Do We Use Personal Information For?
Who Do We Share Personal Information With?
How is Personal Information Secured?
Links to Other Websites 
When Do We Dispose Of Your Personal Information?
Your Rights
Children’s Personal Information
Jurisdiction
Contact Us



Who We Are and What We Do


Phyla provides you with services and insights to help you manage your gut health. This means collecting information about you through nutrition and symptom logging and our home microbiome test kits that are used by our laboratory partners to find out about your gut health and beyond. The information you provide to us enables us to provide you with a curated wellness information platform and personalized lifestyle recommendations. Phyla is not a medical services provider, although some of our reports have been designed with input from health professionals to help you manage your gut health with your health team. You should consult with your physician if you have any specific concerns about your health. 


At every stage of your experience with us,  we take steps to protect your personal data so that you can feel confident using our platform and get the insights you need to lead a healthy and comfortable lifestyle. 
This Privacy Policy (“Policy”) will describe the kinds of personal data we collect, use and disclose and the choices you have with respect to how we handle your data. In addition to protecting your privacy, we are committed to ensuring the security of our processing of personal and confidential data.


This Policy may change from time to time. If there is a substantive change we will notify registered users and customers of the change. Please note the date that this Policy was last updated for your records if you have concerns.


What Information Do We Collect?


For the purpose of this Policy, “personal information” is information about you or information that could easily be used to identify you. 


The personal information that we collect may include the following categories of information:

 

We do not collect personal information to provide medical services, although you may choose to provide the reports we generate as part of our service to your health care team.


How Do We Collect Personal Data?


We collect information directly from you through our Websites, Apps, and Services. We may also collect raw data test results from our test laboratory that you submit the microbiome test kit to as part of our Services. 
When you land on the Phyla Website, certain technical information is collected, such as your IP address. We may ask you to provide information by completing forms or otherwise requesting information from you, such as journaling or logging daily activities or symptoms, either on our Website or App.  When you download, install and use our App on your mobile device, Phyla automatically receives technical information from your device.

 

Cookies and Other Tracking Technologies
 

Our Website, like most other commercial websites, uses cookies and similar technologies. These are files installed on your computer hard drive or web browser to collect information such as your language of preference, browsing history and browser type and version for the primary purpose of optimizing your experience on our Website. We also use cookies to compile aggregate data about site traffic and site interactions to offer better site experiences and tools in the future. When you first visit our Website, and on subsequent visits, you may manage your cookie preferences and accept or reject our use of cookies, except for those cookies that are strictly necessary for the Website’s operation. You can choose to have your computer warn you each time a cookie is used, or you can choose to disable all cookies in your browser. Disabling cookies on your browser could adversely affect your browsing experience on our Website.


What Do We Use Personal Information For?


We use the information you provide to us to create your account, enable your activity within our Services, and to develop, enhance, and improve our Services and your experience. We also use this data for internal purposes, such as product research, analytics, and innovation. 


We may use your personal information to verify your identity, assist with the identification of users, reply to your inquiries, determine appropriate services, and for loss prevention and anti-fraud purposes. From time to time, we may use your personal information to send important notifications, such as information related to your Subscription Services, In-App purchases, or changes to our terms and policies. 


We may use de-identified data or aggregated information derived from your personal information, but which does not identify you, to improve our Services and for other business purposes, such as product research or analytics by ourselves or with partner organizations. In doing so, we will take steps to ensure that individuals cannot be re-identified. We use information held about you in the following ways:

 

  • To ensure that content provided by the Services is presented in the most effective manner for you and for your computer or other devices.

  • To ensure the quality of the data and recommendations in the Service.

  • To provide you with customer service communications.

  • To carry out our obligations arising from any agreements entered into between you and us.

  • To notify you about changes to the Services.

  • To understand your interactions with our Services including location or time-related services as well as normal service and resource usage.

  • To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as postal/zip code, province/state or country).

  • If you are an existing customer or if you have contacted us to inquire about our Services, we may contact you by electronic means (e-mail or in-product communication) with information about products and services.  

  • To optionally provide you with information, products or services related to Phyla that will facilitate your engagement with the Services.

  • To allow you to participate in interactive features of the Services when you choose to do so.

  • We may use de-identified data for research purposes, possibly with qualified research partners (e.g. What is the impact of a particular nutrient or lifestyle choice on the microbiome) to improve our services and the recommendations we provide you.

  • We may contact you to ask if you are willing to participate in prospective clinical research studies. We will only provide your contact information to prospective researchers with your consent.

  • We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

  • The research we do with your de-identified data could lead to the creation of commercial products that could eventually be protected by patents or other intellectual property rights. In such cases, you will not be able to derive any financial benefit.


We will not use your personal information for purposes other than those for which it was collected, except with your consent or as required by law. 


Who Do We Share Personal Information With?


In general, we do not disclose information about you. We may use third parties and service providers to provide our Services and support our App and Website, but only as required for normal business operations and to deliver the Services we provide to you except as required by law. 


If you request a microbiome test kit it will be provided to you by a laboratory under contract to us. This means that they send you the kit, receive the kit that you send them, do the analysis of the kit, and provide us with the result of the test. The laboratory will not use this data for any other purpose other than providing the kit to you and the production of raw data to us for the provision of our service to you. All raw data analysis is performed by Phyla.


When you make a payment for services, such as ordering a microbiome test kit, we use third party payment processors. When you choose to make a payment you will be asked to create, or log into an existing account if you have one, with the payment processor. The payment processor will collect and use your credit card or banking information and provide us with a transaction tracking number to validate that payment has been made. We do not collect, use, or disclose your credit card or banking information. Your account with us will be linked to your ID with the payment processor so that we may receive confirmation of your payments and they proceed to fulfill your orders with us.


Your de-identified data may be used for research purposes. Phyla will use various de-identification techniques to ensure that your privacy is protected while your data is used for research purposes. This means that medical or commercial research organizations are able to do research on microbiome data and health metrics. While you will not benefit directly from any given research project, Phyla may be able to recommend improved treatment protocols or lifestyle changes as a result of this research.


We do not disclose personal information to companies that host advertisements on our behalf, but we may provide them with aggregate information about our users (for example, we may inform them that: “500 men aged under 30 have clicked on their advertisement on any given day”). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.


How is Personal Information Secured?


We have implemented safeguards appropriate to the sensitivity of your data. These include administrative safeguards such as security policies and security training, physical safeguards to limit access to data centers and other facilities, and technical safeguards such as access control and encryption. These safeguards are reviewed and updated on a regular basis to ensure that your information is protected. Please note that no computer system or computer communication can be perfectly secure, and keep this in mind when sharing information with us or our providers.


Links to Other Websites 


This Policy applies only to our Website, App and Services and does not apply to other websites not operated or controlled by us that may be linked to by our Website, App or Services (“Third Party Sites”). The policies and procedures we described here do not apply to Third-Party Sites. The links to Third Party Sites do not imply that Phyla endorses or has reviewed the Third-Party Sites. We suggest that you review the privacy policies on the Third Party Sites. 


When Do We Dispose Of Your Personal Information?


We will retain personal information only so long as it is useful for the provision of our Services and support our App or Website. When we no longer have a business purpose for retaining your personal information will securely destroy the information. Note that information that is anonymized and aggregated may be retained, but this information does not allow you to be identified.


Your Rights


You may have certain rights with respect to the processing of your information. This section of the Policy describes those rights and how you may exercise them should you choose to do so. 

 

  • Right to access, correction, and deletion: As a general rule, you see all of the personal information that we have about you when you access our Service or use or App, and can correct or delete the data as allowed in the App. Some data, such as the results of a laboratory analysis cannot be changed by you and some data may only be deleted if you decide to delete your account and the App from your device. If there are images or elements that you want to delete, you may contact us directly to request the deletion.

  • Right to data portability: The App and the Services are designed to enable you to share your information with your health providers or others from whom you seek advice.

  • Right to complain or object: If, at any time, you have a question or concern about how we protect your privacy that is not addressed in this Policy, please send us an email so that we can contact you to follow up

 

Children’s Personal Information


We do not knowingly collect personal information from children under the age of 13. If you are under the age of 13, please do not submit any personal data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided personal data to Phyla through the Services, please contact us, and we will endeavor to delete that information from our databases.


Jurisdiction


We are a Canadian company. Phyla uses data centers and computing infrastructure in Canada. Some of our service providers, such as the laboratory service used to analyze your microbiome data, are located in Europe and the United States and will be subject to privacy and data protection laws in their countries.
This Policy and our processing activities are intended to comply with the applicable Canadian privacy laws. In the course of providing our services, personal information may be processed in other jurisdictions such as the European Union or the United States. The data protection laws of those jurisdictions may differ from those in Canada. While your personal information is in another jurisdiction, the laws of that jurisdiction may apply to your information.


Contact Us


If you have any questions about this Policy or how you may exercise your rights beyond those set out above, please send an email to support@phyla.ai or mail us at:


400 rue Montfort, CP12, Local J-2340 
Montreal, QC H3C 4J9
Canada 

You should know that before we respond to any emails or requests regarding your privacy we may have to take steps to verify that the person making the request is actually you. That may mean requesting personal data about you to confirm your identity.

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