Privacy Policy
We value and Respect Your Privacy
Tiny understands the importance of your private information and appreciates your decision to share that information to us. We strive to be open and clear with how we manage the data and information you generate and/or provide in connection with our Services; that includes, without limitation, your Personal Information, Payment Information, and SI (collectively, your "Private Information").
This Privacy Policy governs how Tiny collects, stores, and uses your Private Information, and other data and information relating to you and your use of our Services. Please review this Privacy Policy very carefully – and if you find anything in here that doesn't make sense or seem right to you, please write to us at legal@tinyhealth.com.
Our Terms incorporate this Privacy Policy by reference in its entirety; capitalized terms set forth in the Terms, and their respective definitions, apply equally to this Privacy Policy. By accessing our Services and agreeing to our Terms, you accept all terms and conditions herein.
If you do not accept this Privacy Policy in its entirety, you must stop using our Services and cease all further use, effective immediately.
1. Tiny Collects Data and Information about You and How You Use Our Services.
In order to provide our valuable, groundbreaking Services, Tiny needs to know about you and how you use our Services. Tiny accordingly reserves the right to require you to provide Private Information, a Sample and/or other information or data in order to use our Services.
More specifically, without limitation, if you wish to receive such Services as a specimen collection, Analysis Results, a follow-up consultation, and/or customized information –you may be required to provide Personal Information (e.g. first and last name, email address, date of birth, mailing address and zip code, ethnicity, and race), SI (e.g. medical history, present symptoms, self-reported information regarding you and/or your child) and/or Payment Information. You further acknowledge and agree that – in order to receive such Services as the aforementioned – you may be required to provide a Sample, genetic data, and/or SI specifically concerning your Sample.
You should expect Tiny to collect anything you provide in connection with our Services. Tiny and our Affiliates reserve the right to collect any and all Samples, text, data, photos, video, audio, images, and multimedia you create, upload, export, share, generate and/or otherwise provide in connection with our Services. This includes, without limitation the collection of Private Information. This also includes, without limitation, a reservation of rights to record, save, and memorialize all communications (including, without limitation, any calls, text/SMS messages, and emails from you) for the purposes of providing our Services, offering and improving customer service, assuring quality control, establishing evidence in a dispute, and/or enforcing our Terms.
Tiny often makes use of third-party partners and providers to facilitate our operations and Services. Tiny and our Affiliates reserve the right to utilize one or more third party providers and partners to: (a) facilitate our specimen collection services; (b) transport and/or collect the Sample(s) you provide; (c) process and/or derive data and information from your Sample(s); (d) provide your Analysis Results; (e) gather SI and other information from you (including without limitation self-reported information); (f) engage in a consultation and/or the provision of customized information in connection with your Analysis Results; (g) provide you with customer service; (h) facilitate account creation, management, maintenance, and login; (i) enable a transaction in connection with our Services; (j) bolster the safety and security of systems, servers, accounts, technologies, data, and information arising out and/or relating to our Services; and (k) otherwise facilitate our operations, our Services, and the reasonable access and use of our Services. You hereby authorize all such third party providers to collect and store your Private Information and other data and information (and your Sample, where applicable) –to the extent permitted by Tiny, and as reasonably necessary in furtherance of Services – and to communicate and transfer all such data and information to Tiny, our Affiliates, and our designated third-party providers – all of whom may collect, store, retain, and use such data and information subject to the same rights and obligations that apply to data and information received and/or collected directly by Tiny. To the extent we use such third party partners and providers to receive, collect, store, process, analyze, communicate, transmit, and/or make use of your Private Information and/or Sample, Tiny requires these partners and providers to take equivalent measures to protect the security and confidentiality of your Private Information and/or Sample.
You agree that Tiny and our Affiliates may, in our sole discretion, require you to furnish Private Information directly to a third-party service provider in order to: (a) create an account; (b) access Services; (c) use, purchase, and/or receive Services and/or products; and/or (d) communicate with Tiny and/or our third-party providers and partners.
Tiny currently utilizes third-party vendors to process Payment Methods in connection with our Services; excepting details of your transaction (e.g., time of transaction, amount) and the name on the card, our third-party payment vendors typically do not collect or store Payment Information.
In order to enhance the protection of your Private Information, Tiny collects Private Information over a secure processing server (SSL-protected, with a valid SSL-certificate). If you transact with us via direct payment gateway, your Payment Information will be encrypted through Payment Card Industry Data Security Standard (PCI-DSS).
Tiny likes to keep track of how people connect with and use our digital offerings; it helps us learn, grow, and provide the best possible experience. Tiny and our Affiliates reserve the right to automatically collect data and information about you, your device/computer, and your use of our digital Services. This includes, without limitation, information regarding: your browser type and language; your location, computer and/or device type; your operating system; your computer and/or device usage history; your browser history; the ID and IP address of your computer, device, and/or proxy server; your internet services provider and/or mobile carrier; your pathway and interactions navigating through our Site and other Services – including but not limited to what you view, when and for how long you view it, what you click and when you click it, which features you utilize and to what extent, which products or services interest or disinterest you, which products or services you decide to add to a cart, abandon, or purchase, and what you do before and after you use our Services. To the extent that you have agreed to receive communications, (e.g. text/SMS messages, emails) from Tiny and/or our Affiliates, Tiny and our Affiliates reserve the right collect data and information regarding such communications, including without limitation data and information regarding your receipt and viewing of such communications, as well as your interaction with and circulation of such communications.
Like many online companies, Tiny and our Affiliates reserve the rights to make use of tracking technologies (e.g. pixel tags, beacons, clear GIFs) to record information about how you experience and make use of our Services. Tiny and our Affiliates reserve the rights to make use of cookies and log files to track and collect data about you, your actions, and the technologies you use. To learn more about cookies, visit www.allaboutcookies.org. Please note that many phones and browsers enable you to restrict tracking technologies and/or deactivate location sharing.
Remembering all of your passwords can be a hassle – we get it! If you use credentials from a third-party service (e.g. Facebook, Google) to login or provide other information in connection with our Services, Tiny and our Affiliates reserve the right to collect data and information from that third party, to the extent you have given the third party permission to share data and information; this includes, without limitation, your contact information, online profile and user history information, information regarding your settings and preference, and information regarding your online contacts.
2. Tiny Maintains Flexibility in Storing and Retaining Your Data and Information.
It’s important for Tiny to store and retain the data and information we obtain. Tiny and our Affiliates reserve the right to store and retain any data and information that we collect from you – in any commercially reasonable manner and/or format we choose, in any location we select, worldwide, and for any duration of time.
Notwithstanding the foregoing, Tiny makes commercially reasonable efforts to process only microbial DNA contained in a given Sample, and not the genetic material of the human being furnishing the Sample. While nothing is 100% guaranteed or promised, it is our policy that neither Tiny nor any of our third-party providers derive data or information from such human DNA, unless you expressly agree otherwise.
Furthermore, Tiny doesn’t want to hold onto data and information that we no longer need or wish to possess. Tiny and our Affiliates reserve the right to delete, modify, remove, and/or destroy any data and/or information we collect – at any time, for any reason or none, without notice or cause; we maintain no obligation to preserve your data or information.
As part of a holistic effort to protect your data and information, Tiny implements various safeguards – technological, physical, and procedural. Likewise, all Private Information stored on our servers is encrypted, whether in transit or at rest, and transmitted over SSL.
3. If You Provide Your Personal Information in Connection with our Services, We Will Not Sell That Information to Third Parties for Advertising or Marketing Purposes.
We are not in the business of selling your Personal Information. If Tiny and/or our Affiliates collects your Personal Information in connection with our Services, neither Tiny nor our Affiliates will sell or transfer that information to any third party. Notwithstanding, you accept that, in the event of a merger, acquisition, asset sale (partial or total), liquidation, bankruptcy, or other change in control, your Personal Information may be considered an asset and/or otherwise subject to sale and/or transfer to a third party
We may wish to present you with advertisements and marketing. You agree that Tiny and our Affiliates may send you marketing and advertising messages on behalf of a third party (including subject to a paid arrangement). Under such a circumstance, neither Tiny nor our Affiliates will disclose your Personal Information to said third party.
Within the bounds of the law, Tiny reserves the right to obtain any information and/or data we desire from any third party we choose; provided that we comply with any restrictions imposed by that third party, Tiny may use such information and/or data as though it were provided or generated by you during the course of using our Services, subject to our Terms of Service, including this Privacy Policy.
4. Tiny Intends to Make Substantial Use of Your Data & Information.
a. Disclosure of Your Data & Information
i. Tiny needs the flexibility to disclose your data and information in order to provide our Services and facilitate Company operations. Tiny may, in our sole election, disclose any of the data and information you provide us, including but not limited to your Private Information, to the extent reasonably necessary to: (a) facilitate the Services and aspects thereof; (b) enable a transaction or facilitate a collection of amounts owed; (c) protect the rights, security, property, and/or safety of Tiny, our Affiliates, our community, and/or any other third party; enforce our Terms; and (d) assist with the investigation, pursuit or defense of a civil or criminal action and/or other legal dispute. This paragraph embraces, without limitation, Tiny providing third parties with: (a) your Personal Information, Sample, and SI to third party specimen collection providers, laboratories, and specimen analysis providers in order to facilitate the analysis of your Sample(s); (b) your Personal Information and SI to third party microbiome consultants and/or data analysis service providers to facilitate consultations and personalized information regarding your Analysis Results; (c) your Personal Information and SI to third-party communications services providers, to facilitate (i) the scheduling and reminding of dates, events, deadlines and/or appointments, (ii) notification and provision of Analysis Results, and (iii) the delivery of important messages and announcements relating to our Services; (d) your Personal Information and SI to customer service providers; (e) your Payment Information and Personal Information to payment providers; and (f) your Personal Information to shipping and logistics providers. To the extent we disclose your Private Information and/or Sample to any third-party partners and/or providers, Tiny requires these third parties to protect the security and confidentiality of your Private Information and/or Sample.
ii. You may access our Services via networks, ISPs, and devices. All of these third parties have developed and are responsible for their own policies and practices around online privacy.
iii. You acknowledge and agree that neither Tiny nor our Affiliates are responsible for the acts and/or omissions of any third party with respect to the collection, storage, and/or usage of your Private Information or any other data or information. We urge you to review any applicable third-party terms, conditions, and policies very carefully; your decision to consent to such is strictly between you and said third party.
b. De-Identified and Aggregated Data. Tiny intends to study and learn from your Analysis Results and other SI. Tiny may also wish to make use of Analysis Results and other SI in a way that leaves your identity anonymous, while allowing us to disclose the underlying SI with third-party partners.
i. Tiny and our Affiliates reserve the rights to use any information and data provided and/or generated in connection with your use of our Services in order to research, study and infer factual information about you and other members of the Tiny community; this includes, without limitation, using your Analysis Results and other SI for such purposes.
ii. Tiny and our Affiliates also reserve the rights to de-identify and/or pseudonymize any information and data provided and/or generated in connection with your use of our Services (including without limitation your Analysis Results and other SI), such that the data and information cannot reasonably be connected back to the individual from whom such information and/or data was collected. Tiny reserves the right to use such de-identified and/or pseudonymized information and data for its own analysis, as well as for any other lawful purpose it deems fit, including without limitation for sale to third parties (e.g. market research firms, advertisers, medical practices and research firms) and for research pertinent to healthcare, wellness, and related services, products, and offerings.
iii. Tiny and our Affiliates further reserve the rights to create compilations and aggregated data sets that exclude Personal Information and pool your other data and information (including without limitation Analysis Results and other SI) with that of other users. Tiny reserves the right to use such aggregated data for its own analysis and any other lawful purpose it deems fit, including without limitation for sale to third parties (e.g. market research firms, advertisers, medical practices and research firms) and for research pertinent to healthcare, wellness, and related services and products.
c. Targeted Offerings & Interest-Based Advertising. Tiny and our Affiliates reserves the right to use any data or information that you furnish and/or generate in connection with our Services to provide you and others with customized experiences and targeted offerings, and relevant marketing; this includes, without limitation using such data and information to provide targeted ads and promotions, as well as push notifications.
i. You may unsubscribe from our marketing emails at any time by clicking “Unsubscribe” at the bottom of the email.
ii. You can find many technology options to help you set boundaries around the use of your Private Information for targeted ads purposes. For example, AppChoices (http://youradchoices.com/appchoices) enables you to opt-out of interest-based mobile advertisements, while the Digital Advertising Alliance (optout.aboutads.info) created a tool to opt-out of targeted ads on websites. Platforms like Google (https://adssettings.google.com) and Facebook (https://www.facebook.com/about/ads) also contain feature that help you opt-out of unwanted interest-based ads. Browser and mobile settings can often be utilized to limit the transmission of Device ID information and/or third-party cookies in connection with interest-based advertisements.
d. Intracompany Communications. You agree that, within and/or among our Company and our Affiliates, Tiny may freely disclose and discuss any information and data arising out of, relating to, or otherwise concerning you – including without limitation your Private Information – in furtherance of legitimate business purposes.
e. Your User Content. Your User Content is considered non-confidential in its entirety – it may be publicly displayed and circulated, discovered, attributed to you, and/or used by Tiny and our Affiliates as described in our Terms. You acknowledge and agree that neither Tiny nor our Affiliates controls or is responsible for the use of your User Content by any third party.
f. Communications from Tiny. Tiny needs to be able to contact you regarding purchase confirmations, matters concerning the security of your PrivateInformation, and other important service announcements (“Essential Communications”). Furthermore, Tiny may wish to keep you in the loop as we roll-out new features and offerings (“General Communications”). By sharing your contact information with Tiny, you agree to receive Essential Communications and General Communications from Tiny and our Affiliates. You may always opt-out of General Communications by clicking as indicated; however, you are not permitted to opt-out of Essential Communications.
g. Changing or Closing Your Account. If you decide to close and/or delete your account with Tiny, we reserve the right to preserve your information, including without limitation your Private Information, in order to: (a) fulfill any remaining obligations to your or any third-party provider; (b) preserve information that we believe, in good-faith, to be necessary for the protection and/or enforcement of our legal right; and (c) send you Mandatory Communications and, if allowed, General Communications. Please note that you may update or close your account at any time via your account settings.
5. Tiny Requires You To Accept These Disclaimers, Releases, & Indemnification Obligations.
Even with commercially-reasonable efforts, you acknowledge and agree that neither Tiny nor any of our Affiliates promises or guarantees the security of your Sample or Private Information or other data and information. Likewise, you acknowledge and agree that Tiny and our Affiliates cannot represent that your Sample or Private Information has been free or warrant that it will remain free from unwanted access, usage, disclosure, modification, and/or alteration. Indeed, you acknowledge and agree that you are solely responsible for protecting your own privacy and access to your Private Information (e.g. protecting your passwords and financial account information).
To the maximum extent legally permitted, you agree to release and hold Tiny, our Affiliates, and our third-party partners and providers harmless in connection with any losses, liabilities, claims, controversies, lawsuits, disputes, or matters arising out of and/or relating to the unwanted access, collection, storage, and/or usage of data and information – including but not limited to your Private Information – regardless of prior notice or warning. Furthermore, to the maximum extent legally permitted, you agree to defend and indemnify Tiny, our Affiliates, and our third-party partners and providers and hold Tiny, our Affiliates, and our third-party partners and providers harmless in connection with any third-party claims, controversies, lawsuits, liabilities, decisions, damages, awards, amounts, costs, fees, and/or penalties arising out of and/or relating to your actions and/or omissions in connection with data and/or information (including without limitation Private Information) arising out, relating to, transmitted and/or communicated in connection with, and/or otherwise concerning our Services. You agree that the terms specified in this paragraph apply regardless of whether the matter at issue originated from Tiny’s sole negligence, and regardless of prior notice or warning; however, this paragraph shall not apply to matters directly resulting from any recklessness and willful misconduct of Tiny.
If you have not already done so, please carefully review all disclaimers, limitations, and indemnification obligations set forth in our Terms; these terms apply with equal force and effect to this Privacy Policy.
6. You must accept the following terms and conditions in order to access and use our Services.
a. Policy Changes. Tiny reserves the right – in our sole discretion, at any time, for any reason – to make changes to this Privacy Policy and the manner in which we collect, store, and use your data and information. Tiny promises to make a reasonable effort to notify you of any changes to this Privacy Policy, including without limitation by banner notification, pop-up, email, and/or text/SMS message. You acknowledge and agree that your continued use of our Services constitutes your full acceptance of any changes to this Privacy Policy.
b. Competent Adults Only. You represent that you are older than eighteen (18) years of age. You represent that you are of sound mind to understand and accept our Terms, including without limitation this Privacy Policy. Notwithstanding that you may provide us with data, information, and Specimens relating to your child or legal ward - and that we may collect such information from you - you acknowledge that our Services are not intended to be utilized by children under the age of eighteen (18) and we do not knowingly collect information from such persons. If you think a minor has accessed and/or our Services or otherwise provided data or information, let us know immediately at legal@tinyhealth.com.
c. Disclosure of Law Enforcement or Judicial Body. From time to time, Tiny may be legally compelled to turn over Personal Information to law enforcement or a judicial or administrative body of competent jurisdiction. You acknowledge and accept that Tiny will disclose Personal Information upon receipt of a proper court order, subpoena, warrant, or other form of legal process to the extent necessary to meet its obligations under law and/or in furtherance of the public interest.
d. California Residents.
i. California residents may request information regarding the categories and sources of Personal Information we collect, the purposes for our collection of Personal Information, the nature of any related third-party disclosures, and the identities of such third-party recipients.
ii. California residents also have the right to request a copy of their Personal Information, demand deletion of their Personal Information, and opt-out of the sale of any Personal Information.
iii. To exercise these rights, California residents can: (a) submit a request via email at legal@tinyhealth.com, subject line “CCPA”; or (b) contact us by mail or private carrier at: Seeding, Inc., Attention: Legal Department, 9613 Streamside Dr, Austin, TX 78736. Please note, however, that Tiny reserves the right to require verification that the person submitting the request is the rightful owner of the Personal Information in question.
e. Nevada Residents.
i. Nevada residents are permitted to opt-out of the sale of Private Information, as covered by the Nevada Privacy of Information Collected on the Internet from Consumers Act (the “Nevada Privacy Act”).
ii. To exercise these rights, Nevada residents can: (a) submit a request via email at legal@tinyhealth.com, subject line “CCPA”; or (b) contact us by mail or private carrier at: Seeding, Inc., Attention: Legal Department, 6104 Old Fredericksburg Rd #91622, Austin TX 78749. Please note, however, that Tiny reserves the right to require verification that the person submitting the request is the rightful owner of the Personal Information in question.
iii. Please further note that, at this time, Tiny is not engaged in the “sale” of “personal information” obtained from your use of our Services, as the terms “sale” and “personal information” relate to the Nevada Privacy Act.
Thank you for taking the time to learn more about your privacy right in connection with our Services! We encourage you to reach out if you have any further questions or feedback.
