Introduction
My Way Up GmBH is an AI-driven, personalised therapeutics platform and application that empowers people with data, technology, and Services based on the functional analysis of DNA, metagenomic, and genetic information. Our Services include access to the My Way Up public website, My Way Up complimentary medicine, supplement, superfood, and probiotic suite, including subscription services, and personal metagenomic testing services, including the collection and analysis of your stool.
Data obtained from this quiz (“Sample Data”) is used for producing AI-driven data (“Test Data”) that will be stored and used with customer-provided information (the responses to our quiz) and My Way Up proprietary reporting technology that uses analytics and Artificial Intelligence to generate quiz results (“Test Results”) and offer a recommended gut health regimen. Based on our analysis of Test Results and customer-provided data, using My Way Up technology, My Way Up makes personalised supplement, complimentary medicine, probiotic and superfood recommendations and offers these products as a once off purchase or on a Subscription Service (“Subscriptions”) to individuals via, My Way Up website located at www.mywayup.com.
My Way Up takes privacy very seriously. We are committed to protecting the privacy and security of “Personal Information” which could be used to identify our customers, either alone or in combination with other information. By accessing or using the Service (as defined above), customers allow us to collect, store, and use their Personal Information that enables us to provide more accurate and personalised supplements, superfood, complimentary medicine and probiotics recommendations. My Way Up recognises and understands the importance of privacy and respects our customers’ desire to store and access Personal Information in a private and secure manner.
THIS PRIVACY POLICY DESCRIBES HOW INFORMATION ABOUT YOU MAY BE COLLECTED, USED, STORED, MAINTAINED, DISCLOSED, PROTECTED, AND ABLE TO ACCESS THIS INFORMATION. THIS PRIVACY POLICY FURTHER DESCRIBES OUR POLICIES ON OUR CUSTOMERS’ PERSONAL INFORMATION, PERSONAL DATA, PERSONALLY IDENTIFIABLE INFORMATION, SELF-REPORTED INFORMATION, PROTECTED HEALTH INFORMATION, AND SENSITIVE INFORMATION. PLEASE REVIEW IT CAREFULLY.
Acceptance of Privacy Policy
By subscribing to or otherwise using our Services (including our Quiz), or accessing any content or materials made available through the Service, you agree to be bound by our Terms of Service, that includes this Privacy Policy. My Way Up reserves the right to change or modify this Privacy Policy at any time and in its sole discretion. Any changes or modifications will be effective immediately upon posting of the revised Privacy Policy (with the revision effective date posted on the top left side) on our Service. Your continued use of the Service following the posting of revised Privacy Policy will constitute your acceptance of those.
What Information We Collect
When you subscribe to or use our Services, My Way Up collects and uses several types of information as identified below. These include information you provide directly to us, your clinical and test data, information our customers provide in response to our quiz, data we retain in order to improve our data analytics methods and artificial intelligence engine and our Service, data we retain for provisioning our Service and securing payments for same, information we collected through tracking technology, web analytics, and other types of information we receive about you from third party sources.
We may collect “Personal Information” about you that amounts to any factual or subjective information whether recorded or not about an identifiable individual.
“Personally, Identifiable Information” or “PII” is information about an individual when used alone or with other relevant data that can identify an individual (e.g., first and last name, birthdate, home address, social security number, bank account number, credit card number, passport number, Health insurance ID number, etc.).
“Personal Data” is any information relating to a natural person, when that person can be identified, directly or indirectly, in particular by reference to an identification number (e.g. social security number or credit card number) or one or more factors specific to his physical, physiological, mental, economic, cultural or social identity (e.g. last name and first name, date of birth, biometrics data, fingerprints, or DNA).
“Sensitive Information” or “Sensitive Data” is a category of Personal Information or Personal Data of an individual relating to confidential medical facts, records, racial or ethnic origins, political or religious beliefs, or sexuality.
“Self-Reported Information” is all information you provide us about yourself, including input and answers to our Quiz (e.g., information about your personal traits (e.g., eye colour, height), ethnicity, disease conditions (e.g. Type 2 Diabetes), physical health-related information (e.g., pulse rate, cholesterol levels, visual acuity, medicine you currently take, habits such as smoking), diet related information (e.g., vegetarian, vegan, allergies, etc.), mental health related information (e.g. emotional conditions such as fear or anxiety), and family history (e.g., information similar to the foregoing about your family members).
“Protected Health Information” or “PHI” is any information about health status, provision of health care, or payment for health care that can be linked to a specific individual that also includes such information as any part of a medical record or payment history.
“Registration Information” is collected when you subscribe to or register for our Service. This information includes, but is not limited to Personal Information such as your name, date of birth, and password.
“Medical Information” is information that is also contained within your medical records.
“User Content” is information that you create or content that you post or upload on our website, social media, or public forums that relate to us, such as blogs, data, text, software, documents, audio, photographs, graphics, video, messages, discussions, emails, or other materials that you create or provide to us through public or private transmissions.
“Test Data” is information we extract from Sample Data for use in our testing services that produce data and test results that help us provide you with accurate and personalised recommendations.
“Individual-level Data” means information or data about a single individual's Quiz answers, medical information or other types of data provided by the individuals themselves or collected from other sources.
“Web Information” is information on how you use My Way Up website (e.g. browser type, domains, page views, etc.) or other online media owned by My Way Up, and are collected through log files, cookies, and web beacon technologies. We use your data to help us provide a better and more personalised email experience.
How We Use your Information
My Way Up will use and share your information (including Personal Information) in the ways that are described below and elsewhere in the Privacy Policy.
- a) Provide you with the Services
We use your information in accordance with this Privacy Policy for activities necessary for provisioning the Service that include testing and analysis of data, generate and deliver Test Results and recommendations, customise your gut health regimen, and improve our Services. These activities may include but not limited to: i) open and maintain your My Way Up Account; ii), enable purchase of our Service (e.g., process payments and for purchase of supplements, superfoods, complimentary medicines and probiotics); iii), communicate with you (e.g., informing you of policy changes, security updates or issues, etc.); iv) implement your requests (e.g. requests to Customer Service); v) facilitate use of our website and mobile applications (including authenticating your visits, providing personalised content, and tracking your use of our Services); vi) enforce our Terms and other agreements such as monitor, detect, investigate and prevent prohibited or illegal activities, spam and other security risks, performing quality control; vii) perform Research Studies and Research & development activities (which may include, for example, Research conducted by My Way Up); viii) conducting data analysis to improve existing Services or develop new Services; and ix) improving our data analytics and artificial intelligence engine that help us provide more precise recommendations, and infer data that help us make products for you.
We may also use your information to fix bugs or issues, analyse use of our website, charge recurring Subscription Fees, to improve or optimise the customer experience and Customer Service, or assess the efficacy of our marketing campaigns.
For individuals located in Europe, we process your Personal Data in the same way in accordance with this Privacy Policy and our Terms of Service.
Children’s Privacy
My Way Up is committed to protecting the privacy of children. The Service is not directed, designed, or intended to attract children under the age of 13.
In rare instances, a parent or legal guardian of a child, however, may specifically request or consent his/her child to participate in the quiz and use our Services, and may assist the child with providing assent, if the child is old enough to do so. In such cases, the parent or guardian may create an Account for, assist and be responsible for providing Self-Reported Information on behalf of his or her child. If you are the parent or guardian of a child, you assume full responsibility for ensuring that the information you provide to My Way Up about your child is: i) accurate; ii) you have the legal right to provide your child’s information to My Way Up, and iii) that the child’s information is kept confidential and secure.
In the event My Way Up is notified or becomes aware that the Service has been used by a child under the age of 13 to store information of that child without parental consent, My Way Up shall be and is authorised to delete, in its entirety, with no notice to you, any of the information stored by that child or by you on that child’s behalf. My Way Up also reserves the right to revoke any license to use the Service, which is being used or has been used by a child under the age of 13.
Retention of Personal Information
By choosing complete the My Way Up Quiz, you consent to have My Way Up access, analyse, and store your Personal Information using the same or more advanced technologies, in a manner consistent with our Terms and this Privacy Policy. Unless we notify you otherwise, we will store your Samples and data from the Samples for at least ten (10) years, but may, in its sole discretion, to the extent permitted by law, retain such Samples and data for a longer period of time. All of the same safeguards applicable to Personal Information will be provided, to any further use of your Samples, as in our Terms of Service and this Privacy Policy.
Unless you close your Account and delete your Personal Information in the Account as described under Account Closure as specified above, My Way Up will store your Personal Information as long as your Account is open.
Data Security
My Way Up shall take reasonable steps and employ processes to protect Personal Data from loss, misuse and unauthorised access, disclosure, alteration and destruction. My Way Up has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the customer information from loss, misuse, unauthorised access or disclosure, alteration or destruction. However, My Way Up cannot guarantee the security of information on or transmitted via the Internet. Such safeguards and processes include but not limited to:
- i) Self-assessment
My Way Up uses a self-assessment approach or outside compliance review to assure compliance with this Privacy Policy and it periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, and in accordance with the Principles.
- ii) Data Integrity
My Way Up shall only process Personal Data in a way that is compatible with and relevant for the purpose for which it was collected or authorised by those who provided the information. To the extent necessary for those purposes, My Way Up shall take reasonable steps to ensure that Personal Data is accurate, complete, current and reliable for its intended use.
iii) Access
In those instances in which My Way Up collects Personal Data directly from individuals, My Way Up shall allow those individuals access to their Personal Data and allow the individual to correct, amend or erase inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.
Contact Us
If you have questions about this Privacy Policy, please contact us by email at hello@mywayup.com
