Privacy Policy
Last Updated: October 15th 2019
“We” are NRJY Inc., a company registered in the United States of America, under company number 7113801 and with our registered office at 251 Little Falls Drive, Wilmington, DE 19808, referred as “NRJY,” “NRJY Inc.,” or the “Company” or “we” or “us.”
”Covid Testing Today” is a trademark of the Company.
”You” or “Customer” is the individual who has accessed our website or called our telephone number and intends to place or has placed an order for our Product(s).
This Privacy Policy applies to all websites and mobile applications owned and operated by the Company, including www.covid-testing-today.com, and any other websites, pages, features, or content we own or operate, as well we to your use of the Company mobile app and any related Services (collectively referred to herein as “Website”). This Privacy Policy applies to visitors to the Website, who view only publicly-available content, and customers who have purchased a Service.
The purpose of this Privacy Policy is to help you better understand how we collect, use, store, process, and transfer your information when using our Services and accessing our Website.
Please carefully review this Privacy Policy. Your access and use of the Website is subject to your agreement to this Privacy Policy, along with our Terms and Conditions. By accessing the Website and using our Services, you acknowledge all of the policies and procedures described in the foregoing documents and consent to the collection and use of your information, as is described in this Privacy Policy. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or our Terms and Conditions you should immediately discontinue accessing the Website and using our Services.
Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms and Conditions.
In addition to this Privacy Policy, if you are a California consumer, please review Section 10 of this Privacy Policy regarding your additional data privacy rights.
1. Information We Collect
“Personal information” means information that can be used to identify you, either alone or in combination with other information. We may collect and process the following types of personal information about you through the Website:
a. “Registration Information” is the information you provide about yourself when registering for and/or purchasing our Services (e.g., name, gender, email, address, password, and payment information).
b. “Test Results Information” is information regarding the results of your tests, generated through processing of your Samples by the Company or by its contractors, successors, and assignees; or otherwise processed by and/or contributed to the Company.
c. “Self-Reported Information” is all information about yourself, including your disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your account.
We may also collect non-personal information about you. Non-personal information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We obtain non-personal information about you from information that you provide us, either separately or together with your personal information. We also automatically collect certain non-personal information from you when you browse or otherwise access the Website. This information can include, among other things: your IP address or other unique identifiers that are automatically assigned to your computer, mobile or other device used to access the Website; the type of browser you are using (e.g., Internet Explorer, Firefox, Safari, etc.); the third party website from which your visit originated; the operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.); the domain name of your Internet service provider; the search terms you use on our Website; the specific areas within our Website that you visit; and the time of day and duration of your visits. We may collect such information by tracking, or asking our third party vendor to track, your click stream activity when such information is not tied to a specific user name or account through the use of "cookie" technology or by tracking internet protocol (IP) addresses, as explained below.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.
Additionally, if you communicate with us by email or otherwise, complete anonymous questionnaires or surveys, or otherwise interact with or use the features of the Website, a record of such communications may be kept. We may also ask you for information when you report a problem with our Website.
We collect this information:
• Directly from you when you provide it to us.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
• From third parties, for example, our business partners.
Cookies
Like most web sites, we may use cookies and web log files to track Website usage. A cookie is a tiny data file that resides on your computer that allows us to recognize you as a user when you return to the Website using the same computer and web browser. Like the Registration Information you provide during account registration, cookie and log file data is used to customize your experience on the Website. One type of cookie, known as a “persistent” cookie, is set once you have logged in to your account. The next time you visit the Website, the persistent cookie will allow us to recognize you as an existing user so you will not need to log in before using the Website. In order to access or change any of your private information, you must log in with your password even if your computer contains your persistent cookie. Additionally, if you log out of the Website, you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the Website. Session cookies expire after a short time or when you close your web browser. You can choose to disable cookies on your browser or allow your browser to notify you when a cookie is being sent, however this may prevent you from utilizing certain features of the Website and Services.
Third-Party Analytics
We may use one or more third-party analytics services (such as Google Analytics) to evaluate your use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. The third parties we currently work with are those listed below. These third parties may change from time to time, but in each case, we will provide you with the links to view these organizations' privacy policies and find out more about what data they hold about you, what they do with it, and how to opt-out from certain data collection. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website, and the Services.
For Google Analytics, please visit: https://www.google.com/analytics
For Segment.io, please visit: https://segment.com/docs/legal/privacy/
For Intercom, please visit: https://docs.intercom.com/pricing-privacy-and-terms/intercom-inc-privacy-policy
For Mixpanel, please visit: https://mixpanel.com/privacy/
For Hubspot, please visit: https://legal.hubspot.com/privacy-policy
The Information Collected by or Through Third-Party Advertising Companies
We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Website over time so that they may play or display ads on our Website, on other devices you may use, and on other websites, apps or services, including on Facebook. It is important to note, however, that we do not share any of your Personal Information with these parties. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect this non-personal information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site. You may opt-out of the tailoring of advertising based on information we collect. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings.
2. How We Use Your Information
How Will Your Identifiable Health Information Be Used?
We may use any identifiable health information (including Test Results) or other information that you voluntarily provide us in order to provide you with information, products or services (including the Services) that you may order through the Website.
If you are a customer or the legal representative of a customer, any identifiable health information that you share via the Website will be kept confidential and only used and disclosed with your consent or as permitted by applicable law.
We may also use your identifiable health information and personal information to send you reminders or other notifications regarding the Services. If you elect to provide us a cell phone number, you expressly consent that we can provide these communications to you via text message. Data or text charges may apply.
We will share your identifiable health information with the Accredited Laboratories and our affiliates, suppliers and vendors to the limited extent necessary or helpful to provide the Services. We require those suppliers and vendors to comply with all applicable data privacy laws and regulations regarding protection and use of identifiable health information. We do not sell, lease or rent your identifiable health information to unaffiliated third parties.
How Will Your Other Information Be Used?
To the extent permitted by applicable law, we may use your personal information to communicate to you special offers and featured items from us, from our affiliates, from third parties, and/or from other suppliers and vendors. If you are receiving additional communications and special offers, you may revoke your authorization to receive such materials from us at any time by contacting us using the contact information below or as outlined in the applicable communication. We will implement your revocation as soon as is commercially reasonable. We cannot control any communications and other materials that you may receive directly from third parties.
We will also use your information to customize your browsing experience and communicate with you and otherwise respond to your questions and suggestions regarding use of the Website as may be permitted by applicable law. This includes sharing your information with our suppliers and vendors and used in the aggregate to create summary statistics that help us analyze Website usage trends, assess what information is of most and least importance, determine technical design specifications, arrange the Website in the most user-friendly way, and identify system performance or problem areas.
We may also use your geographic location to provide you with specific content and direct you to your closest service providers to the extent permitted by applicable law.
In addition to the foregoing, we or the third party contractors providing services on our behalf may use your personal information or non-personal information as follows:
• Pursuant to your consent;
• When required by law or court order;
• To provide you with information or services or process transactions that you have requested or agreed to receive;
• To process your registration with the Website, including verifying your information is active and valid;
• To improve the Website, to customize your experience with the Website or to serve you specific content that we believe is relevant to you;
• To enable you to participate in a variety of the Website’s features;
• To contact you with regard to your use of the Website and, in our discretion, changes to the Website and related policies;
• For inclusion in our data analytics and to improve our success in marketing, research and promoting the Services;
• For purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy;
• To protect or defend our legal rights or property, our Website or other users; and
• During an emergency to protect the health and safety of our users or the general public.
3. Periodic Information / Promotions
When you register online for one of our services, you may be given the option of receiving periodic informational/promotional mail or email from The Company. You choose whether or not to receive correspondence when you provide this information or by changing your preferences within your registration profile or by following the instructions provided in the email at any time. The Company utilizes a third-party service to manage certain email communications.
4. Disclosure of Your Information
Except as described in this Privacy Policy, we will not share any of your personal information outside of our organization, except with our affiliates and related companies, our contractors, vendors, consultants and professional advisors to the extent necessary for them to perform services on our behalf. For example, we may use a third party credit card processing company to bill users for products and services.
We may disclose non-personal information or aggregated or de-identified personal information about our users, without restriction, including for commercial purposes or in exchange for remuneration.
We may disclose personal information that we collect or you provide as described in this Privacy Policy:
• To our subsidiaries and affiliates.
• To carefully-screened contractors, service providers and other third parties we use to support our business, such as contracted laboratories, credit card processors, or data storage service providers. Such entities are bound to contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred, and you agree to and do hereby consent to our assignment or transfer of rights to your personal information.
• To third-parties to market their products or services to you if you have agreed to receive periodic information or promotions. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. We will not disclose any Test Results or Self-Reported Information to such third parties for this purpose.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
We may also disclose your personal information:
• To comply with any court order, law or legal process, including responding to any government or regulatory request.
• To comply with any state or local requirements regarding the disclosure of information for public health purposes, including reporting HIV and other sexually transmitted disease results to state public health regulatory bodies.
• To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
5. What We Don’t Do With Your Data
• We do not share your personal information with any public databases.
• We will not disclose your Test Results to any person or entity without your prior consent unless any such disclosure is required by law.
• We will not provide information to law enforcement or regulatory authorities unless required by law to comply with a valid court order, subpoena, or search warrant.
6. Links to Third Party Websites
The Website may contain links to a number of sites that may provide useful information. Links contained on the Website that transfer you to a non-Company site are not maintained by the Company and may contain different information and/or different privacy policies from those of our Company. You may review the privacy policies of these websites and/or receive specific information regarding that site's privacy policies and procedures after leaving the Website. The Company is not responsible for the content or privacy practices of a non- Company website. The Company does not control, or have any input into, whether our business partners or internet-linked sites use or accept cookies on their sites.
7. Accessing, Downloading, and Deleting Your Data
How to access and download your data
As a Company customer, you can access and download your data from within your account. Specifically, you can:
• Access and download your Company reports, self-reported survey data, order history, and other personal data at any time within your account.
• Request a copy of your personal data processed by the Company's third-party service providers. We work with these third-party service providers to provide, analyze, and improve our Service.
You can do the foregoing by contacting us at the email address given below.
How to delete your data
You can delete your Company account and data from within your account settings at any time. Once you submit and confirm your request, we will delete your data. Data deletion is permanent and cannot be canceled, undone, withdrawn, or reversed.
8. Your Choices About How We Use Your Information
You can choose not to provide us with personal data. If you choose to do this, you can continue to visit our Website and browse its content, but we will not be able to provide you with Services, even if you have already paid for them.
We provide you with choices regarding the personal information you provide to us. We have created ways to provide you with the following control over your information:
• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
• Promotional Offers from Us. 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 Website 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 contact@covid-testing-today.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future promotional email distributions. 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.
• 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 contact@covid-testing-today.com.
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. You can opt out of receiving targeted ads from members of the Network Advertising Initiative via their website.
9. Children Under the Age of 18
This Website is offered and available to users who are 18 years of age or older. We do not collect or maintain information from people we actually know are under 18 years old. If we obtain actual knowledge that a user is under 18 years old, we will use our best efforts to remove that person’s information from our database. If you are not 18 years of age or older, you must not access or use the Website.
10. California Residents
Under California Civil Code Section 1798.83, California residents who have an established business relationship with the Company may choose to opt out of our sharing their Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to help@covid-testing-today.com or write to us at:
NRJY Inc.
251 Little Falls Drive
Wilmington, DE 19808
We have also prepared a supplemental Privacy Policy (“California Statement”) for California consumers in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Please review our California Statement for more information. Please note that the CCPA will not be effective until 2020 and may experience changes through the legislative amendment process. As a result, please check back often as our California Statement may change to comply with the then-current CCPA requirements.
11. How We Protect Your Information
We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We follow generally accepted industry standards to protect the Information submitted to us, both during transmission and once we receive it. However, we cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.
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 Website, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
12. Data Retention
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
13. Changes to this Privacy Policy
We may alter or make changes to this Privacy Policy from time to time at our discretion by posting such changes to this page. When changes are made, we will post a notice regarding the new policy on our Website. Any changes will be effective immediately upon posting of the revised Privacy Policy unless otherwise stated. Please review this page periodically to ensure that you are aware of any such updates. You can see when this Privacy Policy was last updated by referring to the Last Updated legend at the top of this page.
By accessing the Website after such changes are posted, you agree and consent to all such changes. If you do not agree to any changes we make, you should immediately stop accessing the Website and using the Services.
14. Contact Information
If you have questions about this Privacy Policy, or wish to submit a complaint, please email The Company's Privacy Administrator at privacy@covid-testing-today.com, or send a letter to:
Privacy Administrator
NRJY Inc.
251 Little Falls Drive
Wilmington, DE 19808
SUPPLEMENTAL PRIVACY POLICY FOR CALIFORNIA CONSUMERS
Last Revised: 1/29/19
DO NOT SELL MY PERSONAL INFORMATION
(1) INTRODUCTION.
Our business proudly serves natural persons residing in the State of California (each, a “consumer”). We have prepared this supplemental Privacy Policy (“Statement”) for our California consumers to inform them of their rights under the California Consumer Privacy Act of 2018 (effective 2020) (“CCPA”). We review and update this Statement at least annually.
When we use the term “personal information” in this Statement, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
(2) PERSONAL INFORMATION WE COLLECT.
If you are a California consumer, please be aware that we collect, process, and maintain personal information to fulfill certain business purposes related to our Service. We will not collect additional categories of personal information or use personal information collected for additional purposes without providing you notice. We and our service providers may collect, and you may consent to provide, the categories of personal information set forth below in order to provide our Service to you, or because we are legally required to do so:
• Name;
• Email address;
• Address;
• Payment information;
• Ethnicity;
• Gender;
• Phone number;
• User name;
• Password;
• Communications you send to us;
• Health and test result information related to the Services.
(3) PERSONAL INFORMATION WE DISCLOSE.
We may disclose personal information in certain cases where that disclosure otherwise constitutes the sale of personal information (such as, for example, when we partner with third parties to jointly market products and services to you).
(4) YOUR PRIVACY RIGHTS.
In accordance with the CCPA, California consumers may exercise under certain conditions the following four (4) categories of privacy rights with respect to their personal information. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.
Privacy Right Description
Access
You have the right to know the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the personal information was collected, the specific pieces of personal information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to know the categories of personal information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information. For your reference, however, we post a list of our service providers here whom we disclose personal information to and the business purpose for such disclosure.
Data Portability
You have the right to receive the personal information you have previously provided to us. We will provide this information in accordance with Section 6 of this Statement, below.
Erasure
You can request to have your personal information deleted from our servers and we will direct our service providers to do the same. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required to retain your personal information for one or more of the following categories of purposes: (1) to complete a transaction for which the personal information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); (4) to otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
To Opt Out
You have the right to opt out of the sale of your personal information to third parties. You may exercise your right to opt out immediately by sending an email at privacy@covid-testing-today.com and mentioning the subject : “Do Not Sell my Personal Information”. You may also exercise your right to opt-out via Section 5 of this Statement, below. You do not have to create an account to exercise this right. Please note that if you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information for at least twelve (12) months before we request that you authorize the sale of your personal information again. However, if you decide at any time that we may sell your personal information, you may write to us below providing express authorization for us to do so.
(5) HOW TO EXERCISE YOUR RIGHTS.
If you would like to exercise your rights listed above, please send an email to privacy@GwynnieBee.com or call us toll-free at: please consult website. While we take measures to ensure that those responsible for receiving and responding to your request are informed of your rights and how to help you exercise those rights, when contacting us to exercise your rights, we ask you to please adhere to the following guidelines:
• Tell Us Which Right You Are Exercising: Specify which right you want to exercise and the personal information to which your request relates (if not to you). If you are acting on behalf of another consumer, please clearly indicate this fact and your authority to act on such consumer’s behalf;
• Help Us Verify Your Identity: Provide us enough information to verify your identify. For example, provide us (at a minimum) your full name, address, and customer or invoice/order number. Please note that if we cannot initially verify your identity, we may request additional information to complete the verification process (such information may include a copy of your driving license and/or a recent utility or credit card bill). Any personal information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification.
• Direct Our Response Delivery: Inform us of the delivery mechanism with which you prefer to receive our response. You may specify, for example, email, mail, or through your account (if you have one with us).
Please note that you don’t need to create an account with us in order to make a request to exercise your rights hereunder.
(6) HOW WE RESPOND TO YOUR REQUESTS.
In all cases, we will respond to your request within 45 days. However, where reasonably necessary, we may extend our response time by an additional 45 days, provided we send you notice of such extension first. We will provide the information to you via your preferred delivery mechanism. If the information is provided to you electronically, we will provide you the information in a portable format and, to the extent technically feasible, in a machine readable, readily useable format that allows you to freely transmit this information without hindrance.
Please note that we will not charge you for making a request, provided that you make no more than two (2) requests per year. If you make three (3) or more requests in any given twelve (12) month period, we may refuse to respond to such requests, if determined by us to be unfounded or excessive (e.g. repetitive in nature), or we may charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested. If we refuse to act on the request, we will provide you notice and the reason for our refusal to act.
(7) CONTACTING THE ATTORNEY GENERAL.
California law also gives you right to file a complaint with the California Attorney General’s office. The Attorney General’s office who may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or telephone: (916) 210-6276. We encourage you to reach out to us first, however, so that we may help resolve any complaints you may have.