Baze Labs, Inc. (“
regarding the Personal Data (as defined below) we collect from users of our website, located at [www.baze.com] (the “
Site”), our mobile application (“
Application(s)”), and online services (collectively, the “
1. Questions; Contacting Company; Reporting Violations.
or if you want to report any security violations to us, please contact us at the following address or phone number:
Baze Labs, Inc.
Cambridge, Massachusetts 02142
Data Protection Officer: Simon Goedecke
2. User Consent.
By submitting Personal Data through our Services, including providing us with a blood sample, you agree to the terms of this
3. A Note Regarding Research.
When you sign up for our Services, you may be asked to review and sign a consent to participate in an institutional review
IRB”) approved research study (“
Research Study”). Participation in the Research Study may be required to use parts of our Services. In this case
your Personal Data (as defined below) as well as the results from your blood sample (as described in Section 5(b)) will
4. A Note About Children.
We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal
Data to Company and we learn that the Personal Data is the information of a child under 13, we will attempt to delete
the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please
contact us at
5. A Note to Users Outside of the United States.
If you are a non U.S. user of the Services, by visiting the Services and providing us with data, you acknowledge and
Personal Data may be processed in the country in which it was collected and in other countries, including the United
States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By
providing your data, you consent to such transfer.
6. Types of Data We Collect.
Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address,
telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked
to any of the foregoing data. “
Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not,
by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described
Information You Provide to Us.
- We may collect Personal Data from you, such as your first and last name, gender, e-mail and mailing addresses,
birth date, professional title, company name, and general health information, such as information relating
to your diet, lifestyle, tastes preferences, and physical activity levels, when you create an account to
log in to our network (“
Account”). If you use our Services on your mobile device, including through our Application(s), we may
collect your phone number and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and
use that information to provide you with location-based information and advertising. If you want to deactivate
this feature, you can either reinstall the Application(s) or deactivate GPS on your mobile device.
- When you subscribe to certain Services or order products or services through our Site or Application, we will
collect all information necessary to complete the transaction, including your name, credit card information,
billing information and shipping information.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us feedback or contact us via e-mail or through the Application, Site, or Services, we will collect
your name and e-mail address, as well as any other content included in the e-mail, in order to send you a
- We may also collect Personal Data at other points in our Site or Application that state that Personal Data is
Information Obtained through Blood Sampling. When you subscribe to certain of our Services, you will receive
a Baze blood sample testing kit. Once you obtain a blood sample using the directions provided with the kit, you must
ship your blood sample to our third-party laboratories. Once received by the laboratory, your blood sample will be
identified by a unique number. The unique number identifies you to us, but not to our third-party laboratory. Your
blood sample will be analyzed by our third-party lab, and your results will be made available to you through the
consent form, if you are part of the Research Study. Your blood sample will be destroyed after the laboratory completes
its work, but in no event later than six (6) weeks following the lab’s receipt of such work, unless the laboratory’s
legal and regulatory requirements require it to maintain physical samples.
Information Collected via Technology.
Information Collected by Our Servers. To make our Services more useful to you, our servers (which may
be hosted by a third party service provider) collect information from you, including your browser type, operating
system, Internet Protocol (“
IP”) address (a number that is automatically assigned to your computer when you use the Internet, which
may vary from session to session), domain name, and/or a date/time stamp for your visit.
Log Files. As is true of most websites, we gather certain information automatically and store it in log
files. This information includes IP addresses, browser type, Internet service provider (“
ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information
to analyze trends, administer the Services, track users’ movements around the Site and Application, gather
demographic information about our user base as a whole, and better tailor our Services to our users’ needs.
For example, some of the information may be collected so that when you visit the Services again, either through
the Site or Application, it will recognize you and the information could then be used to serve advertisements
and other information appropriate to your interests.
Cookies” are small pieces of information that a website sends to your computer’s hard drive while you
are viewing the website. We may use both session Cookies (which expire once you close your web browser) and
persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal
and interactive experience on our Site and Application. This type of information is collected to make the
Services more useful to you and to tailor the experience with us to meet your special interests and needs.
Pixel Tags. In addition, we use “
Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images
with a unique identifier, similar in function to Cookies, that are used to track online movements of Web
users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded
invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and
they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest
to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the
information gathered by Pixel Tags to our users’ Personal Data.
How We Respond to Do Not Track Signals.
Some internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for
“Do Not Track” signals have not yet been adopted, Baze does not process or respond to “Do Not Track”
Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded
our Application(s). This information is generally used to help us deliver the most relevant information to
you. Examples of information that may be collected and used include your geographic location, how you use
the Application(s), and information about the type of device you use. In addition, in the event our Application(s)
crash on your mobile device, we will receive information about your mobile device model software version
and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our
Application(s). This information is sent to us as aggregated information and is not traceable to any individual
and cannot be used to identify an individual.
Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place,
other companies may set their own cookies or similar tools when you visit our Site and Application. This
includes third party analytics services, including but not limited to Google Analytics (“
Analytics Services”), that we engage to help analyze how users use the Site, Application, and Services,
as well as third parties that deliver content or offers. We may receive reports based on these parties’ use
of these tools on an individual or aggregate basis. We use the information we get from Analytics Services
only to improve our Site, Application, and Services. The information generated by the Cookies or other technologies
about your use of our Site, Application and Services (the “
Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics
Information to compile reports on user activity. The Analytics Services may also transfer information to
third parties where required to do so by law, or where such third parties process Analytics Information on
their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such
to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
If you don’t want to take advantage of these services, you may be able to opt-out by visiting
http://networkadvertising.org/choices/, or if you are located in the EU,
7. Use of Your Personal Data
General Use. In general, Personal Data you submit to us is used either to respond to requests that you make,
or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- provide improved administration of our Site, Application, and Services;
- provide the Services you request;
- for the Research Study as described in the IRB-approved consent form;
- improve the quality of experience when you interact with our Services;
- regularly adjust the nutrient dosing to your individual nutrient needs;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories; and
- send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing
purposes of Company.
User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences
with our Services. We occasionally publish such content. When we publish this content, we may identify our users
by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting
his or her name along with the testimonial. We may post user feedback on the Site and Application from time to time.
Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information
(such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request
and usage patterns so that we may enhance the content of our Services and improve Site and Application navigation.
We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and
disclose Anonymous Data to third parties in our sole discretion, including for research purposes.
Disclosure of Your Personal Data.
Third Party Service Providers. We may share your Personal Data with third party service providers to: provide
you with the Services that we offer you through our Services; to conduct quality assurance testing; to facilitate
creation of accounts; to provide technical support; and/or to provide other services to the Company. For example,
we work with third-party laboratories and contractors to process and analyze your blood samples for purposes of determining
which nutrients may be suitable for your personalized subscription pack. While we implement procedures and contractual
obligations on our service providers designed to protect the confidentiality and security of your information, we
cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing
and transmitting data electronically.
Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures,
or other companies under a common control (“
Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation
of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture,
or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership,
Personal Data may also be transferred as a business asset. If another company acquires our company, business, or
assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding
Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company
may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with
any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company;
(c) to protect or defend the rights or property of Company or users of the Site, Application, or Services; and/or
9. Third Party Websites.
Our Services may contain links to third party websites. When you click on a link to any other website or location, you will
leave our Services and go to another site or service, and another entity may collect Personal Data or Anonymous Data
from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content.
of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies
of every website you visit. The links to third party websites or locations are for your convenience and do not signify
our endorsement of such third parties or their products, content or websites.
10. Your Choices Regarding Information.
You have several choices regarding the use of information on our Service:
Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use
of our Site, Application, or Services. When you receive newsletters or promotional communications from us, you may
indicate a preference to stop receiving further communications from us and you will have the opportunity to “
opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly
(please see contact information below). Despite your indicated e-mail preferences, we may send you service related
Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the
purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies
or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information.
If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality
of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact
information provided below.
Changing or Deleting Your Personal Data. All users may review, update, correct or delete the Personal Data in
their user account (including any imported contacts) by editing their profile via the Services or sending an email
to email@example.com. If you completely delete all of your Personal Data, then your user account may become deactivated.
We will use commercially reasonable efforts to honor your request. Data submitted to an IRB or the U.S. Food and
Drug Administration (“
FDA”) in connection with the Research Study cannot be reviewed, updated, corrected or deleted. We may retain
an archived copy of your records as required by law or for legitimate business purposes.
Applications. You can stop all collection of information by the Application(s) by uninstalling the Application(s).
You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile
application marketplace or network.
Security of Credit Card and Bank Account Information. We do not process, record or maintain your credit card
information. We use third party payment processors, such as Stripe, to process your credit card information when
you pay with your credit or debit card using our Services. For more information on how payments are handled, or to
understand the data privacy and security afforded to such information, please visit Stripe’s privacy terms at
https://stripe.com/us/privacy. We follow generally accepted industry standards to protect the personal information
submitted to us, both during transmission and once we receive it. No method of transmission over the Internet,
or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
If you have any questions about security relating to our Services, you can contact us at firstname.lastname@example.org.
Policy regularly for any changes.