Effective date: February 20, 2024
At People Science, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your Personal Data (as defined below). This Privacy Policy is meant to help individuals (“Users”) and employees of our enterprise clients (“Professionals”) that access our platform and use our Services to understand how we treat their Personal Data. It also addresses how we treat the Personal Data of visitors to peoplescience.health (“Website Visitors,” and, collectively with Users and Professionals, “you,” or “your”). By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of People Science’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
You may print a copy of this Privacy Policy by clicking here.
This Privacy Policy covers how we treat Personal Data that we gather from end users when they access or use our Services directly (including via our Chloe app), from professionals when they access or use our Services on behalf of one of our enterprise customers, and from visitors to peoplescience.health. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.
In addition to offering the Services directly to end users, People Science also offers products to enterprise customers. In the ordinary course of providing those products, we may process data that consists of or contains personal data about individuals at the direction of our enterprise customers, including on behalf of individual clinical research sponsors. In those cases, depending on terms in place between People Science and the enterprise customer, we may not be the controllers of such data. The privacy notices applicable to the processing of your Personal Data in connection with clinical research can be found in the clinical research materials provided to you, including the Informed Consent Form you reviewed in accordance with your entry into the clinical research study. In the event of any inconsistencies between the Informed Consent Form and any of the terms within this Privacy Policy, the terms of the Informed Consent Form will apply. If we process your personal data on behalf of one of our enterprise customers and you wish to discontinue such processing, or if you seek to correct, amend, or delete inaccurate data, we will follow our customer’s instructions with regard to the data at issue. We will retain such personal data pursuant to our retention policy and will retain it as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Some of our enterprise customers may be regulated by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). This Privacy Policy does not describe how we collect or use individuals’ “Protected Health Information” or “PHI” (as defined by HIPAA) on behalf of those enterprise customers. Specifically, when (a) People Science, acting as a “Business Associate” (as such term is defined in HIPAA), receives identifiable health information about an individual from or on behalf of one of our enterprise customers; and (b) such enterprise customer is a “Covered Entity” (as such term is defined in HIPAA), this information is considered PHI. Personal data that is provided to People Science outside of the foregoing context is not PHI. For example, when you create an account, use our tools and services, or when you send us an email or otherwise contact us, that information is not PHI. HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Please read the Notice of Privacy Practices of your healthcare provider to understand how your PHI can be used and disclosed.
Finally, this Privacy Policy does not cover the practices of companies we don’t own or control, such as our enterprise customers, or people we don’t manage.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share This Personal Data: |
| Profile or Contact Data | • First and last name • Phone number • Mailing address | • Service Providers • Advertising Partners • Analytics Partners • Business Partners • Parties You Authorize, Access or Authenticate |
| Online Identifiers | • Unique identifiers such as username and passwords | • Service Providers • Parties You Authorize, Access or Authenticate |
| Device/IP Data | • IP address • Device ID • Type of device/operating system/browser used to access the Services | • Service Providers • Advertising Partners • Analytics Partners • Business Partners • Parties You Authorize, Access or Authenticate |
| Web Analytics | • Web page interactions • Referring webpage/source through which you accessed the Services | • Service Providers • Advertising Partners • Analytics Partners • Business Partners • Parties You Authorize, Access or Authenticate |
| Consumer Demographic Data | • Age / date of birth • Zip code • Gender • Race • Ethnicity • Sex life or sexual orientation | • Service Providers • Advertising Partners • Analytics Partners • Business Partners • Parties You Authorize, Access or Authenticate |
| Geolocation Data | • IP-address-based location information | • Service Providers • Advertising Partners • Analytics Partners • Parties You Authorize, Access or Authenticate |
| Sensory Data | • Photos, videos or recordings of you or your environment | • Service Providers • Business Partners • Parties You Authorize, Access or Authenticate |
| Health Data | • Medical conditions • Weight • Health or exercise activity monitoring • Mental health information | • Service Providers • Parties You Authorize, Access or Authenticate |
| Inferences Drawn From Other Personal Data Collected | • Profiles reflecting user attributes • Profiles reflecting user behavior | • Service Providers • Advertising Partners • Analytics Partners • Business Partners • Parties You Authorize, Access or Authenticate |
| Other Identifying Information that You Voluntarily Choose to Provide | • Identifying information in emails or letters you send us | • Service Providers • Parties You Authorize, Access or Authenticate |
This chart details the categories of Personal Data that we collect and have collected from Professionals over the past 12 months:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share This Personal Data: |
| Profile or Contact Data | • First and last name • Phone number | • Service Providers • Parties You Authorize, Access or Authenticate |
| Professional or Employment-related Data | • Job title | • Service Providers • Parties You Authorize, Access or Authenticate |
| Online Identifiers | • Unique identifiers such as username and passwords | • Service Providers • Parties You Authorize, Access or Authenticate |
| Device/IP Data | • IP address • Device ID • Type of device/operating system/browser used to access the Services | • Analytics Partners |
| Web Analytics | • Web page interactions • Referring webpage/source through which you accessed the Services | • Analytics Partners |
| Other Identifying Information that You Voluntarily Choose to Provide | • Identifying information in emails or letters you send us | • Service Providers • Parties You Authorize, Access or Authenticate |
This chart details the categories of Personal Data that we collect and have collected from Website Visitors over the past 12 months:
| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share This Personal Data: |
| Profile or Contact Data | • First and last name | • Service Providers • Parties You Authorize, Access or Authenticate |
| Device/IP Data | • IP address • Type of device/operating system/browser used to access the Services | • Analytics Partners |
| Web Analytics | • Web page interactions • Referring webpage/source through which you accessed the Services • Non-identifiable request IDs • Statistics associated with the interaction between device or browser and the Services | • Analytics Partners |
| Other Identifying Information that You Voluntarily Choose to Provide | • Identifying information in emails or letters you send us | • Service Providers • Parties You Authorize, Access or Authenticate |
We collect Personal Data about you from the following categories of sources:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
People Science does not sell or share Personal Data in exchange for monetary compensation. People Science only shares Personal Data with the service providers and other parties listed in this section to the extent necessary to perform services on People Science’s behalf such as helping to provide or improve Chloe’s functionality. Service providers and other parties do not disclose Personal Data or use it for any other purpose including to target ads for third parties.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age. We do not knowingly collect or solicit personally identifiable information from a child under 13 without obtaining verifiable consent from that child’s parent or guardian (“Parental Consent”), except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent (“Required Information”). Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent. If you are a child under 13 years of age, please do not attempt to send any Personal Data about yourself to us before we obtain Parental Consent, except for the Required Information in the context of the Parental Consent process. If you believe that a child under 13 years of age has provided us with Personal Data (beyond the Required Information) without our obtaining Parental Consent, please contact us at privacy@peoplescience.health. We do not condition participation in our Services on disclosure of more Personal Data from a child under 13 years of age than is reasonably necessary for that participation, and we do not retain Personal Data from children under 13 years of age longer than is reasonably necessary in order to fulfill the purpose for which it was disclosed.
If you are a parent or guardian of a user of our Services who is under 13 years of age, you may contact us at any time to ask that (a) we stop collecting Personal Data from such user, (b) we delete any Personal Data already collected from such user (although note that we may further retain information in an anonymous or aggregated form where that information would not identify such user personally), or (c) we stop disclosing Personal Data collected from such user to third parties, but continue to allow for collection and use of Personal Data collected from such user in connection with the Services.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@peoplescience.health.
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. People Science will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@peoplescience.health. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@peoplescience.health. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
The Services are hosted and operated in the United States (“U.S.”) through People Science and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to People Science in the U.S. and will be hosted on U.S. servers, and you authorize People Science to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.
We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the People Science website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
