Privacy Policy

Effective Date: August 9, 2021; Last Date Updated: March 8, 2023

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This Privacy Policy applies to intrivo.com, carestart.com, letsongo.com and the On/Go application (collectively, the “Site”) and describes the data and information Intrivo, (“Intrivo”) may collect from you or that you may provide when you visit the Site. This Privacy Policy governs Intrivo’s practices related to data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Intrivo include intrivo.com, legsongo.com, the On/Go application and Intrivo. When you interact with healthcare providers, clinicians, or labs through our Site, the information these third parties collect from you is subject to the notices or terms they provide to you. This Privacy Policy does not apply to those interactions.

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This Privacy Policy is part of and incorporated into the End-User License Agreement available when you download the App, the Terms and Conditions, found at intrivo.com/terms-and-conditions, carestart.com/terms-and-conditions, and letsongo.com/terms-and-conditions, as applicable, which is a legally binding agreement between you and Intrivo. By using the Site, you consent to the data practices described in this statement.

Information We Collect

In order to respond to and report to public health authorities in connection with the Covid-19 public health emergency, we are required to collect and share certain personal information about you with public health authorities. This information will be shared only with the public health authorities in compliance with applicable law, and may include:

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• Dates you took any On/Go or CareStart tests
• Location you took the test(s)
• Results from the test(s)
• Residential zip code
• State of Residence
• Date of Birth

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Intrivo may also collect other personally identifiable information, such as your:

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• Contact Information. This includes your first and last name, mailing address and email address. It also includes your phone number. 
• Demographic information. We may collect your gender and sex. We may collect your height and weight and your age. This also includes information about your habits. 
• Health Information. Whether you are symptomatic, specific symptoms and date they started. We may collect information about conditions you may have or medications you have been on. Further, if you choose to enable Bluetooth on your mobile device, the On/Go application will collect measurements from connected devices you enable as part of receiving select services.‍
• Payment information. If you purchase Intrivo’s products and services, we will collect billing and certain credit card information. This information is used to complete the purchase transaction.‍
• Usage Details. When you access and use the Site, we may automatically collect certain details of your access to and use of the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App. We may also track if you open emails we send you or click on links in those emails.‍
• Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number. For example, the App checks network connection and WiFi status to make sure it will function correctly, including saving your test results so that you can reference them later.‍
• Stored Information and Files. The Site also may access metadata and other information associated with other files stored on your device. Further, if you choose to upload a vaccine photo or file from your device, the App shall request access to your device’s external storage to access these files.‍
• Location Information. If you grant access to your location through your device, the Site collects real-time information about the location of your device.

Methods of Collecting Information

We collect information directly from you. This includes when you register for an account on our Site, enter a sweepstake or contest sponsored by us or one of our partners, or sign up for special offers from selected third parties. When you send us an email message or order and purchase products and services on our Site we also collect information. We also collect information using features on your smartphone. This includes the camera when you submit a photo for test verification. If you grant access to your location, we also collect that information. If you enable Bluetooth connectivity, the On/Go application will collect weight and temperature measurements from connected devices that are provided as part of select services. Finally, this Site and, specifically, the On/Go application, uses your audio and microphone to allow you to have a conversation with a care guide if you use this feature.

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We collect information from others. Our partners may give us information about you. This includes lab providers that perform tests that you request or that a clinician orders. It also includes from clinicians that review your test results and provide feedback and results. We may get information from your insurance provider. A current user may share your email and name with us if they purchase a test for your use. 

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We collect information passively. We use tracking tools like browser cookies and web beacons. We do this on our websites and in emails that we send to you. We collect information about users over time when you use the Site. This includes usage and browser information. We may have third parties collect personal information this way.

Use of your Personal Information

Intrivo collects and uses your personal information to operate its website(s) and deliver the services you have requested.

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For example, Intrivo may use your personal information to:

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• offer and provide information, products, and services to you;
• communicate with you about, and administer your participation in, surveys, events, programs, newsletters, promotions, and other Site features;
• respond to and communicate with you about your inquiries and requests; 
• provide Services, information, and products you request (for example, if you grant access to your calendar through your device, we will be able to save appointments to your calendar);
• conduct and participate in research activities;
• protect our company and other users;
• secure and defend our company and our Site;
• send periodic emails to market and promote our products 
• Inform you of other products or services available from Intrivo and its affiliates;
• deliver customized content and advertising within Intrivo to customers whose behavior indicates that they are interested in a particular subject area;
• Services and for non-marketing or administrative purposes; and
• operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; targeting advertising for our products; performing data analytics; and performing accounting, auditing, billing reconciliation, and collection activities and other internal functions).

Sharing Information with Third Parties

Within our family of companies. We may share information with our parents, affiliates and subsidiaries. This includes future related companies.

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Vendors and service providers. Intrivo may share data with trusted third-party service provider partners to help us provide you with services. This includes if we send you email or postal mail, provide customer support, or arrange for deliveries. This also includes vendors that deliver your products or medications. 

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Health Care Professionals. We may disclose your information to labs and other entities involved in providing you services. If you seek care, treatment or other services through the Site, a healthcare provider will have access to the information you provided in your intake form and account in order to provide you with services.

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Other individuals or entities at your choosing. If you elect to share your test results with another person or your employer, the information in that result will be shared to whomever you choose to send the result. 

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As required by law. Intrivo may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to (a) conform to the edicts of the law or comply with legal process served on Intrivo or the Site; (b) protect and defend the rights or property of Intrivo; and/or (c) act under exigent circumstances to protect the personal safety of users of Intrivo or the public. This includes for public health purposes such as reporting to regulatory bodies.

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Merger, sale, or other asset transfer. We may transfer any information we have about you in the event we sell, transfer, or merge all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

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We may share information for other reasons we may describe to you or as otherwise permitted by law.

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Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Intrivo’s public message boards, this information may be collected and used by others.

Use of Cookies

The Site may use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

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One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Intrivo pages, or register with Intrivo site or services, a cookie helps Intrivo to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Intrivo website, the information you previously provided can be retrieved, so you can easily use the Intrivo features that you customized.

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You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Intrivo services or websites you visit.

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We Combine Information

We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.

Children Under Thirteen

Intrivo does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

Protecting Your Information

We use reasonable security measures as required by applicable law. Unfortunately, no methods used to transmit information via the internet or methods of data storage are completely secure. We cannot guarantee that information may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or administrative safeguards. Any transmission of information is at your own risk. We encourage you to use caution when using the Internet. This includes not sharing your passwords.

We Store Information in the United States

Our Site is intended for people who are in the United States. We make no representations that our Site is appropriate or available for use in any location outside of the United States. If you are a resident of another country or are accessing the Site from outside of the United States, please note that you are transferring your data to the United States of America which does not have the same data protection laws as the European Union and other regions.

Third Party Sites and Links

The Sites may be linked to, rely on and be integrated with websites, applications, interfaces, services and platforms operated by other companies. The Sites may also feature advertisements from these companies. Once you leave the Sites via a link, access a third-party service or click on an advertisement, you should check you their privacy policy. We are not responsible for the practices of these third-party sites or apps.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in the balance of our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device (“personal information”). Personal information does not include:

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• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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Personal information does not include:

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• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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We obtain the categories of personal information listed above from the following categories of sources:

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• Directly from you. For example, from forms you complete, applications your submit and documentation and information you provide.
• Indirectly from you. For example, from observing your actions on our Website.
• From third parties, for example, our business partners.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

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• To fulfill or meet the reason you provided the information. For example, if you grant access to your calendar through your device, we will be able to save appointments to your calendar. If you provide your personal information to subscribe to a service, we will use that information to process your request and facilitate delivery. We may also save your information to facilitate new transactions.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, transactions and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other 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 users is among the assets transferred.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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We share your personal information with the following categories of third parties:

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• Service providers.
• Affiliates.
• Partners.
• Data aggregators.
• Parent or subsidiary organizations.
• Internet cookie data recipients, like Google Analytics.
• Other third party categories (with your consent).

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

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Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category I: Professional or employment-related information.

Category J: Non-public education information.

Category K: Inferences drawn from other personal information.

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We disclose your personal information for a business purpose to the following categories of third parties:

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• Service providers.
• Affiliates.
• Partners.
• Data aggregators.
• Parent or subsidiary organizations.
• Internet cookie data recipients, like Google Analytics.
• Other third party categories (with your consent).

Sales of Personal Information

In the preceding twelve (12) months, Company has not sold personal information based on our understanding of that term.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights,” below), we will disclose to you:

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• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion,” below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by contacting us at the addresses below.

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Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

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You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

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Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

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If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

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Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. 

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We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

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However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

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Other California Privacy Rights

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California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the address identified below.

Changes to this Privacy Policy

Intrivo reserves the right to change this Privacy Policy from time to time. When changes are made, an updated Privacy Policy will be posted on our Site. We will notify you about material changes to this Privacy Policy as required by law. Please check our site periodically for updates.

Your Choices

You can review and change your personal information by contacting us to request access to correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Contact Information

Intrivo welcomes your questions, comments, and concerns regarding this Privacy Policy. You can contact Intrivo at:

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Intrivo Diagnostics, Inc.

10000 Washington Blvd, Floor 6

Culver City, CA, USA 90232

Tel. 888 965 0301

Email: [email protected]

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No representations or claims regarding Intrivo products are intended to substitute for professional medical advice. Intrivo recommends that you always seek the advice of a qualified healthcare provider with any questions you may have regarding a medical question or condition.

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