Privacy Policy

Welcome to Celia Health! Celia Health delivers personalized wellness solutions by combining genetic testing with peptide therapies to develop targeted programs to promote longevity, vitality, and overall well-being. Our products address a range of health areas, including immunity, metabolism, skin and hair health, gut health, and brain function (“Products”).

This Privacy Notice describes how Celia Group, Inc. (“Celia”, “we”, “us” and/or “our”), handles the personal information that we collect from and about you when you visit our websites, currently located at https://celia-health.com/ and https://celia-rx.com/ (the “Site(s)”); use our mobile applications(s) (“App(s)”); engage with us through our newsletters, emails, and branded social media accounts; or otherwise interact with us (collectively, our “Services”). This Privacy Notice also describes certain legal rights you may have, subject to applicable law, and how you can exercise them.

For the purposes of this Privacy Notice, “Personal Information” means information about an identified or identifiable person, as defined by applicable law. This includes information that alone or in combination with other information may be used to identify, contact, or locate you, such as your name, address, email address, or phone number.

Some state laws classify certain categories of Personal Information as Sensitive Personal Information or Consumer Health Data. Where required by applicable law, we obtain your affirmative consent before collecting, processing, or sharing such information. Residents of California, Colorado, Virginia, and other states with comprehensive privacy laws have the right to limit our use of Sensitive Personal Information for targeted advertising purposes.

If you are a resident of Connecticut, Nevada, or Washington, please also review our Consumer Health Data Privacy Notice, which provides additional information about how we handle Consumer Health Data as defined under the laws of those states.

We may sell or share your Sensitive Personal Information as defined under Texas law. You have the right to opt out of such sharing by emailing us at privacy@celia-rx.com.

Please read this notice carefully. In addition, please review our Terms of Use, which govern your use of the Services.

1. Information We Collect

1.1 Information You Give Us Directly

Some information we collect directly from you. For instance, we collect information that you voluntarily provide in the following ways:

• When you set up an account. When you create an account, we ask you to provide your first and last name, email address, and a password we can use to authenticate you at sign in. Creating an account allows you to log in on a different or shared device, purchase Products, and access your order history. If you are a medical practitioner and sign up for a “Provider” account, we collect additional information to verify your credentials, including your clinic/practice name, area of practice, speciality, license number, and a photo of your medical board license.
• When you make a purchase from our Site. If you choose to purchase Products through our Site, you will be required to provide certain information including your name, payment information (such as credit/debit card details, Paypal or other payment account details), and billing address in order to facilitate payment. Payments are handled by our third-party payment processing partners. You will also be asked to provide a name, phone number, and shipping address where you’d like us to send your order. If you subsequently post a rating, review, or other user-generated content on our Sites or post a review or comment on one of our social media pages, we will collect any Personal Information you include in your rating, review, or comment.
• When you sign up to receive communications from us, including signing up for emails, newsletters or SMS updates. When you engage in one of these activities, we may collect your name, email address, telephone number, and any additional information you choose to provide to us as part of that request. We use your email address and telephone number to notify you about Products and promotions we may offer and provide news and information we believe will be of interest to you.
• When you take quizzes, answer surveys, or answer screening questionnaires. When you complete a quiz or surveys on the Sites, we collect a variety of information, including your name, email address and responses to questions about your age, gender, general demographics, wellness routines, and certain health-related information. We use this information to help ensure our Products are not offered to individuals for whom they may be inappropriate (such as individuals who are pregnant, breastfeeding, or undergoing certain medical treatments), and to provide personalized Product recommendations and relevant informational content. If you express interest in prescription-grade Products, you will be asked to participate in a consultation with a contracted telehealth provider who will conduct a clinical evaluation through our Service to determine whether a prescription is appropriate. We do not access or store the information you share with the telehealth provider during that consultation.
• When you participate in telehealth consultations.. If you express interest in prescription-grade Products, we will connect you with a prescribing physicianwho will conduct a clinical evaluation to determine whether a prescription is appropriate. Our role is limited to facilitating that connection. We do not access, retrieve store, or otherwise process the information you share with the prescribing physician during that consultation (including any medical history, symptoms, diagnoses, or prescription information). Any medical records created in connection with your consultation are maintained by the prescribing physician (and, as applicable, the dispensing pharmacy) and are subject to their privacy practices. To exercise any rights you may have under the Health Insurance Portability and Accountability Act (HIPAA) with respect to such information (such as the right to access and obtain a copy of your records, request corrections/amendments, request restrictions on certain uses and disclosures, receive an accounting of disclosures, receive a Notice of Privacy Practices, or file a complaint) please contact the prescribing physician and/or pharmacy directly.
• When you contact us. When you contact us by email; through our branded social media accounts; through any integrated chat providers we may provide; or by telephone, SMS, or physical mail, we may collect your name, social media username (if applicable), email address, phone number, physical address, and the contents of your communication which can include any information you choose to provide
• When you send a gift card or invite others to try Celia. When you purchase or send a gift card for one of our Products, we collect your name, contact details, and payment information, as well as the recipient’s name and email address. Additionally, if you invite a friend to try our Products, we may collect their name and email address. This information is used solely to process the transaction, deliver the gift card, or facilitate the invitation.
• Registering for a contest, competition, or sweepstakes. In these circumstances, we may collect your name, contact information, and any other information relevant to that contest or competition or which you choose to provide
• When you participate in surveys or research studies. We may contact you to ask if you would be willing to participate in a survey or research study. If you decide to participate, you may be asked to provide demographic information, feedback on your experience (such as satisfaction data, before-and-after pictures, and testimonials), and any other information relevant to that survey or study. This research may be published in aggregated, anonymized form.

1.2 Information We Collect Automatically When You Use Our Services

We also collect certain information automatically as you navigate our Services or interact with our communications, including the following:

• Information about the devices you use to access our Services (including your internet protocol (IP) address, browser type, and operating system);
• The address of the web page visited before and after using our Services;
• Details about your interactions with our Services (such as the date, time, length of stay, and specific pages accessed during your visits);
• Search terms used to reach our Services;
• Usage information (such as the number and frequency of visitors to our Site); and
• Location information (such as general location information inferred from your IP address)
• Transaction information. We collect information related to any transactions made through our Services, including date and time of order, items ordered, delivery information, and amount charged.

We collect some of the information above using cookies or similar technologies. A “cookie” is a small text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or device or to store information or settings in the browser/device. We, and our third-party service providers, use cookies in order to do things such as recognize you when you return to our Site, save your preferences (including your preferences regarding cookie handling), understand usage patterns, and improve our mobile applications. We use both session cookies (which expire when you close your browser or app) and persistent cookies (which stay on your device until you delete them or until they expire).

If you do not want us to collect information through the use of cookies, you can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to the guidance offered by your chosen web browser if you would like help managing your cookie preferences. Please note that if you reject or block cookies, the Services may not work as intended.

We also may partner with third parties who provide analytics services and serve advertisements on our behalf across the Internet and in mobile applications. These third parties may use cookies and similar technologies to track your engagement with our Site as well as our online advertising and email marketing campaigns and permit us and them to analyze and track data, and do things like determine which advertising or marketing source brought someone to our Sites and target advertisements to an audience based on prior browsing patterns on our Sites.

1.3 Information We Collect from Other Sources

We may also obtain Personal Information from other sources. For instance, we may collect Personal Information about you from the following third-party sources:

• Payment processors. In general, when you purchase Products through our Sites, your payment card information is provided directly to our third-party payment processing partners, and Celia does not collect or store that information. However, we may have access to limited information about your payment card from these partners and related transaction details, such as the last four digits of your card, the country of issuance, and the expiration date.

We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

2. How We Use Your Information

We use the information described above to do the following:

• Provide our Services (including taking and processing your orders; shipping Products; communicating with you regarding your purchases; and sending you technical notices, updates, security alerts, and support and administrative messages);
• Operate and improve our Services (including monitoring and analyzing usage, trends, and activities related to the Services and identifying, fixing, and troubleshooting bugs and service errors);
• Communicate with you (including responding to your requests, inquiries, comments, and suggestions);
• Personalize content (including tailoring content we send or display to you in order to provide you with information and resources we think will be relevant to you);
• Further our networking, marketing, and social strategies (including posting testimonials and communicating with you by email or SMS about programs, services, offers, promotions, and events);
• Serve and administer advertising (including serving you with relevant ads about our brands and programs, measuring and tracking the effectiveness of advertising campaigns, and carrying out other administrative and accounting activities with respect to ad campaigns);
• Conduct data analysis (including de-identifying and/or aggregating information and using it to perform research and provide statistical information and trend data);
• Protect against, identify, investigate, and respond to misuse of our Services (including preventing and detecting fraud, unauthorized access, and other unlawful behavior);
• Support our general business operations (including maintaining our business and legal recordkeeping); and
• Carry out any other purpose described to you at the time the information was collected.

We use information that may be considered “sensitive personal information” or “special categories of data” under applicable law (“Sensitive Personal Information”), for each of the purposes described above and to make inferences about users, which we may use to promote certain products or services. Where required by law, Celia only processes this Sensitive Personal Information with your consent.

3. How We Share Your Information

We may disclose information about you with third parties in the following circumstances:

• Companies under common control. We may share Personal Information between and among any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership with Celia.
• Vendors and service providers. We may share Personal Information with vendors, consultants, and other service providers who need to access the data in order to perform services on our behalf.
• Advertising and Analytics Partners. We may share your Personal Information with other third parties that provide online analytics and advertising services in order to better understand how individuals interact with our Services and other online services over time and across devices.
• Buyers or business transferees. We may share Personal Information with another company in connection with or during negotiations of any merger, acquisition, financing, re-organization, bankruptcy, sale of all or a portion of our assets, or transition of services to another provider.
• Professional Advisors. We may also share your Personal Information with our professional advisors, which include lawyers, accountants, licensed medical professionals, and other similar professional advisors.
• Legal requirements. We may share Personal Information when we believe it is necessary to comply with a legal obligation, including lawful requests from public authorities to meet national security or law enforcement requirements. We may also share Personal Information when we believe it is necessary to protect our rights and property, to protect the safety of our users, and to defend against legal liability.
• Consent. We may share Personal Information with third parties with your consent and at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide that information. For example, if you request information about a clinical trial, we will share your Personal Information with the clinical trial sponsor as necessary to facilitate your request.
• De-identified/Aggregate Information. We may also share aggregate or de-identified information, which cannot reasonably be used to identify you, for various purposes including compliance with various reporting obligations; for business or marketing purposes; or to assist third parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services. Additionally, we may use such information to support the design and analysis of clinical trials, evaluate the performance of our products, and enhance our understanding of user experiences. Any de-identified data used in research will not be associated with personal identifiers and will be solely for scientific and development purposes.

4. Your Rights and Choices

You have a variety of rights and choices related to our use of your Personal Information.

• Opting out of promotional communications. You can opt out of receiving our promotional communications emails and texts at any time. You may do so by contacting our customer service team or by following the opt-out instructions in the promotional emails or texts we send you. Please be aware that it may take up to ten (10) days for us to process your request, and you may continue receiving promotional communications from us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms).
• Restricting cookies/Do Not Track. Celia does not currently change its behavior in response to web browser “do not track” signals. However, you can configure most browsers to reject cookies or to notify you when you are sent a cookie, giving you a chance to decide whether or not to accept it. You can consult the help section of your browser to find out how to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” or similar opt-out signals, we will assess and provide an appropriate response to those signals.
• Limiting information available through social media platforms. If you want to limit or stop receipt of information from third-party social media platforms, you can change your privacy settings on those other websites. You also may choose not to use social features we make available.
• Access, update, or delete your information. If you would like to access, update, or delete Personal Information you have provided you may do so by emailing us at privacy@celia-rx.com. To learn how to close your account, please contact us by email. Please note that we may keep certain Personal Information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements. We may also keep cached archived copies of Personal Information for a certain period of time.

5. Additional Disclosures for Residents of the EEA, UK, and Switzerland

The laws in the European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland require businesses to disclose certain information, including (i) the controller(s) of your Personal Information, (ii) the legal bases relied on to use or disclose your Personal Information (iii) your legal rights with respect to your Personal Information, (iv) safeguards used for transferring your Personal Information outside of these jurisdictions, and (v) the contact details of the controller and/or data protection offer. To the extent those laws apply, our answers are as follows:

Controller	Celia is considered the “data controller” of the Personal Information that we handle under this Privacy Notice.
Legal Basis	Legitimate Interest. In most cases, we handle Personal Information on the ground that it furthers our legitimate interests in commercial activities such as the following in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals: Providing Services pursuant to our contract with our customers; Processing billing and payments; Marketing our Services; Protecting our customers, personnel, and property; and Analyzing and improving our business. Legal Compliance. We need to use and disclose Personal Information in certain ways to comply with our legal obligations, such as complying with trade control laws and legal and business recordkeeping requirements. To Honor Our Contractual Commitments to an Individual. We need to process some Personal Information to meet our contractual obligations to the individual to whom the Personal Information pertains. Consent. Where required by law, and in some other cases, we handle Personal Information on the basis of implied or express consent. For instance, we will obtain and rely on your consent to send you newsletters or for the use of certain cookies.
Legal Rights	Right to Access & Portability: You have the right to request that we provide access to and/or a copy of the Personal Information we hold about you (including, in some cases, in an easily accessible format along with information explaining how that data is used). You may also request that we transfer your Personal Information to a third party. Right to Correction: You have the right to request that we update Personal Information about you that is out-of-date or incorrect. Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your Personal Information. Right to Deletion: In certain circumstances, you have the right to request the deletion of your Personal Information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of our business. Right to Object: If we process your Personal Information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will stop processing your Personal Information unless we have a compelling legitimate ground to continue processing or where it is legally necessary. Right to Withdraw Consent: Where we rely on consent, you can withdraw your consent to our processing by using various means we offer, such as an email unsubscribe link. This is without prejudice to your right to permanently delete your Personal Information. We will consider all requests and provide our response within the time period stated by applicable law. Please be aware that certain information may be exempt from such requests in some circumstances. Before responding to your request, we may require that you provide us with additional information to confirm your identity. You have the right to lodge a complaint with the appropriate supervisory authority if you believe our processing of your Personal Information violates applicable law.
Safeguards	Personal Information we collect may be stored and processed for the purposes set out in this Privacy Notice in the United States where we are based or in any country where we have operations or engage vendors or service providers. These countries may have different data protection and government surveillance laws than your country. Some of these countries have received a European Commission adequacy decision. For other countries, we take organizational, contractual, and legal measures, such as entering into written agreements with the relevant third party, to ensure your Personal Information is adequately protected and processed exclusively for the purposes set forth above. In most cases, our legal reason for processing and transferring your Personal Information is to fulfill a contract with you or to provide the services or assistance you have requested. For additional information regarding these transfers, please contact us at privacy@celia-rx.com.
Electronic Direct Marketing	Celia may send you electronic direct marketing subject to national law, if you have not declined such messages. If you do not wish to receive such messages any longer, you can opt-out at any time by following the instructions in those messages or by contacting us at privacy@celia-rx.com.
Contact Information for Controller/DPO	For personal information we process under this Privacy Notice: 405 Elizabeth Street, Austin, TX 78704

6. Additional Disclosures for U.S. Residents

Certain U.S. state privacy laws – such as those in California, Colorado, Virginia, Connecticut, and other applicable jurisdictions – require businesses to provide certain disclosures to residents, including (i) the categories of Personal Information collected, (ii) the purposes for which Personal Information is used or disclosed, (iii) the categories of third parties with whom Personal Information is shared, (iv) your rights with respect to your Personal Information, including the rights to access, delete, correct, or opt out of certain data processing, and (v) how you can exercise those rights. To the extent these laws apply, we provide those disclosures below.

Notice of Collection	While this information is covered in greater detail above, the categories of Personal Information that we have collected – as described by the California Consumer Privacy Act – are: Identifiers. Includes direct identifiers such as name, alias, email, phone number, address, unique personal identifier, online identifier, IP address, or other similar identifiers. Other individual records. Includes your account and profile information and customer records that contain Personal Information, such as name, demographics, and other characteristics or descriptions, contact information, and financial or payment information. Commercial information. Includes records of Services purchased, obtained, or considered, or other purchasing or use histories or tendencies. Internet or other electronic network activity. Includes browsing history, clickstream data, search history, and information regarding interactions with our websites, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services. Location data. Such as general location information or geolocation data about a particular individual or device. Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting consumer preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.
Business or Commercial Purpose for Collecting and Using Personal Information	We collect each category of Personal Information listed above for the business or commercial purposes described in “Personal information we collect” section above.
Categories of Sources of Personal Information	We collect each category of Personal Information listed above directly from you, through automatic data collection means, or through the third-party sources described in “Personal information we collect” section above.
Categories of Personal Information Disclosed	In the preceding 12 months, we have disclosed the categories of Personal Information listed above in the circumstances described in “How we share your personal information” section above.
Selling and Sharing Personal Information	California law requires that we disclose whether we sell or share your Personal Information. We do not “sell” your Personal Information, as that term is defined under California law. However, we may “share” personal information (in the form of identifiers and internet activity information) with third-party advertising partners for the purposes of targeting advertisements for our Services to you on non-Celia websites, applications, and services. In addition, we may allow third parties to collect Personal Information from you on our Services if those third parties are authorized service providers who have agreed to contractual limitations as to their retention, use, and disclosure of your Personal Information.
Right to Opt Out of Selling and Sharing / Personalized Advertising Opt Out	You have the right to direct Celia not to share your Personal Information. You can exercise this right by emailing us at privacy@celia-rx.com or by using the Global Privacy Control (GPC). You can also adjust your cookie preferences to decline all non-essential cookies on our Services. If you notify us of your preference through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal. If you are logged in, your preference will be associated with your account and if you log in from another device or browser, you will be automatically opted out. However, if you are not logged into your account, your request will only be associated with the browser you are currently using.
Right to Limit the Use and Disclosure of Sensitive Personal Information (or Sensitive Personal Information Inferences)	You can request to limit the use of Sensitive Personal Information to only what is necessary for providing goods or services.
Right to Opt Out of Processing for Purposes of Profiling	You may have the right to opt-out of processing of your Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. Celia does not use your Personal Information for purposes of profiling.
Right of Appeal	If we deny (or otherwise refuse to act) on your request to exercise your rights, we will provide you with information about how you can appeal our decision.
Notice of Financial Incentive	We may offer referral programs, points, or other incentivized data collection programs. For example, we may offer incentives to you such as discounts, points, promotional items, or credits in connection with these programs, wherein you provide your Personal Information in exchange for a reward, or provide Personal Information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. The referred party may also receive rewards for signing up via your referral. These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depend on whether the referred party ultimately becomes a customer and uses our Services. Said value will be reflected in the incentive offered in connection with each program.
Non-Discrimination	You have the right not to receive discriminatory treatment by us for the exercise of your rights.
Authorized Agent	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. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification	To protect your privacy, we take reasonable steps to verify your identity before fulfilling your request.
De-identified Data Disclosure	Celia may use de-identified data in some instances. Celia either maintains such data without attempting to re-identify it or treats such data as personal information subject to this Privacy Notice and applicable law.
Shine the Light	California Civil Code § 1798.83, also known as the “Shine the Light” law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. Tiled does not share personal information with third parties for their direct marketing purposes.