Privacy Policy

Table of Contents

1. Alter Privacy Policy
2. DNA Privacy
3. Types of Data Collected & How We Collect It
4. Why We Collect Information
5. Your Choices
6. Security
7. Retention of Personal Information
8. Links to Other Websites
9. How to Contact Us

Alter Privacy Policy

FIT Wind, LLC, d/b/a Alter (“Alter,” “we,” “our,” or “us”) provides fitness technology hardware, software and services that combine DNA, biometrics, wearable technology, computer vision, machine learning and human performance science expertise to deliver a uniquely personalized at-home connected fitness and stress management plan and experience. At Alter, your privacy is important to us, and we are committed to protecting it. By sharing your personal information with Alter, we can provide you a personalized plan, adaptive workouts, and other services.

This Privacy Policy applies to the personal information that Alter collects and processes when you interact with our websites and mobile applications, including alterme.com (our “Sites”), and when you use our services, including DNA services and summaries, health summaries, fitness classes and training programs through AlterSense, vision technology, biometric feedback, and through other services available through your Alter Screen and membership subscription, as well as from your interactions directly with us (collectively, our “Services”).

At Alter, we collect personal information provided by our users as well as data provided or received from other sources. This Privacy Policy describes the types of personal information that we collect, how we use it, how and when it may be shared, and the controls we give you over your information.

By continuing to use the Services you acknowledge this Privacy Policy, and agree to our Terms of Use.

We may change this Privacy Policy to reflect new laws, new services, or for other reasons. When we make a change, we will provide you with notice of such updates as required by applicable law, and will revise the date at the top of this Policy. You are advised to review this Privacy Policy periodically for any changes.

DNA Privacy

At Alter we collect your DNA to recommend a personalized fitness and wellness system, to provide you with a personalized DNA report, to allow your wellness advisor to provide your Alter consultation and discuss your results with you, and to personalize your Alter experience.

How does it work? Alter and our CLIA-certified, CAP-accredited service provider laboratory partners (“Alter Labs”) will send you an Alter DNA Test collection kit to the address you provide us. When you register, complete the test, and return the test to us, we will extract DNA from your saliva in your Alter DNA Test and convert it into information regarding your genotype (e.g., the As, Ts, Cs, and Gs at particular locations in your genome). At Alter, we are focused only on certain portions of your DNA called Single Nucleotide Polymorphisms (SNPs) which will be analyzed from your Alter DNA Test. This analysis looks for common genetic variations among people, and identifies the SNP values that are unique to your DNA. These SNP values help us to identify your genetic predisposition related to several health and wellness attributes. Examples include systemic inflammation, weight loss tendency, and many others. We may also use statistical techniques to infer additional genetic information based on genetic information generated directly through the processing of your saliva sample. With this unique information, we can use your own genes, daily biometrics, and computer vision feedback, to recommend the exercise, wellness, nutrition, and lifestyle strategies that your body is most likely to respond to on any given day.

At Alter, the security of your genetic information is important to us. We use robust data security measures to safeguard your genetic information. Your DNA sample and genetic information are secure with Alter Labs. The results of your DNA test are stored in a secured database. Your DNA sample which you send to us is automatically destroyed by Alter Labs after testing and quality control checks. Additionally, you can ask us to delete your DNA data from our systems anytime, although this may affect the overall useability of your Alter system.

At Alter, we do not presently use your DNA for any scientific research. If that changes, before we use your DNA for any scientific research, we will first obtain your explicit consent. If you choose not to consent, we will not use your DNA for scientific research. Period.

Alter will not provide individual-level genetic information to law enforcement unless required by law to comply with a valid court order, subpoena, or search warrant. We require all law enforcement inquiries to follow a valid legal process, such as a court order or search warrant, and are prepared to exhaust available legal remedies to protect our customer’s privacy. If we are compelled to disclose your individual-level genetic information to law enforcement, we will try our best to provide you with prior notice, unless we are prohibited from doing so under the law. Nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your individual-level genetic information.

Types of Data Collected & How We Collect It

Before we talk about the types of data that are collected and assist Alter in providing the most comprehensive services to you, let’s talk about the things we don’t want.

Alter does not knowingly collect or maintain personal information from persons under 18 years of age, and no part of the Services are directed at persons under 18. If you are under 18 years of age, then please do not use the Services. If you believe that Alter has collected personal information of persons under 18 years of age please contact us at privacy@alterme.com, and we will take the appropriate steps to delete this information.

So, what do we collect?

We collection various types of personal information. Personal information is any information that relates to you, identifies you personally, or could be used to identify you. Personal information does not include information that is aggregated, anonymized, publicly available, or information that cannot be reasonably linked to you.

Aggregate information is information about a group of people, and does not contain information about, nor can it reasonably be linked to, a specific individual. For example, the number of Alter customers with a specific exercise related SNP would be considered aggregate information. Anonymized information is information that has been stripped of all identifying data such that you cannot reasonably identify a specific individual.

Here’s the general types of personal information that we collect when you use our Service.

Account Information: When you purchase our Services or create an Alter account, we collect certain information, which may include your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information (e.g., email, phone number and license number).

Third Party Sign-in: You may create an Alter account and/or sign into our Services using an account you created with a third-party service, such as Google. If you provide authorization to Alter, we will collect and use the information you share with us via that third party service (such as your email address, name, and date of birth as specified in your third-party service account) in accordance with this Privacy Statement. You are responsible for managing your credentials for your third-party service account, and for maintaining the security of your third-party service account. Alter does not have access to the credentials for your third-party service account. If you choose to use third party sign in and you lose access to your credentials for your third-party service account, you may not be able to access your Alter account. You may manage authorization for third party sign in through your Alter Account Settings or through your third-party service account.

Kit Registration Information: To receive the complete benefits of the Alter experience, among other things, you must purchase or receive as a gift, an Alter DNA Test collection kit (“Alter DNA Test”). Before you ship the Alter DNA Test with your saliva sample to us or our third-party laboratory for processing, you must register your Alter DNA Test on the website using the code on the swab. You will also be asked to provide information about your birthday, ethnicity, biological sex, and your workout interests and goals.

Genetic Information: Your DNA sample and genetic information are secure with Alter Labs. For more information, see our detailed DNA Privacy section above. 

Self-Reported Information: You have the option to provide us with additional information about yourself through screenings, surveys, forms, features, and applications. For example, you may provide us with information about your health history, gender, personal exercise habits (e.g., types and number of workouts), ethnicity, disease conditions (e.g., Type 2 Diabetes), other health-related information (e.g., injuries, limitations), and goals. Workout Data: When you participate in the Alter program, we collect various types of Workout Data, which is used to help create custom fitness plans, track your progress, to provide real time changes to your Alter workouts and plans, and to enable you to build your user profile so you can share your successes with other users.

Information You Provide: You can provide us with certain health data, including height and weight data, exercise data, or other physical patterns or rhythms from your workouts or fitness goals. We may use information that you share to create a profile of your aspirations, goals, and accomplishments to provide you with suggestions to help you reach fitness goals.

Information Received from Our Service: Our systems automatically collect information about your workout history, such as your total number of AlterSense classes taken, the dates you took those classes, fitness performance history (including leaderboard rank, achievements earned, total output, calories burned, range of motion data), and other data to the extent you have worn the Alter Signal since your last login. We may also collect a record of the workouts and AlterSense Classes you have accessed on the Services, including titles, trainers, date, time, duration of the Alter Workouts and the duration of your participation.

When you wear your Alter Signal, we collect information about your heart rate, activity, motion, and sleep.

When you use the Alter Screen, our computer vision technology, AlterSense, uses imaging graphics that collect information about your body movements and kinetics during Alter workouts. If you choose, the Alter Screen and Alter App may allow you to record information about your own Alter workouts, including video from your Alter Screen, and share that information with Alter or other users. Alter does not record, save, or upload any video information from your Alter Screen without your express consent.

Customer Service: When you contact Customer Service or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Use, and analyze and improve our Services.

Contest and Promotions: If you choose to participate in a context or promotion we offer or sponsor, we will collect certain personal information, which will be described upon entry.

Usage and Device Information: When you visit our Site and use our Services, we collect certain information about how your use our Services, such as your IP address, internet service provider, operating system, browser information, device information, browsing history, and your interactions with the Services. We may use cookies and other similar tracking technologies (collectively “cookies”) to collect this information. We use this data to analyze trends on and use of our Sites, help us recognize you when you use our Services, customize and improve your experience, manage and administer the content, improve security and availability of the Services, improve the performance of the Services, and for fraud protection and to protect our rights and the rights and safety of individuals. We may use this information to serve personalized or targeted advertising and/or marketing on our Site and on other sites around the Internet, subject to the applicable law.

Blogs and Forums: Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission ("User Content"). Our Site may offer publicly accessible blogs or online forums that contain User Content. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. Please note that when you post something publicly, it may sometimes be impossible to remove all instances of the posted information, for example, if someone has taken a screenshot of your posting. Please exercise caution before choosing to share personal information publicly on our blogs, Forums or in any other posting. To request that we remove or de-identify your personal information from our blog or Forums, contact us at privacy@alterme.com. You may be required to register with a third-party application to post a comment. To learn how the third-party application uses your information, please review the third party's terms of use and privacy policy.

Social Media Features and Widget: Our Services may include Social Media Features, such as the Facebook "Like" or "Share" button and widgets ("Features"). These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Feature to function properly. They may also allow third party social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the third-party social media service. Features are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy policy of the third-party company providing them. You should always review and, if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to our Site or Service.

Third Party Services (e.g., social media): If you use a third party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person's name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third party site. We do not control the third-party site's information practices, so please review the third party’s privacy statement and your settings on the third party’s site carefully.

Gifts: If you provide us with personal information about others, if others give us your information, or if you authorize another individual to share or send your personal information to our third-party service provider(s) for the purpose of ordering the Service or other personalized gift(s), we will only use that information for the purpose for which it was provided to us. These purposes may include, for example, where you provide us with a friend’s or family member’s shipping address when placing an order. Once a gift recipient registers for our Services and agrees to our Terms of Use, and if applicable, certain consent documents, their personal information will be used in manners consistent with this Privacy Policy, and will not be shared with the purchaser, unless they independently choose to share their own personal information through the Services with the purchaser. Information shared directly with our third-party service provider(s) for personalized gifts are subject to such third party’s terms of service and privacy policy, and are not subject to this Privacy Policy.

Why We Collect Information

Unless otherwise stated above, we use the information we collect to:

• Provide our Services to you
• Allow our support teams to communicate with you, or to share information about our Services or other offers or information we think may be relevant to you;
• Personalize, contextualize, and market our Services to you;
• Develop, operate, improve, maintain, and safeguard our Services, products, and features;
• Enhance the safety, integrity, and security of our Services, including prevention of fraud and other unauthorized or illegal activities on our Services;
• Enforce, investigate, and report conduct violating our Terms of Use or other policies;
• Conduct surveys or polls, and obtain testimonials or stories about you;
• Comply with our legal, licensing, and regulatory obligations; and
• Analyze and measure trends and usage of the Services.

We may use some personal information to market our products and offers from us or our business partners. This marketing includes advertising based on your interests. However, Alter does not share your Genetic Information with third-party marketers, insurance companies, or employers, and we will not use your Genetic Information for marketing or personalized advertising without getting your explicit consent.

We Do Not Sell Personal Information

Your user data is not for sale. Alter does not sell your personal information, Genetic Information, biometric data or other health data to any third parties. This includes information we receive from third parties you provide us access to, such as Health Connect, Apple Health or other sources of user data.

Protecting Genetic Information and Personal Information

Alter does not share your individual personal information, including your Genetic Information, with third parties except as described in this Privacy Policy or with your additional consent. Rest assured, your Genetic Information and health data is never transferred to third party advertisers, data brokers or information resellers. Furthermore:

Alter will not voluntarily share your Genetic Information with:

• Public databases;
• Insurance companies or employers;
• Law enforcement, absent a valid court order, subpoena, or search warrant.

We may, however, share personal information about you as follows:

• With Alter Partners who have contracted with us to operate our site and Services and require this information to bring our Services to you or improve the Services you receive from us, as discussed in our Terms of Use.
• With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf.
• In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, bankruptcy, divestiture or dissolution of all or a portion of our business (but only under non-disclosure and confidentiality agreements and protections).
• With our outside professional advisors such as attorneys or accountants to facilitate the professional advice from those professional advisors.
• If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; to enforce applicable user agreements or policies; to protect the security or integrity of our Services; and to protect us, our users or the public from harm or illegal activities.
• With your consent.

We may also share aggregate information with third parties.

Your Choices

We give you account settings and tools to access and control your personal information.

Access, Correction, or Export: You may access update or correct information about yourself by logging into your account. You can download information in a commonly used file format by emailing us at privacy@alterme.com.

Edit or Delete: By logging into your account, you can edit your information. You can also delete your Alter Account within your Account Settings at any time. Keep in mind this process cannot be canceled, undone, withdrawn, or reversed, and your account deletion is subject to retention requirements. If you choose to delete your account, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data recorded by your Alter Signal and other data stored in our backup systems. We may also preserve data for legal reasons.

“Do Not Track” Signals: We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes, and that is why we provide above the Network Advertising Initiative’s “Consumer Opt-out” link, Digital Advertising Alliance’s Consumer Opt-Out Link, and TRUSTe’s Advertising Choices page.

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

The security of your personal information is important to us. We maintain administrative, technical and physical safeguards designed to protect your information’s security, confidentiality and integrity. These safeguards include, among other things, facility and data access control, password protection, encryption of data at rest and in transit, security monitoring tools and protocols and the appointment of a Security Officer and a Data Protection Officer who oversee and manage privacy and security.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone. We urge you to be careful about giving out information in public areas of the Site like message boards. The information you share in public areas may be viewed by any user of the Site.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to Site and Services, any transmission of your information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Retention of Personal Information

We retain personal information for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Alter Labs will only retain your Genetic Information, date of birth, and sex as required for compliance with applicable legal obligations, including the federal Clinical Laboratory Improvement Amendments of 1988 (CLIA), California Business and Professions Code Section 1265 and College of American Pathologists (CAP) accreditation requirements, even if you chose to delete your account.

Alter will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, communications related to inquiries or complaints and legal agreements for a limited period as required by law, contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.

Links to Other Websites

Our Services may contain links to other websites and those websites may not follow the same privacy practices as Alter. We are not responsible for the privacy practices of third-party websites. We encourage you to read the privacy policies of such third parties to learn more about their privacy practices.

Assistance For The Disabled

Alternative formats of this Privacy Statement are available to individuals with a disability. Please contact us at accessibility@alterme.com for assistance.

How to Contact Us

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have questions, please contact the DPO with any questions, concerns, or complaints regarding this Privacy Policy at privacy@alterme.com or contact us at:

FIT Wind, LLC d/b/a Alter

2825 E. Cottonwood Pkwy, Suite 500

Salt Lake City, UT 84121 Email: privacy@alterme.com