Suracell is a U.S. based company whose mission is to integrate proven state of the art genetics knowledge and technologies, and individual environmental and lifestyle influences, into customized wellness programs. Suracell's clients submit DNA and Biomarker samples for testing and answer an Environmental and Lifestyle questionnaire, and based on a personalized analysis of these factors, Suracell recommends individualized wellness protocols of nutraceuticals for clients, mediated by their physicians. Personalized programs are delivered over a secured web based platform that meets the industry's highest standards for encryption and information protection. Suracell maintains the highest level of privacy and security supported by the latest and most effective technology, and is fully compliant with privacy laws and regulations, including, but not limited to HIPAA, and is also a TrustE licensee.

Suracell's Commitment to Privacy

Suracell believes that consumers can make informed decisions about disclosing personal information only after fully understanding how it collects, maintains and uses such information. This is why Suracell wants you to know what its privacy policy and practices are. Suracell understands that you may be concerned about the privacy of your personal information, and recognizes the importance of strong protections and appropriate management of any information you choose to share with Suracell. That is why Suracell is strongly committed to maintaining your personal information as strictly confidential according to the highest standards of privacy protection. Furthermore, to demonstrate our commitment to safeguarding your privacy, we guarantee that you have full control over the uses of your personal information.

The Federal Trade Commission (FTC) established Fair On-line Information Practices that represent the closest thing to an industry regulatory standard for privacy practices. The FTC defines fair information practice as

1. providing full disclosure about what information is collected and how it is used,
2. giving consumers a choice about how their personal information is used,
3. providing consumers access to their personal information,
4. securing all obtained information to ensure it is kept strictly private
5. establishing redress procedures that allow consumers to resolve problems that may arise with the company's handling of private information.

Suracell's senior management assumes complete responsibility for maintaining full compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Gramm-Leach-Bliley Act (GLBA), and any other applicable state and federal privacy laws. Suracell guarantees that in the event that Suracell ever receives, or creates, protected health information, as defined under HIPAA and / or non-public personal information, as defined under GLB, all regulations will be fully complied with. Suracell has established policies and procedures to penalize any compliance failures. Such failures by Suracell employees could result in employment termination or legal action.

Suracell's Collection of Information

Visitors to its site:

Suracell respects the privacy of individuals who visit our web site and for this reason anyone can visit our site without telling us anything about themselves. From time to time our website may be configured to collect web-domain information as part of our analysis of how people use our site. This is a common practice that most companies follow to better understand the aggregate users of their website, and the type of usage. Suracell gathers this information in order to improve its website to better serve its users. This web-domain information does not identify any specific individual. We only gather certain information based upon how visitors access our web-site. For example, this information could include what browser is used and the user's Internet Protocol ("IP") address. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate and browse on the Internet. On an aggregated basis, we may collect anonymous data related to the web pages that are accessed, clicked on, and searched for, and this data may be used by Suracell internally to improve its ability to serve its customers and visitors.

Some pages and functions on the Suracell website require use of a technology called "cookies". This is also common practice on most websites. Cookies are small files that the Suracell website places on your hard drive for the purposes of tracking user identification, enhancing functionality and tracking page navigation. Suracell does not gather or store any permanent information from use of cookies during a user's interaction with the Suracell website. You should note that cookies cannot read any information off of your hard drive. Further, your web browser can be configured to allow you to be notified when you are receiving a cookie, and give you the choice to accept it or not. You can also refuse all cookies by turning them off in your browser's internet options. You do not need to have cookies turned on to use any informational area of our web site, but cookies must be turned on to allow product purchases, and to allow registered users of the website to sign in to their Suracell accounts. Any information used by Suracell via use of cookies is collected automatically and requires no action on your part. If you have suggestions about how Suracell can improve its website, we encourage you to send them to webmaster@suracell.com

Collection of Personal Information from Customers

Suracell does not obtain any personal information without prior customer consent. Suracell does not use disclosed information in any ways other than those specifically authorized by its customers. Furthermore, Suracell does not share or sell any personal information to third parties, unless as described in this privacy statement.

When you register on the Suracell website, order Suracell products online, or elect to participate in the Suracell program, Suracell collects "personally identifiable data" that identifies you in some way, such as your mailing address, your telephone number or your answers to the Suracell environmental and lifestyle questionnaire. "Personally identifiable data" can also refer to your biological data, such as any samples you may submit for testing. None of this data is ever shared with any outside individual or business entity unless you have provided us with specific prior permission.

Registration:

If you want to participate in the Suracell program, we require that your tests be registered on our website. The registration process requires that you provide us with some "personal information", such as your name and email address. This is done so that Suracell can provide you with your personal login, give you an account domain where you can go to access your personal wellness information, and contact you if necessary, such as if problems processing your order arise, or if your specimen(s) that were sent cannot be tested. In the latter case, we would notify you that we need you to repeat the specimen collection process. Suracell will not contact you, however, unless you have given us prior authorization to do so. When your test is registered, a registration number is created which is included with your samples when they are sent to the processing laboratory. The laboratories that analyze your samples and provide Suracell with test results use only the test registration number to identify test results returned to Suracell. Suracell then matches that number to a highly secured database, so that test results are associated with the correct client. This mechanism enables Suracell to keep your genetic information strictly private and anonymous to any party when being processed by outside entities such as the clinical laboratories. Suracell's secure database is accessible only to a few highly trained Suracell staff who are in charge of making sure that you receive the correct results and regimen. Any failure to maintain Suracell's strict confidentiality of personal information results in disciplinary action against the person involved, including possible termination of employment, or, if warranted, criminal prosecution. Suracell reserves the right to contact you about any aspect of their current and future health and age management programs, but only with your prior consent.

Collection of Customer Information

If you purchase products from our web site, we require that you complete an order form which involves sharing some personal information, such as your name, email address, mailing address, billing address, telephone number and payment information, so that we can process your order. Credit card information is used solely for fulfilling customer orders. In the event of order processing problems, Suracell uses the contact information you provide to reach you in order to resolve such problems.

Service Providers

We use other third parties to provide credit card processing as well as shipping services for our site. When you purchase a product, we will share your shipping information such as your name and address as well as your credit card information as necessary for these third parties to provide that service. These third parties are prohibited from using your personal information for any other purpose.

Testing and the Suracell Program:

If you choose to undertake the Suracell program, Suracell will request that you provide two types of personal information;

1. individual identifying information that is not health related (such as your name and address)
2. individual identifying information that is health related; such as your specimen containing DNA and/or Biomarkers, and the answers to your online environmental and lifestyle questionnaire.

Suracell only obtains the personal information that you agree to disclose to us. (See the informed consent form acceptance on the Suracell website, which is required before genetic health information can be generated). Everyone who chooses to share personal information with Suracell nonetheless owns and controls that information. Please note that you will receive the most accurate results if you answer all of the questions in the online questionnaire.

Collecting Information From Prospective Partners

Suracell will also collect personal information from physicians and health care practitioners who are looking to become partners of Suracell. We will collect their contact information such as name, phone number, address and email. We collect these forms of personal information so we can contact them directly to discuss partnerships. Also, if a partnership materializes out of the collection of this information, the information may be posted publicly on our website in the “Our Partners” section so the clients can find Suracell Partners in their area. If at any point in time the partners want to edit or remove their information from the website and terminate the partnership, they are able to do so by contacting us via telephone at (973) 932-1200 or via email at address contact@suracell.com, or in writing to our mailing address at: Suracell Inc., 184 S. Livingston Avenue #113, Livingston, NJ 07039-3011.

How Suracell Keeps your Personal Information Confidential and Secured

Immediately upon completion of testing, your specimen(s) are destroyed. This prevents any unauthorized access or usage.

Your DNA and Biomarker samples and all other personal health information is kept strictly confidential by "de-personalizing" the data, as explained above, by the use of the test registration number. Tests and assessments are done only on "anonymous" data identified only by the test registration number. Suracell's experts, in other words, do not know whose data they are evaluating. The few highly trained Suracell staff who are authorized to access your personal information, are prohibited from sharing any of that information with anyone, unless under exceptional circumstances, such as when ordered by a court. For example, as with written records, Suracell may be required by law or judicial authority to release your personal information, such as in the event of a court order or search warrant. Suracell will always notify you in advance of making the required disclosure, unless court order prohibits prior notification. All Suracell employees are strictly prohibited from sharing any information with any third party. Furthermore, all Suracell employees are obligated to abide by this Privacy Policy and Practices. Anyone who violates these conditions is subject to disciplinary action, up to and including termination or possible criminal prosecution.

Suracell's Use of Personal Information Collected

Suracell uses the personal information it collects to generate your personalized wellness program, which involves providing you or your designated physician or health care practitioner with your test results, and your personalized nutraceutical regimen. All personal information that is sent from the laboratories to Suracell and used to determine your individual personalized program is de-identified until the very last step of matching your results and program to your personal information so that it may be properly and securely delivered to you or your physician or health care practitioner.

Suracell meets, if not exceeds, industry standards for assuring data integrity and confidentiality. The loss, misuse or alteration of personal information is controlled by various measures. All personal information transmitted online is carried and stored by a data network which is protected by firewalls, password protections and encryptions using Secure Socket Layer ("SSL"/HTTPS) technology that encrypts all data before being transmitted or stored via Suracell's secure network. While transmitting personal information is never absolutely 100% risk free because there is always some risk of loss, misuse or alteration, the risks in transmitting information to Suracell are exceedingly low, and more secure than other common methods of communication such as your use of the telephone or US Postal System. Suracell encourages clients to check and make sure that their personal information is fully accurate Clients may request a copy of information provided and / or contact Suracell to correct errors by emailing contact@suracell.com, or calling 1-973-932-1200.

What choices do you have about the collection, use and distribution of your information?

Access to and Ability to Correct Personal Data

All customers have the right to access their online account at any time in order to correct mistaken information. Upon request, Suracell will provide you with a summary of any or all personal data that you've shared with us. You may contact Suracell at any time via telephone at (973) 932-1200 or via email at address contact@suracell.com, or in writing to our mailing address at: Suracell Inc., 184 S. Livingston Avenue #113, Livingston, NJ 07039-3011. You have the right to request that such information is modified, corrected, updated or removed from our database. We encourage you to correct any inaccuracies, especially because the quality of our advice to you strongly depends on the accuracy of the information provided in your questionnaire. Suracell will only contact you at the email address held on file for you.

"Opting-out" of Receiving News and Information from Suracell

On the "Billing Address" page that appears when new clients make an online purchase there is a question which asks whether you, as a client, wish to receive news and product updates from Suracell. The default value is "No" ("opt-out"), so if you do not wish to be contacted for these purposes, leave the check box at "no" -- you do not need to do anything further. However, if you choose to select "Yes" ("opt-in"), then at some future time decide you do not wish to be contacted for these purposes, you may sign in and select "My Profile" and update your profile by selecting "No" ("opt-out") to this question.

You may also contact Suracell directly to have your profile setting set to "No" ("opt-out"). To do this, you may either call 973-932-1200, or email us at contact@suracell.com, or write to us at our mailing address at: Suracell Inc., 184 S. Livingston Avenue #113, Livingston, NJ 07039-3011. On your request, we will set your profile to "opt-out" and you will not be contacted in any form for the purposes of receiving any news or promotional information.

Withdrawal of Consent

As with any purchase, you have the right to change your mind and ask for a refund. That is, you have the right to change your mind about whether to have your specimen(s) tested and receive your personal genetic information. If you purchase a Suracell test kit but elect not to take the test, the kit may be returned within 30 days for a full refund. If you take and register a test, but then do not send in your samples, the kit may be returned (minus the used specimen collection items) within 30 days for a refund. If you change your mind after sending in your samples and registering a test kit, you may contact Suracell at any time and your samples will be discarded, testing will not take place, or, if testing has already occurred, your test results will be destroyed and hence made unavailable to yourself or anybody else. If analysis of your test has been completed and the test results already made available, you can request that the results be discarded and erased. If you further decide that you do not want Suracell to retain any information about you or related to you in any way, you can request that Suracell delete all of your records from our database, and this will be done immediately on request. You may contact Suracell at any time via telephone at (973) 932-1200 or via email at address contact@suracell.com, or in writing to our mailing address at: Suracell Inc., 184 S. Livingston Avenue #113, Livingston, NJ 07039-3011.

Accountability

Suracell has a Security Officer who is accountable to senior management reporting to Suracell's Board of Directors. The Security Officer is responsible for enforcing corporate data security policies and practices, including privacy protection practices.

Suracell may, at any time, revise this Privacy Statement by updating this posting. Any revisions will be posted on our homepage so that visitors, as well as customers, are fully informed of our privacy policy and practices.