Cellera Privacy Policy

1. What Information We Collect

The types of information we collect depend on how you use the Services and what permissions you grant. Below are detailed categories:

a) Personal & Identifying Information

• Name, email address, phone number, physical address
• Account credentials (username, password)
• Payment information (e.g., credit/debit card, billing address). We do not store full card numbers or sensitive payment credentials on our servers. All financial transactions are processed through a third-party payment gateway (currently Stripe), which is PCI-DSS compliant and securely handles your payment details on our behalf.

b) Health, Clinical & Biometric Data ("Healthcare Information")

Collected only if you provide access or submit it, or via connected devices:

• Wearable data: heart rate, HRV, respiratory rate, activity (type/duration), sleep stages, glucose, SpO₂, temperature, stress metrics
• Lab results, diagnostics, imaging (e.g., bloodwork, genomics, MRI, DEXA)
• Medical history, medications, prescriptions, diagnoses
• Lifestyle and behavior data: diet, supplements, mood, stress, sleep, female health tracking, self-reported inputs

c) Technical & Usage Data

• Device identifiers, operating system, app version, browser type
• IP address, geolocation (if permitted), log data, crash reports
• App usage metrics, feature interactions

d) Derived Data & Inferences

• Metrics, risk scores, trends, "biological age," or similar outputs generated using your raw data
• Preferences inferred from your behavior, device usage, health trends

e) Cookies & Tracking Technologies

• Cookies, pixels, web beacons for analytics, functional, essential, marketing purposes
• Third-party analytics, ad-tracking (with opt-outs where required)

2. Legal Basis & Consent

Depending on your location and data type, our legal basis for processing includes:

• Your consent: for collecting and using personal & health data, for research, for marketing communications, AI assistant operations
• Performance of contract: to deliver the Services you sign up for
• Legal obligation: to comply with laws, regulations, HIPAA, etc.
• Legitimate interests: for Service improvement, fraud prevention, analytics, but only where such interests do not override your rights/privacy (especially health data requires stronger safeguards)

2A. Roles & Responsibilities

• Cellera acts as a controller for your account, app operations, analytics, and customer support.
• When we provide services to a clinic or medical group, we may act as a processor for that organization.
• Medical groups, labs, and pharmacies may act as independent controllers/covered entities, and their Notices of Privacy Practices or privacy policies govern their processing. Links to those notices will be provided where applicable.

3. How We Use Your Information

We use your information in the following ways:

• To deliver core functionality: health insights, personalized protocols, telehealth, diagnostics, labs, pharmacies, product fulfillment
• To power and operate our AI assistant (zero-training of identifiable data unless you consent)
• To improve and develop Services, conduct de-identified research, and validate clinical outcomes
• To determine your eligibility for particular services, tests, or protocols
• To communicate with you: account notices, health alerts, lab results, reminders, customer support
• To send marketing/promotional content (with opt-out)
• To prevent fraud, manage security, and comply with regulations

4. Disclosure & Third-Parties

We may share your information under certain circumstances:

• With service providers (labs, pharmacies, logistics, payments, cloud, analytics)
• With healthcare providers you connect to
• With research/analytics partners (only de-identified or aggregated data unless you consent)
• With AI model hosts when you use our assistant (minimum necessary, no training on identifiable data without consent)
• With regulators/legal authorities when required
• In business transactions (merger, acquisition, sale of assets)

Payments

To process transactions, we rely on a third-party payment gateway (currently Stripe). Stripe processes your payment credentials directly, and we only receive limited information necessary to confirm the transaction (e.g., payment confirmation, billing details). Stripe's own privacy policy and security practices apply in addition to this Privacy Policy.

Independent Labs & Pharmacies

Laboratory testing and pharmacy fulfillment may be performed by independent third parties. When they process your data, their privacy policies and terms apply to their processing activities, and they may be independent controllers of your data.

5. Data Storage, Security & Encryption

• Data is encrypted in transit (TLS) and at rest
• End-to-end encryption for certain synced/backed-up health data
• Role-based internal access, least privilege, audit logging, periodic access reviews
• Device-level security (PIN, Face ID, Touch ID) enforced
• Regular third-party security testing, incident response protocols

6. Data Retention

We retain data only as long as needed, subject to law. Typical retention periods:

• Raw wearable streams: 24–36 months
• Derived insights/protocols: 36 months
• Telehealth/clinical visits: 24 months or longer if legally required
• De-identified research data: until study end + 5 years
• AI assistant chat: ~12 months unless deleted sooner by you
• Financial and transaction records (e.g., invoices, receipts, billing details): retained for up to 7 years to comply with tax, accounting, and financial reporting obligations.

After retention, data is securely deleted or anonymized.

7. Your Privacy Rights & Controls

Depending on your jurisdiction, you may have rights that include:

• Accessing and obtaining a copy of your personal/health data
• Correcting or updating inaccurate/incomplete data
• Deleting data (all or by category/timeframe/provider)
• Exporting data (CSV/JSON/FHIR)
• Withdrawing consent for certain uses
• Restricting or contesting processing
• Portability between providers

Appeals

If we decline to act on your request, you may appeal within 30 days via appeals@cellera.ai. We will inform you in writing of any action taken or not taken in response to the appeal. If you remain unsatisfied, you may contact your state Attorney General or relevant authority.

Automated Decision-Making

We do not make decisions with legal or similarly significant effects solely by automated means. If we introduce such features, we will provide required notices and a way to request human review, to contest the decision, or to opt out where applicable.

Privacy & Sharing Dashboard

Available in-app to manage permissions, revoke third-party access, delete data, export data, update communication preferences, and clear AI assistant chats.

8. Children's Privacy

The Services are not intended for users under 18 years. We do not knowingly collect data from minors. If we learn we have, we will delete it.

9. U.S. State Privacy Laws & Consumer Health Data Protections

Cellera is based in the United States, and your information may be processed in the U.S. and other countries. We apply safeguards as required by applicable law.

State Law Rights

If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you may have additional rights under CPRA, CPA, CTDPA, or UCPA, including:

• The right to know what categories of personal information we collect, disclose, and/or sell/share.
• The right to access a copy of your personal information.
• The right to correct inaccuracies in your personal information.
• The right to delete personal information, subject to exceptions.
• The right to opt out of the "sale" or "sharing" of personal information for targeted advertising or profiling.
• The right to limit the use and disclosure of sensitive personal information.

To exercise these rights, submit requests via email to privacy@cellera.ai. We will verify your identity before processing your request. Authorized agents may act on your behalf where allowed by law.

Sensitive health/biometric data is processed only with your explicit consent and is never used for advertising purposes.

Consumer Health Data (WA & NV)

If you are a resident of Washington or Nevada, we comply with state consumer health data laws, which include:

• Requiring separate consents for collection and sharing of consumer health data.
• Requiring distinct authorizations for any sale of consumer health data.
• Providing a process to appeal denied requests (see Appeals in Section 7).
• Prohibiting the use of geofencing around healthcare facilities to infer sensitive health information.

Global Privacy Control (GPC)

We recognize and honor a user-enabled Global Privacy Control (GPC) signal as a valid request to opt out of the "sale" or "sharing" of personal information, where required by law. This allows you to exercise certain rights automatically through your browser settings.

10. Cookies, Tracking Technologies & Advertising Signals

We use a variety of tracking technologies to support and improve our Services.

Types of Cookies and Technologies

• Essential Cookies: Required for login, security, and basic functionality.
• Functional Cookies: Remember your settings and preferences.
• Analytics & Performance Cookies: Measure usage and improve app reliability.
• Marketing Cookies: Support promotional campaigns (disabled unless you consent).

Consent Management

• Non-essential cookies are disabled by default until you provide consent, where required by law.
• You may withdraw consent at any time via our Privacy & Sharing Dashboard or device settings.

Opt-Out Mechanisms

We support industry opt-out tools, such as the Network Advertising Initiative (NAI) and Digital Advertising Alliance (DAA).

We also honor GPC browser signals where required by law.

Restrictions on Health Data

We do not use or share health, biometric, or genetic data for targeted advertising or cross-context behavioral advertising.

11. AI Assistant & Telehealth

AI Assistant

• Data is shared with AI model hosts only when you actively use the assistant.
• Identifiable personal or health data is never used to train models without your explicit consent.
• You can review and delete your assistant history directly in-app.

Telehealth Services

• Use of telehealth services requires your informed consent.
• Telehealth records are accessible to you and disclosed only as authorized or required by law.
• Affiliated medical groups, labs, or pharmacies may maintain their own privacy policies or Notices of Privacy Practices, which apply in addition to this policy.

Limitations

Telehealth features are not a substitute for emergency medical care. If you are experiencing a medical emergency, call 911.

12. Vendor & Sub-Processor Transparency

Engagement of Vendors

We engage third parties to provide services such as laboratories, pharmacies, payment processing, cloud hosting, analytics, and logistics. These vendors may act as "sub-processors" with access to your personal information solely to perform their contracted functions.

Sub-Processor List

We maintain a current list of sub-processors on our website, including their roles and the categories of data they process.

Notification of Changes

We will provide advance notice before adding or replacing sub-processors, via our website or in-app notice.

Safeguards

• All vendors are contractually required to implement appropriate technical and organizational measures to protect your data.
• Vendors are prohibited from using your data for any purpose other than delivering services to Cellera.
• Vendors must notify us of any data breach or security incident without undue delay, and we will notify you where legally required.

13. Changes to this Policy

We may update this Privacy Policy periodically. If changes materially affect your rights or our practices, we will provide prominent notice (email, app alert, or website banner) and request re-consent if required.