Thank you for your interest in Verily Life Sciences, LLC (“Verily,” “we” or “us”), an Alphabet Inc. (“Alphabet”) company. Verily values your privacy and the security of your information. This Privacy Policy has information about how we collect, use, and disclose information about you.



This summary contains highlights about how we handle your personal information (including personal information from the European Union, United Kingdom, and Switzerland). For a complete description and additional details, please read our 

, such as contact and demographic information. 

 that we collect as part of clinical studies or when you use our wearable devices, including biospecimens and biometric authentication data.

Online information collected automatically

, such as information about your device (including geolocation), internet activity, and information collected using cookies.

, including research-related recruitment, analytics, and management.

, including product development and improvement, account management, and for legal, security, and safety purposes.



: Entities that we may contract with to support our operations and to help us operate our technology and services.

: Auditors, attorneys, accountants, and similar professionals.

Depending on where you reside (e.g. United States, European Union, United Kingdom, or Switzerland), you may be able to exercise privacy rights regarding your personal information, such as obtaining a copy of your data, deleting your data, and other rights described in the 

 below. If you have any questions about this Privacy Policy or our privacy practices, you may contact us at 

 or via mail at Attn: Verily Privacy Office, Verily Life Sciences, LLC, 2999 Olympus Blvd, Ste 1000, Dallas, Texas, 75019.

You can jump to specific topics in our full privacy notice by clicking on the links below:

<div id="introduction"><h3>INTRODUCTION AND APPLICABILITY</h3>

<p>This Privacy Policy describes how we handle Personal Information we collect when you interact with our products, services, and digital properties that specifically reference this Privacy Policy (collectively, our “Services”). Examples of our Services include mobile applications, digital biomarkers (including digital and wearable devices), websites, online advertisements, platforms and communications that relate to clinical and research-related studies, and care management platforms and solutions.<br>

This Privacy Policy applies when Verily is responsible for making decisions about how your Personal Information is used and disclosed (as a “controller”). This Privacy Policy does not apply to information that Verily handles to perform services on behalf of Verily’s business customers (as a “processor”), including business customers that are healthcare providers, health plans and research sponsors. In those cases, our business customers (not Verily) control how your information is handled, so we encourage you to review our customers’ privacy policies. This Privacy Policy also does not apply to certain information that is subject to health regulations, such as the Health Insurance Portability and Accountability Act (“HIPAA”) and ethical frameworks governing research studies (like the Common Rule) that apply to some of the research studies and clinical trials we manage. Verily may also provide you with a more specific privacy policy for certain services, in which case that more specific privacy notice will apply rather than this Privacy Policy.&nbsp;&nbsp;<br>

For example, Verily may manage wellness programs and research studies as a “processor” (or “business associate” when subject to HIPAA) to our business customers, such as health plans, healthcare providers, and research study sponsors.&nbsp; In many cases, the information we handle as a “processor” will be similar to the information that we collect as a “controller” (such as health information and your contact information) and used for similar purposes as described in this Privacy Policy. However, when we handle this information as a “processor,” our business customer’s privacy policy applies to that information instead of this Verily Privacy Policy, and you should contact that business customer with questions or to exercise any data subject rights.<br>

Please read this Privacy Policy carefully. Using the Services is voluntary. By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.</p>

<div id="categories-of-information-we-collect"><h3>CATEGORIES OF PERSONAL INFORMATION WE COLLECT</h3>

<p>Depending on how you interact with our Services, we may collect the following categories of “Personal Information” (meaning data that identifies you or can reasonably be linked to you):<b></b></p>

<li><b>Direct identifiers and contact information</b>, including your name, address, phone number, email address, business contact information, user profile data, government identifiers (such as your Social Security Number or driver’s license), or other similar identifiers.<br>

<li><b>Records about you</b>, including the information we collect in clinical or research study-related activities and medical testing activities (such as biospecimens) and other health related information (including information collected when you use wearable and other devices (e.g., Study Watch), such as pulse rate, body movements, and similar information).<br>

<li><b>Demographic and user information</b>, including gender, age and date of birth, race, ethnicity, location, signatures, photos, and user data obtained through surveys or questionnaires, such as study eligibility surveys.<br>

<li><b>Biometric data</b>, such as facial identifiers used to verify your identity if you enroll in a research study.&nbsp;<br>

<li><b>Internet or other electronic activity information</b>, including information about how you and your device interact with the Services. Examples include device type, browser, interaction dates and times, search history, how you interact with our communications (such as when you open an email/text message you received from us, the date and time you access and open them, etc.), precise and non-precise geolocation information derived from your IP address, information you enter into online forms, and similar usage data.<br>

<li><b>Professional or employment-related information</b>, such as academic credentials, job title, organization, professional licenses, professional affiliations and similar information we may collect in the context of your business relationship with us.<br>

<li><b>Account registration information</b>, such as your email address and user profile data you provide when you create or update your account and when using or interacting with our Services.<br>

<li><b>Commercial information</b> about individuals and business representatives, including purchase or subscription information, information about products you order, credit card number, name on credit card, expiration date, security code, and billing address, and information required for financing purchases.<br>

<li><b>Inferences</b> drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our Services.<br>

<li><b>Sensitive or “special” information.</b> Some of the Personal Information described above may be considered “Sensitive” or “Special” Personal Information in certain jurisdictions, such as biospecimens, biometric data, health information, government identifiers, race and ethnicity, and precise geolocation information (you can disable geolocation information using your device’s settings). Where permitted by applicable law, we collect and process such information in connection with clinical or research activities, to verify your identity, to process payments, and for other purposes described in this notice.</li>

<p>You can choose not to share your Personal Information, but that may mean we cannot deliver the Services you request, including enrolling you in a clinical or research study.</p>

<div id="sources-of-personal-information"><h3>SOURCES OF PERSONAL INFORMATION</h3>

<p>We collect your Personal Information in the following ways:</p>

<li><p><b>Directly from you</b>, such as when you use or purchase our Services, register for an account, create a profile, join a research study, contact us, respond to a survey, or sign up to receive emails, text messages, or postal mailings.&nbsp;</p>

<li><p><b>Through cookies and other tracking technologies</b>, such as when you visit our websites, use our mobile applications, open or click on emails we send you, or interact with our advertisements. We or third parties we work with collect information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please review our <a href="/cookie-policy" target="_self" rel="noopener noreferrer">Cookie Policy</a>.&nbsp;</p>

<li><p><b>Through digital and wearable devices</b>, such as Verily’s Study Watch, if you enable features that push information to us (such as pairing it with a portal or mobile app).</p>

<li><p><b>From our third-party partners</b>, including companies we collaborate with to provide you Services, content providers, and data brokers.&nbsp;</p>

<li><p><b>Our study networks and research partners</b>, such as study sponsors, clinical research organizations, laboratories, and healthcare providers (such as your doctors or study team).&nbsp;</p>

<li><p><b>From your Google user account</b>, if you log in to the Service with your Google account. Creation and maintenance of your Google user account is handled by Google and is subject to Google’s <a href="https://policies.google.com/privacy" target="_blank" rel="noopener noreferrer">Privacy Policy</a> -- NOT this Privacy Policy. We may receive certain information from Google related to your Google user account, such as email address, and will treat such information in accordance with relevant Google policies.&nbsp;</p>

<li><p><b>From publicly available sources</b>, such as public registers used for identity verification purposes.</p>

<div id="use-of-your--personal-information"><h3>USE OF YOUR PERSONAL INFORMATION</h3>

<p>We may use your Personal Information to operate and improve our business, including:</p>

<li><b>For everyday business purposes.</b> We use your Personal Information for internal purposes as we manage our business, including for account management, contract administration, website management, corporate governance, troubleshooting, and other internal business functions. Your Personal Information may also be used for internal statistical and research purposes. We rely on the following legal bases for processing your Personal Information for everyday business purposes: contractual necessity, our legal obligations, and our legitimate interests of operating our business.</li>

<li><b>To provide you with the Services that you request.</b> This means that we may use your Personal Information to respond to your questions, process and fulfill your product orders, assist with financing and payments, operate the Services, assess and communicate with you about eligibility for certain Services, and perform other actions that you request. We rely on the following legal bases for processing your Personal Information to provide you the Services: contractual necessity, our legal obligations, your consent (in certain cases), and our legitimate interests of fulfilling your requests.</li>

<li><b>To provide customer service.</b> We use your Personal Information for customer relationship management and administration (including across our business units and divisions), such as to respond and address feedback you provide us or when you contact us for support. We rely on the following legal bases for processing your Personal Information to provide customer service: our legitimate interests of ensuring you have a good experience with our Services.</li>

<li><b>For research and study-related purposes.</b> When you participate in clinical or research study-related activities or medical testing activities, we use your Personal Information to create your profile, determine your eligibility for a study, enroll you in a study, conduct research-related analyses, or for other study related services (such as identity verification and payment). We rely on the following legal bases for processing your Personal Information for research/study-related purposes: our legal obligations, your consent, and our legitimate interests of identifying qualified study participants. For more information about our research and study-related purposes, please see the Research Studies section (Section 5) below.</li>

<li><b>For marketing and promotional purposes.</b> We may use Personal Information to engage in marketing, including targeting, designing and sending you communications (such as newsletters, surveys, questionnaires, and other marketing materials) that promote Verily Services and/or services offered by our partners. We rely on the following legal bases for processing your Personal Information for marketing purposes: your consent (where required by law in certain jurisdictions) and our legitimate interests of sending you information we think might interest you.</li>

<li><b>To develop, improve, and personalize our Services.</b> We use your Personal Information to analyze your needs; to help improve, develop, and evaluate the Services; and to develop new products and services. We also monitor the effectiveness and functionality of the Services, personalize your experience, and consider potential improvements to the Services. We rely on the following legal bases for processing your Personal Information for improving our products and Services: our legitimate interests of improving our Service offerings.</li>

<li><b>For legal, compliance, and safety purposes.</b> We use your Personal Information for purposes such as complying with our policies; legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise, or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property, or rights; detecting, preventing, and responding to security incidents and health and safety issues; and protecting against malicious, deceptive, fraudulent, or illegal activity. We rely on the following legal bases for processing your Personal Information for compliance purposes: our legal obligations and our legitimate interests of operating our business in a compliant way.</li>

<li><b>In connection with a corporate transaction.</b> This includes circumstances where we acquire assets of another business or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change. We rely on the following legal bases for processing your Personal Information in connection with a corporate transaction: our legal obligations and our legitimate interests of entering into such transactions.</li>

<p>We may collect, use or disclose sensitive or “special” Personal Information to provide you with the product or Services you have requested, to comply with our legal and regulatory obligations, or for certain other purposes of which we notify you in advance. For example, we may use biometric information to identify you as required to use certain Services, such as clinical or research studies. Our legal basis for processing is your consent (depending on the circumstances), our legal obligations, legitimate interest for scientific research purposes, and where authorized by law.&nbsp;<br>

In some cases, we may require your Personal Information to fulfill a statutory or contractual obligation. When we ask for your consent to use your Personal Information for specific purposes, you have the right to withdraw your consent at any time.</p>

<div id="research-studies"><h3>RESEARCH STUDIES</h3>

<p>When you engage in our research platform, you may be asked to provide information to create your profile, determine your eligibility for a study, enroll you in a study, or for other study related services (such as identity verification and payment).&nbsp;<br>

For example, when you participate in research studies (both where Verily is the sponsor and when Verily is managing the study on behalf of a sponsor), you may be required to read and sign an Informed Consent Form (“ICF”). The ICF will be more specific than this Privacy Policy about how we (or the study sponsor) will collect, use, and disclose your Personal Information for that particular study – and the ICF will control in the event of a conflict with this Privacy Policy.&nbsp;<br>

We will require you to sign the ICF before starting a study. In some cases, you may be required to agree to the ICF by providing your name, email address, and a password as an electronic signature, or by providing a handwritten signature. In other cases, you may need to provide your name and/or Google account information as an electronic signature.<br>

Once you are enrolled in a study, you may be asked to provide additional information (like periodic health updates) and respond to surveys relevant to the study you are in. You may also be requested to report to a laboratory or other clinical site to provide biospecimens. If that is the case, the ICF and/or the study sponsor will explain this further data collection.</p>

<div id="disclosure-of-your-personal-information"><h3>DISCLOSURE OF YOUR PERSONAL INFORMATION</h3>

<p>We may disclose the Personal Information listed above to companies outside of Verily in the following situations:<br>

<li><b>Service Providers:</b> Verily may disclose your Personal Information or make it accessible to companies that provide services to us (“Service Providers”). For example, Verily relies on Service Providers to provide certain technology and services, including cloud services, security services, data storage, website hosting and other support functions. It is our policy to have in place agreements with our Service Providers that limit how Service Providers can use and disclose your Personal Information and require them to keep it secure.</li>

<li><b>Professional Services Companies:</b> We may disclose Personal Information to professional services companies, such as our external auditors, attorneys, accountants, and similar professionals, in order to receive services.&nbsp;</li>

<li><b>Business and Research Partners:</b> We may partner with other companies that use Personal Information for their own purposes such as partners we work with to conduct research or provide you with products or services, which may be on a joint or “co-branded” basis. In some cases, the relevant partner’s privacy policy may also apply in addition to this Privacy Policy.&nbsp;&nbsp;</li>

<li><b>Affiliates and Subsidiaries:</b> We may disclose Personal Information to our affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership</li>

<li><b>Legal Obligations, to Authorities, and for Safety:</b> We may disclose your Personal Information to satisfy applicable laws or regulations, including those related to product safety and adverse event reporting, and in response to legal processes or enforceable government or law enforcement requests. We may also disclose your Personal Information if disclosure is reasonably necessary to monitor compliance with our policies and applicable terms of service; to detect, prevent, or otherwise address fraud, security or technical issues; or to protect the rights, property or safety of Verily, our customers, our users, or the public, as required or permitted by law.&nbsp;</li>

<li><b>Disclosure to Subsequent Owner or Operator:</b> We may transfer your Personal Information to a successor entity upon a merger, consolidation, bankruptcy, reorganization, or in connection with other forms of corporate change; to a purchaser of all or a portion of our assets; or pursuant to a financing arrangement. The Personal Information we have about you may be transferred to parties to the transaction based on our legitimate interest in preparing for and completing the transaction.&nbsp;</li>

<li><b>Other Disclosures with Your Consent:</b> We may share Personal Information with companies, organizations, or individuals outside of Verily for purposes not specified elsewhere in this Privacy Policy when we have your consent to do so.</li>

<div id="de-identified-aggregate-and-anonymous-information"><h3>DE-IDENTIFIED, AGGREGATE, AND ANONYMOUS INFORMATION</h3>

<p>We may de-identify, aggregate, or anonymize information to ensure it will no longer be identifiable to you. We may use or disclose such data at our discretion, such as for statistical and research analysis. We do not try to re-identify this data unless we are required to or permitted by applicable laws.</p>

<div id="cookies-and-other-tracking-technologies"><h3>COOKIES AND OTHER TRACKING TECHNOLOGIES</h3>

<p>We use cookies and other tracking technologies to collect information about you, your device, and how you interact with our online Services. Please review our <a href="/cookie-policy" target="_self" rel="noopener noreferrer">Cookie Policy</a> for more information about the types of tracking technologies we use.&nbsp;<br>

Do Not Track (“DNT”) is a privacy preference that visitors can set in their web browsers. When a visitor turns on DNT, the browser sends a message to websites requesting that they do not track the visitor. At this time, we do not respond to these signals.</p>

<div id="your-communications-choices"><h3>YOUR COMMUNICATIONS CHOICES</h3>

<li><a href="#introduction">INTRODUCTION AND APPLICABILITY</a></li>

<li><a href="#categories-of-information-we-collect">CATEGORIES OF PERSONAL INFORMATION WE COLLECT</a></li>

<li><a href="#sources-of-personal-information">SOURCES OF PERSONAL INFORMATION</a></li>

<li><a href="#use-of-your--personal-information">USE OF YOUR PERSONAL INFORMATION</a></li>

<li><a href="#research-studies">RESEARCH STUDIES</a></li>

<li><a href="#disclosure-of-your-personal-information">DISCLOSURE OF YOUR PERSONAL INFORMATION</a></li>

<li><a href="#de-identified-aggregate-and-anonymous-information">DE-IDENTIFIED, AGGREGATE, AND ANONYMOUS INFORMATION</a></li>

<li><a href="#cookies-and-other-tracking-technologies">COOKIES AND OTHER TRACKING TECHNOLOGIES</a></li>

<li><a href="#your-communications-choices">YOUR COMMUNICATIONS CHOICES</a></li>

<li><a href="#your-privacy-rights">YOUR PRIVACY RIGHTS</a></li>

<li><a href="#supplemental-us-state-privacy-disclosures">SUPPLEMENTAL U.S. STATE PRIVACY DISCLOSURES</a></li>

<li><a href="#children-privacy">CHILDREN’S PRIVACY</a></li>

<li><a href="#security-and-retention">SECURITY AND RETENTION</a></li>

<li><a href="#linked-third-party-sites">LINKED THIRD-PARTY SITES</a></li>

<li><a href="#international-transfers">INTERNATIONAL TRANSFERS</a></li>

<li><a href="#modifications-to-our-privacy-policy">MODIFICATIONS TO OUR PRIVACY POLICY</a></li>

<li><a href="#contact-us">CONTACT US</a></li>

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Verily is an Alphabet precision health company that helps pharma and consumer health companies develop safe, effective treatments faster and enable patients, providers and payors to make better care decisions