Thank you for your interest in Verily Life Sciences, LLC ("Verily," "we" or "us"), an Alphabet Inc. ("Alphabet") company. Verily values and is committed to protecting the privacy and security of your information. This Privacy Policy is intended to provide you with information regarding how we collect, use and disclose information about you.
You can access specific topics in this Privacy Policy by clicking on the relevant links below:
This Privacy Policy applies to Verily products, communications, and digital properties (including websites, online platforms, mobile applications and wearable devices) that refer to this Privacy Policy, and where Verily may obtain and control your Personal Information (as defined herein) (collectively, the "Services").
For the purposes of this Privacy Policy, Verily is a controller (i.e., responsible party) of your Personal Information when we administer the Services directly on our own behalf. In certain situations, we also administer the Services on behalf of our business customers. In those instances, Verily may act as a processor or service provider to such customers. As such, you should review the privacy policy of these business customers, as they will be responsible for your Personal Information.
We offer a range of Services in support of our mission of bringing the promise of precision health to everyone, every day. Please note that some of our Services are subject to their own separate privacy policy, such as our Project Baseline platform (https://www.projectbaseline.com/privacy/) or certain services offered through our subsidiaries/affiliates.
Please read this Privacy Policy carefully. We want you to understand what information we collect from you when you use the Services, how we use such information, and whether and with whom we disclose such information. Using the Services is voluntary, and by accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.
This section describes the categories of information that we may collect for the purposes described in this Privacy Policy. When you use the Services, several types of information may be collected from you, including: (1) Device Information; and (2) Personal Information. Personal Information generally refers to any information that can be linked to an identified or identifiable person. The term Personal Information also covers certain categories of "Sensitive" or "special" Personal Information that often receive additional protections and/or are subject to additional restrictions under applicable laws. In this Privacy Policy, we refer to this information as "Sensitive Personal Information".
Device Information
We may automatically collect Device Information regarding use of or access to the Services, such as:
In addition, we may collect location information through the use of technology when you use our Services, such as data associated with your IP address or other online or device identifier. If you do not want us to collect and use this information, you may be able to disable the location features on your device. Check your device manufacturer settings for information on how to do so.
This information (collectively, "Device Information") does not, by itself, personally identify users. We use this Device Information to monitor the effectiveness of the Services, to help personalize your experience, and to consider potential improvements to the Services. Device Information may be collected through cookies or similar technologies. For more detailed information on cookies, please refer to the "Cookies and other Online Interactions" section below.
Personal Information
Access to and/or use of some Services may require disclosure of certain Personal Information as further described below. The categories and specific types of Personal Information that Verily has collected in the past 12 months about you may include:
The provision of the Personal Information, including Sensitive Personal Information, listed above is voluntary. In certain instances, however, we will not be able to process your request for our Services without the requested Personal Information.
The following information may also be Personal Information depending on how it is used and linked with other information.
We collect your Personal Information in the following ways, pursuant to applicable law:
Directly From You, when you use or purchase our Services, register for an account or create a profile, contact us, respond to a survey, sign up to receive emails, text messages, and/or postal mailings.
Through Cookies and Other Data Collection Technologies, when you visit our websites, use our mobile applications, or open or click on emails we send you, or interact with our advertisements. For analytics purposes, we or third parties we work with collect certain 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 see the "Cookies and Other Online Interactions" section below.
Through Wearable Devices, when you use wearable devices, such as Verily’s Study Watch; provided that you may be required to enable certain features in order for us to receive information (such as pairing it with a portal or mobile app).
From Our Third-Party Partners, including from third parties that we have partnered with to provide you the Services that you have requested from us.
From Your Google User Account, when you may be required to log in to the relevant Service with a Google user account. Creation and maintenance of your Google user account is handled by Google, and is subject to its separate privacy policy, and NOT this Privacy Policy. We may receive certain information from Google related to your Google user account, such as email address, and we will treat such information in accordance with relevant Google policies.
From Publicly Available Sources, such as information collected for identification verification purposes.
Processing Purposes:
We may use your Personal Information for the following business and commercial purposes ("Processing Purposes") associated with our general business operations.
Legal Basis of Processing
Where a legal basis for processing is required (e.g., in the European Union and the United Kingdom), we process your information for the purposes described in this Privacy Policy based on the following legal grounds:
In some cases, your provision of Personal Information may be required by a statutory or contractual obligation.
Service Providers:
Other Third-Party Vendors:
Business and Research Partners:
Legal Obligations, to Authorities and for Product Safety:
Disclosure to Subsequent Owner or Operator:
Other Disclosures with Your Consent:
De-identified or Aggregate Information:
We use various technologies to collect and store information, including cookies, pixel tags, local storage, such as browser web storage or application data caches, databases, and server logs (collectively for purposes of this section, “cookies”). Cookies are small bits of data cached or stored on your computer or mobile device based on your Internet activity. We may use cookies to improve the Services and provide features that are tailored to your needs. This section describes how we use cookies and how you can manage cookies that are not required to operate our sites and mobile applications.
The information collected by these tracking technologies may include (a) your internet protocol (IP) address, unique device identifiers, location, browser type, and Internet service provider information; (b) information about when and how you access and use our websites or Services, such as the domains you visit, what features you used and for how long, the website that referred you to us, and date/time stamps associated with your usage; (c) information about the device you use to access the websites or Services, such as device type, device ID, and device/browser settings; and (d) location of the device used to access the websites or Services derived from GPS or WiFi use.
We differentiate between cookies that are essential for the technical features of the Services and, in certain instances, optional analytics cookies.
Cookie Type | Description |
Essential Cookies | These are cookies that the Services need in order to function, and that enable you to move around and use the Services and features. Without these essential cookies, the Services will not perform as smoothly for you as we would like it to and we may not be able to provide the Services or certain features you request. Examples of where these cookies are used include: to determine when you are signed in; to determine when your account has been inactive; and for other troubleshooting and security purposes. |
Analytics Cookies | Analytics cookies allow us to understand more about how many visitors we have to our Services, how many times they visit us and how many times a user viewed specific pages within our Services. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our Services multiple times, we cannot use them to find out details such as your name or address. We use Google Analytics. For more information about Google Analytics, please refer to "How Google Uses Information From Sites or Apps that Use Our Services", which can be found at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time. We also use the Meta Conversion Pixel to measure the effectiveness of our advertising in an aggregated manner. |
Depending on your location and applicable laws, we may give you the option of adjusting your preferences with regard to the categories of cookies we use. When this option is available, you can configure your personal settings on our Cookies Banner under “Settings” or via other options that may be available on the relevant Service. If you use a different device to access the same Services, you may need to manage your settings for each separate device you use.
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.
Depending on where you live, you may have certain rights with respect to your Personal Information. For example, under local applicable laws, including the European Union and the United Kingdom, you may have the following rights:
If you choose to assert any of these rights under applicable laws, we will respond within the time period prescribed by applicable law. Please note that you may be located in a jurisdiction where we are not obligated to fulfill a request and that many of the above rights may be generally subject to exceptions and limitations. To the extent permitted by applicable law, we may reject requests that are unreasonably repetitive, unduly burdensome, risk the privacy of others, or would be very impractical to honor. If we are not able to provide the requested information or make the change you requested, you will be provided with the reasons for such decisions. Depending on where you are located, you may have the right to lodge a complaint with the relevant supervisory authority.
If you are based outside of the United States and would like to exercise any individual rights you may have, please submit your privacy requests by emailing us at datarightsrequest@verily.com.
Your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you are a California resident and the California Consumer Privacy Act (“CCPA”) applies to your Personal Information (e.g., an exception described in the next paragraph does not apply), we provide this additional information so you can understand and exercise your rights under the CCPA.
Please note that the CCPA generally does not apply to certain data that is subject to the California Confidentiality of Medical Information Act, the Health Insurance Portability and Accountability Act of 1996 or information collected, used, or disclosed as part of certain clinical trials and research, as defined in Section 164.501 of Title 45 of the Code of Federal Regulations and that is conducted in accordance with the Federal Policy for the Protection of Human Subjects, also known as the Common Rule, good clinical practice guidelines issued by the International Council for Harmonisation, or human subject protection requirements of the United States Food and Drug Administration.
We use and disclose your Personal Information for the Processing Purposes as set out in the “Use of Your Personal Information” and “Disclosure of Your Personal Information” sections above
When the CCPA applies, California residents will have the following consumer rights:
We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy. However, Verily may require use of your Personal Information to provide access to the Services. Therefore, when you exercise your deletion rights, in particular, you may lose access to certain aspects of the Services that require your Personal Information.
Unless otherwise specified, Verily’s Services are not directed to children under the age of 13 (or the relevant age as defined by applicable law) (“Children” or “Child”) and Verily does not knowingly collect or distribute Personal Information from Children. Unless otherwise specified, Children are not permitted to use the Services, and we request that Children not submit any Personal Information through the Services. If you believe your Child has impermissibly submitted Personal Information, please contact us to request that such information be removed. Once we are aware of information impermissibly entered by a Child, we will exercise commercially reasonable efforts to remove such information from our systems.
We may provide links to other third-party websites through the Services solely as a convenience to you. However, such linking does not mean, and should not be interpreted to mean, that Verily endorses, is affiliated with or makes any representations concerning such third-party websites. Verily neither reviews, controls, nor is responsible for these third-party sites or any content therein. By using such links, you will leave the Services. Please note that any Personal Information that you provide to such third parties will be governed by their privacy policies, and we have no control over or responsibility for their privacy practices. If you decide to access any of the third-party sites linked to the Services, you do so entirely at your own risk. Verily shall not be liable for any consequences arising from use of any third-party websites to which the Services link. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed prior to providing any Personal Information.
Unless otherwise specified, we may process the information collected through the Services on a server located outside the country where you live. However, we will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored or processed. When we transfer Personal Information from the European Economic Area, the United Kingdom (UK) and Switzerland to other countries, including to the United States, we use a variety of legal means to help ensure the data is appropriately protected. We comply with certain legal frameworks relating to the cross-border transfer of Personal Information by implementing appropriate contractual or other measures, including but not limited to, the European Union or United Kingdom Standard Contractual Clauses, where required. Where permitted by applicable law, you may request a copy of such contractual clauses by contacting us using the information set out below in the "Contact Us" section.
While Verily does not rely on the Privacy Shield certification as a basis for international data transfers, Verily Life Sciences LLC complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use and retention of Personal Information in the United States from European Union member countries and the UK and Switzerland, respectively ("European Personal Information"), as described in our Privacy Shield certification. Verily’s Privacy Shield certification does not include data processed through our website and portal at www.projectbaseline.com ("Project Baseline"), which is subject to appropriate contractual or other measures, as set for in its separate privacy policy
(https://www.projectbaseline.com/privacy/).
Verily has certified its commitment to be subject to the Privacy Shield Principles such European Personal Information received from the EU and the UK and Switzerland. We shall remain responsible for such European Personal Information that we share under the Onward Transfer Principle with third parties for processing on our behalf, as described under the caption "How We Use and Disclose Information Collected." Learn more about the Privacy Shield program here.
If you have an inquiry regarding our privacy practices in relation to our Privacy Shield certification, we encourage you to contact us using the information set out below in the “Contact Us” section. Verily is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC). You may also file a complaint free of charge with your local data protection authority and we will work with them to resolve your complaint. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.
From time to time, we may update and post revisions to this Privacy Policy. Any changes will be effective immediately upon the posting of the revised Privacy Policy. We encourage you to review this page periodically for the latest information on our privacy practices. This Privacy Policy was updated as of the effective date listed above.
If you have any questions or concerns regarding the information gathered through the Services, please contact us at prisec@verily.com.
Attn: Verily Privacy Office
c/o Verily Life Sciences LLC
269 East Grand Avenue
South San Francisco, CA, 94080