Privacy Policy

Last updated: Jan 5, 2021

Welcome to the website (the “Site”) of Alula, Inc. (“Alula,” “we,” “us,” or “our”). We take your privacy seriously and we want you to be familiar with how we collect, use and share personal information from you.  Alula provides information and resources to help you, your family, and your friends better navigate through the diagnosis, treatment, and recovery of cancer (collectively, including the Site, the “Service”).

This Privacy Policy explains what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Use.

Before using the Service or submitting any Personal Information to Alula, please review this Privacy Policy carefully and email at privacy@myalula.com if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.  Please note that certain rights, requirements, and disclosures in this Privacy Policy may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations.

1. PERSONAL INFORMATION WE COLLECT

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”) as follows:

Personal Information You Provide: We may collect the following categories of Personal Information from you when you register on the Site, create a profile on the Site, and use the Site’s communication tools:

  • Identification Information: We collect identification information that you provide such as collect your name, email address, and mailing/billing addresses.  

  • Financial Information: Our payment processor(s) will collect the financial information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers.

  • Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback.  Providing communication information is optional to you.

  • Commercial Information: We may retain a history of the products you browse and/or purchase using the Service.

  • Demographic Information: We may collect certain demographic information, including your age gender and place of residence

  • Health Information: We may collect health information including your cancer diagnosis, date of diagnosis, types of treatment, treatment drug protocol, treatment locations, and treatment days and times. Notwithstanding anything else in this Privacy Policy, (a) we use Health Information only to provide the Service and not for advertising and (b) we will not disclose Health Information for advertising, marketing, or use-based data mining not needed to provide the Service.

  • Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. 

Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems: 

  • Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site. 

  • Cookies Information: Please see the “Cookies” section below to learn more about how we use cookies.

  • Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. 

  • Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

  • Location Information: We derive a rough estimate of your location from your IP address. 

  • Email Open/Click Information: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email. 

  • Derived Information: We may infer your preferences for products and services based on the Personal Information we collect about you.

Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings. 

Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here

Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site [and use that information to send targeted advertisements].  Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so. 

2. HOW WE USE PERSONAL INFORMATION

We may use Personal Information for the following purposes:

  • To provide the Service, including providing educational resources, a curated ecommerce marketplace, communication tools and treatment navigation/logistics tools; 

  • To respond to your inquiries, comments, feedback, or questions; including technical support

  • To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;

  • To analyze how you interact with our Service;

  • To maintain and enhance  the Service;

  • To develop new products and services with our Service;

  • To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and

  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

  • To personalize the service to your specific treatment and recovery needs.

Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may email hello@myalula.com. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.

3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

Alula does not sell your Personal Information. In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:

  • Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.

  • Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

  • Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.

  • Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Alula. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

  • Other Users: Certain actions you take may be visible to other users of the Service. For example, your profile information may be accessible to other users. You acknowledge that by sharing posts or adding information to your profile you make the information shared available to other users and that Alula cannot control, and shall not be responsible for any use other users make of such information.  You may elect to share your profile with certain individuals.  Please take care when determining the people with whom you share your profile.  Please be aware that Alula cannot control the actions and activities or those third parties with whom you share your profile. 

4. CHILDREN

Our Service is not directed to children who are under the age of 13. Alula does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 16 has provided Personal Information to Alula through the Service please email at hello@myalula.com and we will endeavor to delete that information from our databases.

5. LINKS TO OTHER WEBSITES

The Service may contain links to other websites not operated or controlled by Alula, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies. 

6. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to Alula via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.  You have the responsibility to select a strong password and to keep that password secure, including by instructing anyone that you allow to access your account to also keep your log-in credentials secure.  Contact Alula immediately in the event you have any reason to suspect that your account may have been compromised.

7. INTERNATIONAL USERS

By using our Service, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States.

8. YOUR CHOICES.

In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can also log in to your account or email hello@myalula.com to request updates to, deletions of and/or corrections to your Personal Information.

9. CHANGES TO THE PRIVACY POLICY

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

10. CONTACT US

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: Alula Inc., 335 Madison Avenue, Floor 3. NY, NY 10017 or privacy@myalula.com.