This policy explains how Entourage AI ("we", "us", "our") handles personal data when you visit this site, join the early-access waitlist, order a collection kit, send us a sample, or read your results. We work with proteomics, which means some of what we hold is health-related and deserves particular care. We treat it that way.
What we collect
We collect three kinds of information.
Account details
Your name, email address, shipping address, country, date of birth or age, and any password or sign-in credential. If you order a kit we also hold order and delivery records, and payment status. Card details themselves are handled by our payment provider and are never stored on our systems.
Sample data
The physical sample you return, the proteomic measurements derived from it in the laboratory, and the results, estimates and insights we produce from those measurements. It also includes anything you tell us that gives the measurements context, such as your sex at birth, collection date, medication, or the habits you record in your dashboard. This is health-related data.
Usage data
How you use the site and the dashboard: pages viewed, features used, approximate location derived from your IP address, device and browser type, and timestamps. This is collected only where the relevant cookies are allowed, as described below.
We also keep the content of messages you send us, for example through the Contact Us form, so that we can reply and keep a record of what was agreed.
How we use it
We use personal data to:
- ship your kit, receive your sample and run the analysis;
- produce and present your results and personalised insights;
- create and secure your account, and authenticate you when you sign in;
- reply to you, and send service messages about your order or your results;
- send early-access updates where you have asked for them, which you can stop at any time;
- improve, validate and develop our models and the Service, using de-identified and aggregated data;
- keep the Service safe, detect misuse, and meet our legal and regulatory obligations.
Our legal bases, where that concept applies to you, are: performing our contract with you, for anything needed to deliver the Service; your explicit consent, for the processing of health-related data and for non-essential cookies; our legitimate interests, for security, service improvement and de-identified analysis; and legal obligation, where a law requires us to keep or disclose something. Where we rely on consent, you can withdraw it at any time, and withdrawing it does not affect processing carried out before you did.
We do not sell personal data. We do not use your identifiable data to make automated decisions that produce legal or similarly significant effects about you, and we do not share it with employers, insurers or law enforcement except where a law compels us to.
Cookies
We use a small number of cookies and similar browser storage. They fall into two categories.
- Essential: Required for login, security, and core site functionality. Cannot be disabled.
- Analytics: Helps us understand how visitors use EntourageAI (Google Analytics). No personally identifiable data is shared with third parties.
Analytics cookies are set only if you allow them. You can make or change that choice at any time on the Cookie Preferences page, and your choice is recorded in your own browser. You can also block or clear cookies in your browser settings, though essential cookies are needed for parts of the Service to work.
Sharing
We share personal data only where it is needed, and only with:
- Laboratory partners, who receive your sample and the identifiers needed to match it to your order, so that the analysis can be run;
- Service providers who work on our behalf: hosting, storage, email delivery, customer support, payment processing, shipping and logistics, and analytics;
- Professional advisers, such as auditors and lawyers, where they are bound by confidentiality;
- A buyer or successor, if we are involved in a merger, acquisition or sale of assets, in which case we will tell you before your data becomes subject to a different policy;
- Authorities, where we are legally required to disclose, or where disclosure is necessary to protect someone's life or safety.
Every provider is bound by a written agreement that limits them to acting on our instructions and requires appropriate security. Some of them operate outside your country, including transfers between the United Kingdom, the European Economic Area and the United States. Where that happens we rely on an approved transfer mechanism, such as standard contractual clauses or an adequacy decision, and we can give you a copy of the safeguards on request.
Retention
We keep personal data only as long as we need it.
- Physical samples are retained for [X days] after analysis and then destroyed.
- Proteomic measurements and results are kept for as long as you hold an account, and for [X days] after you close it, so that you can retrieve your history and so that comparisons over time remain possible.
- Account and order records are kept for [X years], where tax and consumer law require it.
- Usage data is kept for [X months].
- De-identified and aggregated data, which cannot reasonably be used to identify you, may be kept indefinitely.
When a retention period ends we delete the data or de-identify it irreversibly.
Your rights
Subject to the law that applies to you, you can ask us to:
- Access the personal data we hold about you, and give you a copy of it in a portable format;
- Correct anything that is inaccurate or incomplete;
- Delete your data and close your account, including destroying any sample we still hold;
- Restrict or object to particular processing, including processing based on our legitimate interests;
- Withdraw consent, including consent to the processing of health-related data and to analytics cookies;
- Opt out of marketing email, using the unsubscribe link in any such message or by writing to us.
Write to us through the Contact Us page. We will respond within [X days], and we will tell you if we need longer or if a law requires us to keep something you have asked us to delete. We will not charge you or treat you differently for exercising a right. If you are unhappy with our response you can complain to your local data protection authority; in the United Kingdom that is the Information Commissioner's Office.
Security
We use technical and organisational measures appropriate to the sensitivity of what we hold: encryption in transit and at rest, access limited to staff who need it, separation of identifying details from proteomic measurements wherever practical, logging, and regular review of our providers. Samples are handled under laboratory procedures designed to keep them traceable and secure.
No system is perfectly secure, and we cannot guarantee that a breach will never happen. If one occurs and it is likely to result in a risk to you, we will notify you and the relevant authority as the law requires, without undue delay.
Children
The Service is for adults aged 18 or over. We do not knowingly collect personal data from anyone under 18. If you believe a child has given us personal data, write to us and we will delete it and destroy any associated sample. We do not direct any part of the Service at children.
Changes
We may update this policy as the Service develops or the law changes. When we do, we will update the date at the top of this page. Where a change materially affects how we use data we already hold, we will give you notice of at least [X days] by email or through the Service, and, where the law requires it, ask for your consent again.
Contact
The data controller is Entourage AI, [Registered entity], of [Registered address], San Rafael, California, USA, and [Registered address], Glasgow, United Kingdom. Our privacy contact can be reached through the Contact Us page, or at [privacy email]. [Representative or data protection officer details, where one is appointed.]
Entourage AI is designed for those focused on long-term wellness. It is not a diagnosis and does not replace care from your clinician.