Política de privacidad
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Published:18 Abril 2023
When you use Sequoia, you are trusting us with intimate personal data. We are committed to keeping that trust, which is why our policy as a company is to take steps to ensure that individual user's data and privacy rights are protected and to provide transparency about our data practices.
The purpose of our Privacy Policy is to explain what data we collect, how it is used and shared, and how you can control it.
Here’s a summary of our Privacy Policy to give you a quick overview of our data practices. The summary is not a substitute for reading the full policy to obtain important information about your personal data, how we use it and your rights with respect to it. Please read this Privacy Policy in full along with our Terms of Use, but here are a few key takeaways we hope you will find useful:
The data that serves you
When you use Sequoia, we collect your Personal Data and may use it to improve the user experience, such as personalizing product offers, the insights you get, etc. For research activities we use only de-identified or aggregated data, which cannot be associated with you.
You can contribute to the growth of the Sequoia community
If you consent, we may use technical information about your device and other information about you (such as your device’s unique technical identifier, age group, subscription status, and the fact of application launch) for promotional purposes to reach more people like you who we believe may be interested in using the Services. You can always withdraw your consent. Please see the section below titled “Processing to find new Sequoia users and stay in touch with you” for more information about how to withdraw your consent.
You are in control
You may ask to access, modify, correct, erase, and update your Personal Data by writing to us at
Securing your data
We take reasonable and appropriate measures to protect your Personal Data from loss, theft, misuse or unauthorized access.
We limit children’s access to the App
You must be at least 17 to use the App. Moreover, some of the App functions are limited for users that are younger than 18.
You can freely talk to us
We believe in transparent and open dialogue, so we strongly encourage you to contact our Support Team at
Introduction
This Privacy Policy explains how Sequoia Health (“Sequoia” or “we” or “us”) collects, stores, uses, transfers and shares Personal Data from our users (“you”) in connection with the Sequoia mobile application, Sequoia: Men's Sexual Wellness (the “App”)*, and the sequoia.health website including any products and services related to it (the "Website") (all collectively, the “Services”).
We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you through the App, or by presenting you with a new version of this Privacy Policy. If permitted by applicable law, your continued use of the Services after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will be given a choice about whether to explicitly accept changes to the Privacy Policy. If you do not accept the terms of the Privacy Policy, please do not use the Services.
Personal Data we collect from you
We collect Personal Data about you in a variety of ways. Sometimes we collect Personal Data automatically when you interact with the Services, and sometimes we collect the Personal Data directly from you. At times, we may receive Personal Data about you from other sources and third parties.
Personal Data you provide to us directly:
General Information. When you sign up to use the Services, we may collect Personal Data about you such as:
- Email address;
- Year of birth;
- Password or passcode;
- Place of residence and associated location information including time zone and language.
In many cases, we may be able to infer your gender by your use of the Services.
Health and Well-being. When you sign up to use the Services, you may choose to provide Personal Data about your health and well-being such as:
- Weight;
- Body temperature;
- Sexual activity types (including sex, masturbation, erection);
- Sexual activity dates;
- Various symptoms related to your sexual activity and health;
Other information about your health (including sexual activities), physical and mental well-being, and related activities, including personal life.
You may also allow us to connect to third-party services, such as Apple HealthKit and Google Fit, to enable us to import Personal Data about your health and activities into the App. This imported data may include sports activities, weight, calories burned, heart rate, number of steps/distance traveled, and other data about your health. We will process this data in order to provide you with the App functionality described below. When you choose to have this data imported you are subject to the Google Fit and Apple HealthKit privacy policies and practices.
Personal Data we collect automatically:
When you access or use the Services, we may automatically collect the following information:
Device Information:
- Device model;
- Information about the operating system and its version;
- Unique device identifiers (e.g. IDFA);
- Mobile operator and network information;
- Device storage information;
- Version of your device system.
Location Information:
- IP address;
- Time zone;
- Information about your mobile service provider.
Data about your use of the Services, including, among others:
- Frequency of use;
- Areas and features of the Services that you access, visit or use;
- Engagement with particular features.
To collect this and other information, we may use cookies and other tracking technologies. See more in our Cookie Policy.
Data from external sources. We may receive Personal Data about you from third parties. For example, we may obtain information from third parties, to enhance or supplement existing user information, including to customize and personalize your experience and for statistical purposes and analytics, as described below.
How we use your Personal Data
We will not collect and use your Personal Data without letting you know. Depending on which features of the Services you use, we will process your Personal Data based on one or more of the following legal bases:
- Your consent. For example, on the registration screen when you give us permission to process your Personal Data;
- To fulfill our contractual obligations to you in order to provide the Services to you;
- Legitimate interest. We may process your Personal Data in relation to our interests in providing the Services to you, our commercial interests, including our interest in protecting the security and integrity of the Services, and wider societal benefits;
- Legal obligation. We may be obligated to process some of your Personal Data to comply with applicable laws and regulations.
Principles of processing
Data minimization and purpose limitation. We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not needed for the mentioned purposes. For any new purpose of processing we will ask your separate consent.
No sale of Personal Data. We will not sell or rent your Personal Data. We will not disclose your Personal Data except as otherwise described in this Privacy Policy. We may share your Personal Data with our service providers solely as described in this Privacy Policy. We will also not use information received through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers.
Your privacy rights
It does not matter what country or region you come from, we are committed to providing you vast privacy rights in relation to your Personal Data.
What rights?
Correction of your Personal Data
If you believe that your Personal Data is inaccurate, you have a right to contact us and ask us to correct such Personal Data.
Restriction of Processing
You have a right to request that the processing of your Personal Data be restricted in some circumstances. For example, you have the right to request the restriction of your Personal Data if you contest the accuracy of your Personal Data and we need some time to verify its accuracy.
Access to your Personal Data (including in portable form)
You have a right to request information about what Personal Data we process about you, to access all your Personal Data, and receive a copy of it, including in a structured and portable form (.json).
Erasure of your Personal Data
You may ask us to erase your Personal Data if you withdraw your consent to processing, if you believe such processing is unlawful. Please be aware that erasing some Personal Data may affect your experience using certain features of the Services that rely on historic data.
Right to object to the processing of your Personal Data
In some cases, you can object to the processing of your Personal Data, for example, if we process it under the legitimate interest basis, by contacting us at
How to exercise your privacy rights
Сontact us at
We will address your request within 30 days after receipt. It may take us up to 90 days in some cases, for example for full erasure of your Personal Data stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.
What else?
Please keep in mind that if we receive a vague request, we may contact you to better understand the request. We may also refuse to comply with a request that is manifestly unfounded and with excessive (repetitive) requests.
We might also require you to prove your identity in some cases. Where you have not registered your account, we may ask you to undergo additional verification measures in an effort to ensure we are appropriately responding to requests.
Subject to applicable laws, you may have a right to lodge a complaint with your local data protection authority about any of our activities (related to your privacy rights, among others) that you think are not compliant with applicable law. If you have any concerns about our privacy practices, please let us know at
Processing to make the App run
In some situations, we engage other companies to process your Personal Data on our behalf.
These are companies that help us run the Services, support our communication with you or perform other App-related activities. They may process certain Personal Data on our behalf to accomplish the goals related to the App functions and associated activities. We remain responsible for any acts or omissions of these companies and undertake to execute formal data processing agreements with them to the extent required by applicable law.
Special circumstances
We may also share some of your Personal Data in the following special circumstances:
- in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law (including to meet national security or law enforcement requirements);
- when disclosure is required to maintain the security and integrity of the Services, or to protect any user’s security or the security of other persons, consistent with applicable laws. In such cases we may also delete some of your Personal Data (e.g., by resetting your password to avoid unauthorized access);
- when disclosure is directed or consented to by the user who has input the Personal Data;
- in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.
Depending on the circumstance, we may rely on legitimate interest or legal obligation as our legal basis for the above processing activities.
Retention of your Personal Data
Except as set forth below, we will retain your Personal Data as long as needed to provide you with the Services or otherwise fulfill the purposes for which it was collected.
Impact of Account Deactivation/Requests to Erase Personal Data: At any time, you can deactivate your account and erase your Personal Data by using option "Delete all my data" in the app settings or emailing
Impact of App Deletion or Inactivity: If you choose to delete the App from your device or your account becomes inactive, we will retain your Personal Data for a period of 3 years in case you decide to re-activate the Services or re-install the App. The App covers different periods of users’ lifecycle; therefore, retention of your data is needed in some cases to secure your smooth experience with other App functions (e.g., switching to pregnancy mode after cycle tracking).
Limitations: You should be aware that, although we will anonymize or otherwise de-identify your data where possible, we may retain certain Personal Data and other information after your account has been terminated or deleted as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
Security of your Personal Data
General security measures
- We implement technical and organizational measures in an effort to protect Personal Data from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the Personal Data that we process and risks associated with special categories of Personal Data we collect (information about health). These measures include Pseudonymization and tokenization of certain categories of your Personal Data.
- Encryption of your Personal Data in transit and in rest.
- Systematic vulnerability scanning and penetration testing.
- Protection of data integrity.
- Organizational and legal measures. For example, our employees have different levels of access to your Personal Data and only those in charge of data management get access to your Personal Data and only for limited purposes required for the operation of the Services. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your Personal Data.
- Conducting periodical data protection impact assessments in order to ensure that the Services fully adhere to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake a privacy audit in the event of. Sequoia’s merger or takeover.
Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. However, no security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information will not be intercepted while being transmitted to us.
Security breaches
If we learn of a security systems breach, we may either post a notice and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Policy. If we learn of a potential Personal Data breach, together with other actions referred to in the Privacy Policy (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices and performing other reasonably necessary activities and actions.
If you want to report a security incident related to the Services please contact us at
Children’s privacy
General age limitation. The Services are not intended for children and we do not knowingly collect information about children under 17 years old through the Services. If you are aware of anyone under 17 using the Services, please contact us at
Moreover, some of the App functions are limited for users that are younger than 18.
Communication with you
We may contact you from time to time via popups or push notifications to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you.
Opt-out options. You may always opt out of receiving popups or push notifications by adjusting your settings in your device. If applicable laws prescribe so, we may ask some users to provide their additional consent for such communications.
Please note that we may contact you with information about products, services, offers, promotions, rewards, and events offered by us and others via third-party platforms (like social media). For more information, including instructions for how to opt-out, please see the section above titled ‘Processing to find new Sequoia users and stay in touch with you.
Storage and international Personal Data transfers
Sequoia is based in the United States (“US”). Personal Data we collect is transferred to and processed in Estonia and to other countries (where it is governed by the laws of those countries). The laws of the US and the laws of other countries may not offer the same protections as the laws of your jurisdiction.
Transfers of Personal Data outside of the European Union, the European Economic Area and the United Kingdom
Personal Data in the European Union (EU), the EEA and the United Kingdom (UK) is protected by the General Data Protection Regulation (GDPR) and Data Protection Act 2018, but some other countries may not necessarily have the same standard of protection for your Personal Data.
Sequoia transfers Personal Data from the EU, EEA and UK to the U.S. and other third countries. When transferring Personal Data outside the EU, EEA and UK we either implement standard contractual clauses or rely on current European Commission adequacy decisions.
Contact us
General
If you have any questions or concerns about your privacy you may contact us at:
Sequoia Health, Inc. 251 Little Falls Drive, Wilmington, New Castle County, Delaware 19808
Email:
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