Last Updated: May 1, 2018

This Privacy Policy (“Policy”) explains how information is collected, used, and disclosed by Aceso Ingenuity, LLC (“Aceso Ingenuity,” “we,” “us,” or “our”) in connection with your use of our websites, and other online services (collectively, our “Services”). This Privacy Policy applies to only those websites, services, and application included within the Services and does not apply to any third-party websites, services, or applications (including those of our Partners), even if accessible through the Services. When you use the Services, you consent to our collection, use, disclosure, and protection of information about you as described in this Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.


We may collect and store information about you in various ways. For example, we may collect information that you provide to us, information that we collect via social networking sites or third-party applications, information that we automatically collect through your use of the Services, and information from publicly available sources or non-affiliated third parties.

Information you provide directly to us:
When you use the Services, you may be invited to provide information to us. We may collect the following illustrative (but not exhaustive) types of information from you when you use the Services:

  • Registration information such as your email and password;
  • Account information that you choose to submit, such as name, gender, date of birth, and address;
  • Aceso Ingenuity Index survey responses and information you submit regarding your eligibility to participate in the Aceso Ingenuity Index survey;
  • The communications or requests you submit to us through the Services; and


If you opt to connect any applications, devices, services, or any accounts that you maintain with a third-party to the Services (collectively “Third-Party Applications”), we will collect certain information [from such Third-Party Applications as permitted by your privacy settings in the Application, including, but not limited to health and wellness data or your contacts. We may combine such information with information that we already hold.

Information from third-Party services: If you choose to register for the Services via a third-party service with which you have an account, such as Facebook or Twitter, we may collect certain information from your third-party account, such as name, email address, profile picture, list of friends, people you follow, likes, work and education history, current city or other third-party account information that your privacy settings in your third-party account permit us to access. Third-party services, such as Facebook and other social networking services, have their own policies concerning the collection, use, sharing, and protection of your information. Aceso Ingenuity does not have any control over how any third-party services uses or discloses the information they collect about you.

Other information collected with your express Consent: In addition to the information collected pursuant to this Privacy Policy, we may collect information about you if we have your express consent to do so. For example, if you opt to participate in a study via the Services, we will collect information for that study, including information you submit and obtained from third parties. In order to participate in a study, you must agree to the terms of an Informed Consent, Patient Authorization, or an equivalent consent agreement. Please review that document carefully as it will outline the specific information to be collected and how it will be used for a given study.

Information from other sources: We may, at times, seek to obtain information about you from other sources. We may receive, or affirmatively gather information about you from such sources and may combine it with the information that we already have for any purpose described throughout this Privacy Policy. The extent to which we may obtain information from such sources is governed by the terms of your relationship with that source.

Automatically collected information: When you utilize our Services, certain information is automatically collected. For example, we and our third party service providers may automatically collect the number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services and upload or post content, error logs, and other similar information. Even if you do not register with our Services, or submit information directly, our Services may collect this automatically collected information.

Location information: When you use the Services, we and our service providers may automatically collect location information, including general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. If you access the Services through a mobile device, we may also ask your permission to collect your precise geo-location information. If you do not wish to have specific geo-location information collected and used by us and our service providers, you may disable the location features on your device For more information regarding location services, please contact your device manufacturer or mobile carrier. Turning off location services may impact certain features of the Services.

Online analytics: We may use third-party web analytics services, such as those provided by Google Analytics. These service providers use cookies and other technologies described in this Policy to help us analyze how users use our Platform. The information collected by the technology will be disclosed to or collected directly by these service providers. To prevent Google Analytics from using information for analytics, a user may install the Google Analytics Opt-Out Browser Add-on by clicking here.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Platform by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt out of ad targeting as described below.

Advertising: You may receive tailored advertising on your computer through a web browser via email if you subscribe to our mailing list. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.

We may use third-party service providers for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.


We use the information collected to provide our Services to you or as otherwise described in this Privacy Policy. For example, we may use your information to:

  • Operate and improve our Services, including development of new features and functionalities;
  • Process and deliver program and/or study rewards;
  • Contact you, or otherwise provide you with information, about:
    • your account;
    • referrals;
    • current and future programs offered via the Services;
    • studies in which you are currently participating; or
    • participation in studies, programs or other opportunities for which you may be eligible, based upon information previously collected.
  • Respond to your feedback, comments, or questions, or to otherwise send you information about our Services;
  • Ask you to complete surveys about the Services or programs;
  • Analyze how you use and interact with our Services;
  • Protect our Services and the information collected against fraudulent, illegal, or otherwise unauthorized activity, including any investigation into such activity;
  • For any other purpose described in this Policy, or the Terms of Use; or
  • When we have your consent, such as pursuant to your participation in a survey, we may combine information that we collect from you through the Services with information that we obtain from affiliated and non-affiliated third parties, and information derived from any other products or services we provide.


In certain circumstances, we may share your information with our affiliates, service providers, and third party business partners. For instance:

Service Providers. We may share your information with third parties that help us operate our business and provide the Services, such as for email management, data hosting, analytics, fraud and safety protection and legal and accounting services.

Third-Party Applications or Services. If you access the Services through our partners’ websites and applications, to provide and administer the Services, may require that we share user identification, such as a logon name, associated with your Account with such partners.

When Required by Law or as Necessary to Protect Our Users and Services. We may share information when we believe that doing so is necessary to protect, enforce, or defend the legal rights, privacy, safety, or property of Aceso Ingenuity, our employees or agents or users, or if we reasonably believe that is necessary in order to comply with laws, regulations, legal process (such as subpoenas or warrants), or any other legal or regulatory request.

Business Transfers. We may disclose or transfer your information to a third party if we sell, transfer, divest, or disclose all or a portion of our business or assets to another company in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding or take steps in anticipation of such a transaction.

Otherwise with Your Consent or at Your Direction. In addition to the sharing described in this Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

Your Choices

Manage Your Account Information. You may modify your account information by accessing the Settings area of your account.

Email Messages. You may opt-out of receiving certain communications from us. To opt-out of any communications, follow the instructions in that communication or visit the settings tab of your account.


We use a technical and administrative safeguards to protect the integrity of your information. No method of Internet transmission or via mobile device, or electronic storage, however, is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.


Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party’s privacy policy. Our Privacy Policy does not apply to such websites or services and we’re not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access.


Our Services are not intended for children under the age of 18.


Your information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Our Services are intended for use only in the United States. If you’re located outside the United States and choose to provide your information to us, we may transfer your information to the United States and process it there (or any other country in which we operate). Your submission of information using the Services represents your agreement to such transfer.


Pursuant to the California Civil Code, California residents have the right to request for a disclosure from companies doing business in California of all disclosures of their personal information during the prior year to third parties, for such third parties direct marketing purposes. As noted above, we do not share your personal information with third parties for their direct marketing purposes unless we have your permission. For any questions regarding, please contact us at the information below.


For any questions regarding this Privacy Policy, or our data practices, please direct your inquiry to:

Aceso Ingenuity Health
Attn: Privacy


We may update this Policy from time to time to reflect changes or updates to our technology, data practices, and other factors. Changes to this Policy will become effective when published in the revised Policy, unless otherwise noted. Please check the “Last Updated” date at the top of this page to see when this Policy was last revised. Your continued use of the Services following the effective date of these changes indicates your consent to the practices disclosed in the update Privacy Policy.