Privacy Policy

Last updated: 11/21/2025

This Privacy Policy explains how Eternell (operated by PHOEBETAL TECHNOLOGIES PRIVATE LIMITED) (“Eternell”, “we”, “us”, or “our”) collects, uses, shares, and protects your information when you use our websites, products and services, including:

Our
websites and online stores (such as eternell.org, buy.eternell.org
and related subdomains)
Our
health programs, diagnostic tests, supplements and food products
Any
digital dashboards, portals or communities we provide (including
biological age tracking and wellness platforms)

By using our services, you agree to the practices described
in this Privacy Policy.

Important: This document is a general template.
Privacy and health-data laws vary by country. You should ask your legal advisor
to review and adapt this Policy for your specific jurisdictions (UAE, US,
India, EU, etc.).

1. Who we are & how to contact us

Eternell operates globally through different offices
and entities. If you have any questions about this Policy or your data, you can
contact us at:

Branch Office – UAE
14th Floor, South Tower, Dubai Science Park, Dubai, UAE
+971 58 553 3724
info@eternell.org

Head Office – US
37660 Estuary Street, Newark, California 94560, US
info@eternell.org

2. What this Policy covers

This Policy applies to personal information we collect when
you:

Visit
our websites or interact with our online content
Create
an account, place an order or submit an enquiry
Participate
in our epigenetic, microbiome, longevity, or predictive disease tests
Use
our dashboards, tracking tools or health platforms
Communicate
with us by email, phone, messaging apps or social media

It does not cover third-party websites, apps, labs,
or clinics that may have their own privacy policies.

3. Information we collect

Depending on how you interact with Eternell, we may collect
the following types of information:

3.1 Identity & contact details

Name,
date of birth, gender
Email
address, phone number, postal address
Country
of residence, preferred language

3.2 Health, lifestyle & questionnaire data

Information
you provide in health forms, questionnaires and consultations
Lifestyle
details such as diet, activity levels, sleep, stress, habits
Family
health history, known conditions or risk factors (if you choose to share)

3.3 Genetic, epigenetic & microbiome data

For specific tests and programs (e.g., microbiome analysis,
DNA tests, epigenetic age tests), we may collect:

Biological
samples (such as saliva, cheek swabs, stool samples – as applicable)
Laboratory
results derived from those samples (e.g., DNA variants, microbiome
composition, methylation patterns)
Calculated
indicators such as biological age, risk scores, or functional
markers

We treat these as sensitive health-related data and
apply additional protections where required by law.

3.4 Test, program & clinical information

Test
orders, unique kit IDs, tracking IDs
Reports
generated for you (longevity reports, risk analysis, health blueprints)
Notes
or recommendations from health professionals working with Eternell (where
applicable)

3.5 Transaction & payment information

Products
or services you purchase
Billing
and shipping details
Payment-related
information (processed via secure third-party payment processors; we do
not store full card details on our servers)

3.6 Technical & usage data

IP
address, browser type, device type, operating system
Pages
visited, time spent, clicks, referral URLs
Log
files, cookies and similar tracking technologies

3.7 Wearables & connected devices (if you choose to
connect)

Data
from wearables or health apps you link to our platform (e.g., steps, heart
rate, sleep, activity, other metrics)
Integration
details for syncing real-time or periodic health information

3.8 Community & social interaction data

Information
you share in Eternell communities, groups or forums
Profile
information, posts, comments, likes, and messages (where applicable)

3.9 Marketing & communication preferences

Records
of your consents and preferences
Responses
to surveys, feedback forms or campaigns
Your
interactions with emails (opens, clicks, unsubscribes)

3.10 Aggregated & de-identified data

We may create aggregated, anonymised or de-identified data
from your information. This data does not identify you personally and
may be used for research, analytics, product improvement and business
reporting.

4. How we collect your information

We collect information in the following ways:

Directly
from you
- When
  you fill out forms, sign up for programs, request information or contact
  us
- When
  you order tests, supplements or other products
- When
  you upload or connect data from wearables or health platforms
Automatically
- Through
  cookies, pixels and similar technologies on our websites
- Through
  logs and analytics tools that measure website performance and usage
From
third parties
- Accredited
  laboratories and diagnostic partners who process your samples
- Healthcare
  professionals or clinics collaborating with Eternell (with appropriate
  consent and agreements)
- Payment
  processors, logistics partners and analytics providers

5. How we use your information

We use your information for the following purposes:

5.1 To provide and manage our services

Processing
orders, payments and deliveries
Managing
test kits, sample tracking and lab processes
Generating
and delivering health reports, dashboards and recommendations
Providing
access to your Eternell account and portals

5.2 To support health insights & personalization

Analyzing
health, genetic, microbiome and lifestyle data
Creating
your biological age score or similar metrics
Offering
personalized strategies, recommendations and wellness plans
Tracking
your progress over time and updating dashboards

5.3 To communicate with you

Responding
to enquiries, support requests and feedback
Sending
service-related notifications (test updates, account alerts, changes to
terms or policy)
Sharing
educational content related to your program (where appropriate)

5.4 For research, product development & improvement

Improving
the accuracy and usefulness of our reports and recommendations
Enhancing
user experience on our websites and digital platforms
Developing
new health, longevity and wellness offerings
Conducting
internal analysis and statistical research (using anonymised or
de-identified data where possible)

5.5 For marketing (where allowed by law)

Sending
you updates about new products, offers and events
Personalizing
marketing content based on your preferences and interests
Running
surveys, campaigns or pilot projects

You can opt out of marketing communications at any
time (see Section 10).

5.6 For legal, compliance & security purposes

Meeting
legal and regulatory requirements
Detecting,
preventing or investigating fraud and misuse
Protecting
our rights, property, customers and the public
Enforcing
our terms and conditions

6. Legal bases for processing (where applicable)

Depending on your location, we may rely on one or more of
the following legal bases:

Your
consent – for example, for certain health tests, use of genetic data,
or marketing communications
Performance
of a contract – to deliver services or products you have requested
Legitimate
interests – to improve our services, secure our systems or communicate
relevant updates (where these interests are not overridden by your rights)
Compliance
with legal obligations – where we are required to keep records or
share information with public authorities

You can withdraw your consent at any time where consent is
the legal basis (see Section 10).

7. How we share your information

We do not sell your personal information to third
parties for their independent marketing.

We may share your data with:

Internal
teams and affiliated entities
- Eternell
  group companies and authorised staff who need access to deliver services
  or support you
Laboratories
& diagnostic partners
- Accredited
  labs that process your biological samples and generate test data
- Medical
  or scientific partners who assist with interpretation and reporting
  (where applicable)
Healthcare
professionals & clinics
- Doctors,
  nutritionists or other practitioners involved in your program, with your
  consent or as required to deliver your chosen service
Service
providers & vendors
- Payment
  gateways, banks and fraud prevention tools
- IT,
  hosting, cloud and data storage providers
- Logistics
  and shipping partners
- Analytics
  and customer support platforms
Regulatory
and legal authorities
- When
  required by law, regulation, court order, or to protect our legal rights
  and safety
Business
transfers
- If
  we enter into a merger, acquisition, restructuring or asset sale, your
  data may be transferred as part of that transaction, subject to
  confidentiality and legal safeguards.

Whenever we share your information, we require recipients to
handle it securely and in line with applicable privacy laws and contractual
obligations.

8. International data transfers

Because we operate globally (including offices in UAE
and US, and customers from multiple countries), your information may be
transferred to and processed in countries other than your own.

Where required by law, we use appropriate safeguards for
international data transfers, such as:

Contractual
clauses and data protection agreements
Technical
and organizational security measures
Limiting
access to only those who need it

9. Data retention – how long we keep your data

We keep your personal information only for as long as
necessary to:

Provide
our services and support your programs
Comply
with legal, accounting and regulatory requirements
Resolve
disputes and enforce our agreements

Retention periods may vary depending on:

The
type of data (e.g., genetic test data, billing records, support
communications)
Legal
or clinical requirements in your country
Our
need to maintain reliable records.

After retention periods expire, we will either delete your
data securely or anonymise it so that it can no longer be linked to you.

10. Your rights & choices

Depending on your location and local laws, you may have some
or all of the following rights regarding your personal information:

Access
– to ask for a copy of the personal data we hold about you
Correction
– to request that inaccurate or incomplete data be updated
Deletion
– to request deletion of your data, subject to legal or regulatory
obligations
Restriction
– to limit how we use your data in certain situations
Objection
– to object to specific types of processing, including some types of
marketing or profiling
Data
portability – to receive your data in a structured, commonly used
format and have it transferred to another provider (where technically
feasible)
Withdraw
consent – where our processing is based on your consent, you can
withdraw that consent at any time

You also have the right to opt out of marketing emails at
any time by using the unsubscribe link in our communications or by
contacting us directly.

To exercise your rights, please contact us at: info@eternell.org
We may need to verify your identity before processing your request.

If you believe your privacy rights have been violated, you
may also have the right to lodge a complaint with your local data protection
authority.

11. Cookies & tracking technologies

We use cookies and similar technologies to:

Keep
you signed in and remember your preferences
Measure
website performance and understand how visitors use our sites
Improve
content, design and user experience
Support
certain marketing and analytics functions

You can manage cookies through your browser settings and, in
some regions, through dedicated cookie banners or preference centers on our
website. Disabling some cookies may affect your ability to use certain
features.

12. Children’s privacy

Our services are not intended for children under the age
permitted by local law (for example, under 18 in many countries), unless
tested or enrolled under the guidance of a parent, guardian or healthcare
professional and subject to appropriate consent.

We do not knowingly collect personal data from children
without proper parental or legal guardian consent. If you believe a child has
provided us with personal information without consent, please contact us and we
will take appropriate action.

13. Security – how we protect your data

We use a combination of technical, organizational and
physical safeguards to protect your information, including:

Encrypted
connections (HTTPS) on our websites
Access
controls and authentication for sensitive systems
Secure
data storage and backups
Internal
policies and staff training on confidentiality and data protection

Despite our efforts, no system can be guaranteed 100%
secure. We encourage you to keep your account details confidential and notify
us immediately if you suspect any unauthorized access.

14. Third-party links

Our websites and platforms may contain links to third-party
websites, apps or services. We are not responsible for the privacy practices of
these third parties. We recommend reviewing their privacy policies before
providing any personal information.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to
reflect:

Changes
in our services or business
Updates
in technology or security practices
New
legal or regulatory requirements

When we make significant changes, we will update the “Last
updated” date at the top of this page, and where appropriate, notify you
through our websites, email or other channels.

16. How to contact us

If you have any questions, concerns or requests related to
this Privacy Policy or your personal data, you can reach us at:

info@eternell.org

Branch Office – UAE
14th Floor, South Tower, Dubai Science Park, Dubai, UAE
+971 58 553 3724

Head Office – US
37660 Estuary Street, Newark, California 94560, US