This privacy policy was last updated May 1st, 2016.

Penscott Management Corporation owns and operates The APO E Gene Online Program, APO E Gene Diet^®, www.perfectgenediet.com and www.apoegenediet.com (known hereafter collectively as "Penscott Management Corporation", "Websites," "we" or "us"). We care about and respect the privacy of each user of our Websites.

If you have any questions or concerns regarding this or any subject related to our privacy policy, contact apoegene234 [at] me.com. You can also contact us via regular mail at:

Penscott Management Corporation

4165 Blackhawk Plaza Circle Suite 125

Danville, CA 94506.

Notification by Our Websites

Penscott Management Corporation, Websites (collectively the "Websites") have agreed to notify each user of the following:

1. What personal information of yours or a third party is collected from you by Penscott Management Corporation, Websites.
2. The name of the organization collecting such information.
3. How the information is or may be used.
4. With whom the information may be shared.
5. What choices are available to you regarding the collection, use and distribution of such information.
6. The security procedures that are in place to protect against the loss, misuse or alteration of the information which is under the control of Penscott Management Corporation, Websites.
7. How you can correct any inaccuracies in the information.

Information Collection and Use

Penscott Management Corporation, Websites collect information from their users at several different points on our Websites. When you access the APO E Gene Program or use any of the Websites some basic, general information is collected. This information is used internally to operate the program and to improve the program and Websites, as well as our marketing and advertising efforts, and to make your use of the Websites as enjoyable and efficient as possible.

Information Voluntarily Provided by You

When you set up an account on our Websites or purchase an item from our Websites, we collect personal information provided by you voluntarily that may include your:

1. first and last name;
2. billing address;
3. shipping address;
4. other shipping addresses;
5. email address;
6. phone number;
7. credit card account number;
8. items purchased from us;
9. medical history;
10. basic information to create the diet and exercise program for you. This includes your height, weight, age, exercise frequency and intensity, and APO E Gene type.

We use this personal information in order to provide you with goods and services that you request or purchase on our Websites (including the customized APO E gene program). We use your email address to provide you with information about your APO E gene program, and any orders you make. We may send emails notifying you of upcoming webinars, seminars, speaking engagements. We may send newsletters to people who have placed an order, with information about other goods and services we offer.

Your phone number may be used to contact you about your program or an order you have placed, or regarding customer offers or information you have requested or we need to provide to you.

Additional Information Collected Automatically Through Your Use of the Websites

To maintain the best possible site and program, we  collect specific information automatically.  As you use the Websites and services, certain information may also be passively collected. Through cookies, pixels, beacons, log files and other technologies we may collect information about how you use the Websites and services. This allows us to  deliver more helpful information, programs, tools, and advertisements. Please see the Third Party Advertising on Penscott Management Corporation and Targeted Advertising sections below for more information.

How We Use Your Information

Penscott Management Corporation owns and operates Penscott Management Corporation, Penscott Medical and the APO E Gene Program Websites, and is the sole owner of any information collected on them. We will not sell, share, or rent this information to a third party in any way other than as disclosed in this privacy policy without your opt-in agreement. We may share non-specific participant information with a 3rd party or vendor in ways disclosed in this privacy policy. We will not share any sensitive individual information – as outlined with HIPAA.

We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities and may, in our sole discretion, disclose personal information or other information to satisfy any law, regulation, subpoena, or government request. We reserve the right to release personal information or other information about users who we believe are engaged in illegal activities or are otherwise in violation of our Terms of Service without a subpoena, warrant or court order, if we believe, in our sole discretion, that such disclosure is necessary or appropriate to operate our Websites or to protect the rights or property of Penscott Management Corporation, our affiliates, or our officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors. We also reserve the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

Registration

To use some aspects of Penscott Management Corporation, Websites, a user must first complete a registration form on the Website. During registration, a user is required to give contact information, such as name and email address. This information is used to contact users about the services on our Websites for which they have indicated interest. In some cases, it is optional for users to provide additional, demographic information, such as age and gender, but we encourage our users to provide such information so that we can provide a more personalized experience for our users on our Websites.

Request Amendment

You have the right to request that we amend your medical information if you feel that it is incomplete or inaccurate. You must make this request in writing to our practice manager, stating exactly what information is incomplete or inaccurate and your reasoning that supports your request. We are permitted to deny your request if it is not in writing or does not include a reason to support your request. We may also deny your request if: 

• the information was not created by us, or the person who created it is no longer available to make the amendment;
• the information is not part of the record which you are permitted to inspect and copy;
• the information is not part of the designated record set kept by this practice; or if it is the opinion of the health care provider that;
• the information is accurate and complete

Uses or Disclosures Not Covered

Uses or disclosures of your health information not covered by this notice or the laws that apply to us may only be made with your written authorization.  You may revoke such authorization in writing at any time and we will no longer disclose health information about you for the reasons stated in your written authorization.  Disclosures made in reliance on the authorization prior to the revocation are not affected by the revocation.

Ways in Which We May Use and Disclose Your Protected Health Information

The following paragraphs describe different ways that we use, and disclose your protected health information.  We have provided an example for each category, but these examples are not meant to be exhaustive.  We assure you that all of the ways we are permitted to use and disclose your health information fall within one of these categories.

Treatment.  We will use and disclose your protected health information to provide, coordinate, or manage your health care and any related services.  We will also disclose your health information to other physicians who may be treating you.  Additionally we may from time to time disclose your health information to another physician who we have requested to be involved in your care.  For example – we may include information to a specialist to whom we have referred you for a diagnosis to help in your treatment.

Payment.  We will use and disclose your protected health information to obtain payment for the health care services we provide you.  For example – we may include information with a bill to a third-party payer that identifies you, your diagnosis, procedures performed, and supplies used in rendering the service.

Request Restrictions.  You have the right to request a restriction or limitation of how we use or disclose your medical information for treatment, payment, or health care operations.  For example – you could request that we not disclose information about a prior treatment to a family member or friend who may be involved in your care or payment of care.  Your request must be made in writing to our practice manager. We are not required to agree to your request if we feel that it is in your best interest to use or disclose that information.  However, if we do agree, we will comply with your request unless that information is needed for emergency treatment.

An Accounting of Disclosures.  You have the right to request a list of disclosures of your health information that we have made outside of our practice that were not for treatment, payment, or health care operations.  Your request must be made in writing and must state the time period for the requested information.  You may not request information for any dates prior to April 14, 2003 (the compliance date for the federal regulation) nor for a period of time greater than six years (our legal obligation to retain information).

Health Care Operations.  We will use and disclose your protected health information to support the business activities of our practice.  For example – we may use medical information about you to review and evaluate our treatment and services or to evaluate our staff’s performance while caring for you.  In addition, we may disclose your health information to third party business associates who perform billing, consulting, or transcription services for our practice.

Appointment Reminders.  We will use and disclose your protected health information to contact you as a reminder about scheduled appointments or treatment.

Treatment Alternatives.  We will use and disclose your protected health information to tell you about or recommend alternative treatments or options that may be of interest to you.

Others Involved in Your Care.  We will use and disclose your protected health information to a family member, a relative, a close friend, or any other person that you identify is involved in your medical care or payment for care.

Research.  We will use and disclose your protected health information to researchers provided the research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.

As Required by Law.  We will use and disclose your protected health information when required to by federal, state, or local law.  You will be notified of any such disclosures.

To Avert a Serious Threat to Public Health or Safety.  We will use and disclose your protected health information to a public health authority that is permitted to collect or receive the information for the purpose of controlling disease, injury, or disability.  If directed by that health authority, we will also disclose your health information to a foreign government agency that is collaborating with the public health authority.

Worker’s Compensation.  We will use and disclose your protected health information for worker’s compensation or similar programs that provide benefits for work related injuries or illness.

Your Health Information Rights

Although your health record is the physical property of the health care practitioner or the facility that compiled it, the information belongs to you.  You have the right to:

A Paper Copy of This Notice.  You are receiving a paper copy of this notice for your records. You may request additional copies upon request.

Inspect and Copy.  You have the right to inspect and copy the protected health information that we maintain about you in our designated record set for as long as we maintain that information.  This designated record set includes your medical and billing records, as well as any other records we use for making decisions about you.  Any psychotherapy notes that may have been included in records we received about you are not available for your inspection or copying by law.  We may charge you a fee for the costs of copying, mailing, or other supplies used in fulfilling

Health Questionnaire

When completing the initial Health questionnaire, we ask general questions about your lifestyle, family history, medical history, and current medications. This information is used to develop your personalized health program and you may use these recommendations as you choose. You have no obligation to purchase products from us. You should not use the information from Penscott Management Corporation, Websites for diagnosing or treating any health problem or disease, or prescribing any medication or other treatment.

Research

We have included two separate research gathering instruments. This research is used to improve the program. You can choose whether or not to provide the requested information. All information is private and only is used by Penscott Management or Medical Corporation.

We may release your health information without your written authorization to people who are preparing a future research project, so long as any information “identifying you” does not leave our facility and all other legal requirements are met. Under no circumstances, would we allow researchers to use your name or identity publicly.

Cookies

A cookie is a text file stored on the user's hard drive containing information about the user. Websites create cookies to record information about a user's preferences, such as the items you add to your shopping cart, and for security purposes (see Security below). Cookies are also used to help us determine the various services you use and the support you may need, and to help us detect and solve any problems you may have while using our Websites. In addition, the use of a cookie on our Websites will enable users to log on without having to for example, repetitively reenter their password on each visit and to fully participate in our sites activities. Most cookies expire after a certain time period. You can choose to set your browser to refuse all cookies and still participate in our Websites. Cookies placed by Penscott Management Corporation, Websites are NOT tied to any personally identifiable information.

Also, in the course of serving advertisements to our Websites, our third-party advertisers may place or recognize a unique cookie on your browser.

Third Party Advertising on Penscott Management Websites

Banner advertisements appearing on these Websites are delivered to you by third-party ad-servers (Google Clicktracker). Information about your visits to these Websites, such as number of times you have viewed an ad (but not your name, address, or any other personal information), is used to serve ads to you.

Targeted Advertising

Penscott Management Corporation, Websites third party vendors may use cookies to understand Web usage patterns of users who see advertisements on the Websites, to control the sequence of advertisements you see, to make sure you don't see the same advertisement too many times, to determine your interests and to target advertisements and promotions based on those interests. These third party vendors may connect information about pages you visit on our Websites with information about pages you visit on other Websites, and show you advertising based on this combined information. The advertisement may appear when you are visiting a different section of the Websites, another site or any other website on the Internet if the website also has a relationship with our vendor.

Information Collected by Third Party Advertisers

Advertisers on the Websites may also engage in Behavioral Advertising and use cookies and web beacons in the manner described above. We do not control these third parties' use of cookies or web beacons or what they do with the information they collect. Many third party vendors that engage in Behavioral Advertising participate in the Network Advertising Initiative (NAI) and abide by NAI principles, which prohibit members from connecting Personal Information to information they collect through cookies without your explicit consent. If you wish to opt out of participating in advertising programs conducted by NAI members or learn more about the NAI, please go to the NAI Opt-Out website and follow the instructions. After you opt-out, you will still see advertisements from NAI members, but the advertising will not be tailored to your web preferences and usage patterns.

If you would like more information about these practices and to know your choices about not having this information used, please visit http://www.doubleclick.com/privacy/opting_out.aspx.

Behavioral Advertising Cookies

Penscott Management Corporation and Websites display retargeted ads to our site prospects, on our behalf, across the Internet by the use of the services of advertising partners who collect non-personally identifiable information about your visits to our Websites, and your interaction with our products and services. The anonymous information is collected through the use of a pixel tag, which is industry standard technology, used by most major Websites. No personally identifiable information is collected during this process. If you do not want the advertising partners of Penscott Management Corporation and Websites to collect this information, you may opt out of their services. Opting out will not affect your use of Penscott Management Corporation and Websites.

If you wish to opt out of participating in advertising programs conducted by NAI members or learn more about the NAI, please go to the NAI Opt-Out website and follow the instructions. After you opt-out, you will still see advertisements from NAI members, but the advertising will not be tailored to your web preferences and usage patterns.

Disclosure of Information to Third Party Advertisers and Partners

We know how important it is to keep the information you've entrusted to us confidential. We will not rent, sell or share your personal information with third parties except as specifically approved or under the circumstances described below. If you do not want us to use or disclose personal information collected about you in the ways identified in this policy, you should not use the Websites or services.

A. Disclosure for Legal Reasons We may disclose and release your personal information to third parties: (a) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (b) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or a violation or alleged violation of this policy or other agreement we may have with you.

B. Disclosure for Shipping and Billing Reasons We use an outside credit card processing company to bill users for goods and services purchased on our Websites. These companies will not retain, share, store or use any of our user's personal information for any secondary purposes. We partner with other parties to provide specific services that are available on our Websites. When a user signs up for these services, we will share the user's name or other contact information that is necessary for the third party to provide these services to the use. These parties are not allowed to use such personal information except for the purpose of providing these services.

Log Files

Like most standard Websites, we use log files on our servers. These log files store information regarding IP (internet protocol) addresses, browser type, ISP (internet service provider), referring/exit pages, platform type, date/time stamp, and number of clicks. These log files are used to analyze trends, administer the Websites, track user's movements in the aggregate, and gather broad demographic information for our use. IP addresses, etc. are not linked to personal information.

Web Analytics Services & Tracking 

Penscott Management Corporation and Websites use third-party tracking and analytics services Google Analytics. The information collected about your use of the Websites (including your IP address) will be transmitted to and stored by the Analytics Service Provider on servers in the United States. The Analytics Service Provider use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The Analytics Service Provider may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the Analytics Service Provider’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website. By using Penscott Management Corporation and Websites, you consent to the processing of data about you by our Analytics Service Providers in the manner and for the purposes set out above.

Links

The Websites contain links to other Websites. We want you to be aware that when you click on such links, including banner advertising, which take you to a third-party or Licensee Website, you will be subject to such third-party's or Licensee privacy policies. We are not responsible for the privacy practices of such other Websites and we expressly disclaim any and all liability for the actions of third parties or Licensees, including, without limitation, actions relating to the use and/or disclosure of personal information by such third parties or Licensees. We encourage our users to be aware of when they leave our Websites and enter a third-party Website and to read the privacy statements of each and every Website that collects their personal information. This privacy policy applies solely to information collected by our Websites.

Newsletters

Penscott Management Corporation uses an internal email management system as well as a third-party Email Service Provider (Constant Contact.). If a user wishes to subscribe to one of our e-bulletins we will ask for contact information, such as name and email address.

User Generated Content: Feedback, Ratings, Comments, and Public Forums

In order to post a message, comment, or rate on our Websites, you will be asked to sign in with your member login information. We do not use this information in any way other than to recognize you for postings. We do not disclose this information to any third parties.

With regard to the message boards, your email address is not visible on the boards, however other users are able to send you email via your nickname without your email address being displayed. Penscott Management does not share this information with any third parties unless required by authorized law enforcement agencies.

Whatever you post on the message boards is considered public knowledge and you should always use caution when posting. Avoid posting your home address or phone number on any public board or chat. Although one must be a registered user to post messages the message boards are public and may be read by non-registered users.

Penscott Management reserves the right to re-publish your postings from the message boards in any format. To request removal of your personal information from our blog or community forum, contact us at apoegene234 [at] me.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Surveys and Contests

From time-to-time, our Websites request information from our users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user has a choice whether or not to provide us with such information. Information requested may include contact information, such as name and shipping address, and demographic information, such as zip code, age level. It may also be shared with other third parties as disclosed at the time of collection or in the promotion rules. These third parties may include a provider of prizes in order to update you of your status of you prize or other fulfillment needs or a co-sponsor who may use your Personal Information to administer the promotion or for marketing purposes, but only in conformance with their privacy policy as made available to you at the time of collection. If data will be disclosed or shared in this manner, we will include a notice at the time of collection of such information. Contact information will be used to notify the winners and award prizes. Survey information will be used to monitor or improve the use and efficiency of these Websites.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about the security of our Websites, you can send an email to apoegene234 [at] me.com.

Communications from our Websites

We send all new members a welcoming email to verify their email address.

Established members will occasionally receive information on products, services, special deals, and the e-bulletins. Each user has the option to not receive these types of communications (see Choice/Opt-Out below).

Occasionally, it is necessary to send out service-related announcements. For instance, if our service is temporarily suspended for maintenance, we might send you an email informing you of such service interruption. Generally, users may not opt-out of receiving these service-related communications. In addition, we may email users to provide requested services and regarding issues relating to their account via email.

Correction/Updating Personal Information  

If a user's personal information changes or if a user no longer desires our service, we will enable our user to correct or update from our Websites the personal data they provide to us. To be removed from the our Websites, please email our Webmaster at apoegene234 [at] me.com

Choice/Opt-out

Our users are given the opportunity when registering with our Websites to opt-out of having their information used for purposes not directly related to the provision of goods or services through our Websites and for each Web newsletter, publication or special edition. Our Profile page has an opt-out mechanism so, users purchasing a product, newsletter or membership from us may elect to not have their email address added to our marketing and promotional address lists.

Users who no longer wish to receive  e-bulletins or other marketing and promotional materials from us or from our partners may opt-out of receiving these communications by replying to any such promotional email indicating their desire to no longer receive such emails, or by emailing our Webmaster at apoegene234 [at] me.com. Users of our Websites will be notified if, in connection with the use of a particular service on our Websites, their information will be collected by any outside third-party. At such time, the user can determine whether they wish to proceed with a service that will involve an outside party having access to their information.

Collecting Information from Children Younger Than 13 Years of Age

The Websites are not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on the Websites or through the services. If we later obtain actual knowledge that a user is under 13 years of age, we will take steps to remove that user's Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at apoegene234 [at] me.com so that we may delete and remove such child's information from our systems.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at apoegene234 [at] me.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Notification of Changes in Use of Information

Our privacy policy is subject to change. In the event of any change, we will provide notice of such change on our Websites. If we want to use your personal information in a manner different from that stated to you at the time you provided such information to us, we will notify you of such change by posting notification of such change on our Websites. At such time, you can determine whether you wish to allow us to use your information in this different manner. If you have opted out of all communication with our Websites or have deleted or deactivated your account with us, then you will not be contacted and your personal information will not be used.

Contact Information

If you have any questions about this privacy policy or believe that Penscott Management Corporation Websites are not abiding by our privacy policy, please contact our Webmaster by e-mail at apoegene234 [at] me.com.