Cookie Policy

Privacy Policy

neotes GmbH (hereinafter referred to as "we") operates the website accessible at www.neotes.com and the associated subdomains and subdirectories (hereinafter referred to as the "Website").

With this Privacy Policy, we would like to inform you about which data we process and in what manner when you visit our Website. At the same time, we hereby fulfill our obligation to provide information pursuant to Article 13 of the General Data Protection Regulation (GDPR).

Controller
The controller responsible for data processing carried out on our Website under data protection law is:

neotes GmbH
Ziegelstrasse 7C
40468 Düsseldorf
Germany
cs@neotes.care

The following person is designated as the data protection officer responsible: Roman Kacer

Purposes, Legal Basis for Data Processing and Storage Period

General Use of the Website

The web server of our hosting provider automatically records access to our Website. Accordingly, when you visit our Website, data is automatically transmitted to us. This data includes:

  • Your IP address
  • The content accessed
  • Information regarding the data transmission
  • Date and time of access
  • The volume of data transmitted
  • Your internet service provider
  • The referrer
  • Your web browser / user agent

We process this data for the purpose of enabling you to access our Website based on our legitimate interest. The legal basis for this processing is Article 6(1)(f) GDPR. After your visit, your IP address is anonymized and the remaining data is stored in log files without any personal reference.

Creation of a User Account

If you wish to create a user account, you must register. In order to complete your registration via the Website and create your user account, we process the following data:

  • Email address
  • Password

We use this data to create your user account and provide you with the corresponding user account functions. The legal basis for this processing is Article 6(1)(b) GDPR.

Purchase of Products and Services

a) Disclosure of Data

For the operation of our Website and the processing of your purchases, it may be necessary to disclose your data to the following recipients:

  • Byrd GmbH (Ritterstrasse 12-14, 10969 Berlin) as recipient of the data for the purpose of processing and shipping orders

This data processing is carried out on the basis of overriding legitimate interests (Article 6(1)(f) GDPR) within the EEA and concerns our customers. Byrd GmbH acts solely on our instructions and has been contractually obligated in accordance with Article 28 GDPR to comply with all applicable data protection requirements.

If you wish to purchase one of our products, you may do so as a guest. For this purpose, we require the following information:

  • Email address
  • First name
  • Last name
  • Street and house number
  • Address supplement / Company / C/O
  • Postal code
  • City
  • Country

In addition, further payment information, such as your credit card number, is collected during the payment process.

This data is used to receive, process and fulfill your order. The legal basis for this processing is Article 6(1)(b) GDPR.

If you subscribe to our newsletter during the ordering process, we will use your email address after your purchase to send you advertising relating to our products, offers and services. We also use information about you, such as previous purchases or survey responses, to tailor advertising to your interests. In addition, we analyze newsletter usage data, such as clicked links, opened pages and similar interactions. You may object to this use at any time. Further information can be found below under your data subject right of "Right to Object." The legal basis for this processing is Article 6(1)(f) GDPR. Our legitimate interest is to send you relevant advertising and to gain insights from your use of our services.

b) Diagnostics

aa) bioAge Test

By ordering the bioAge Basic and bioAge Premium products, you consent to your submitted samples and the health-related data contained therein being processed by neotes for the purpose of analyzing and providing your test results. The data will be shared in pseudonymized form with our partner Agelabs AS, Gaustadalleen 23A, 0373 Oslo, Norway. You may revoke your consent at any time with effect for the future.

We would like to point out that, where applicable, we process the analysis results for scientific research purposes after removing all identifying and allocation characteristics. It is then no longer possible for us to associate the data with your person.

Customers who purchase the bioAge Test Premium also agree that the test results will be forwarded to the consulting physician for the medical consultation included with the product.

bb) HS-Omega 3® Index, Intest-Pro® Gut Microbiome Test and NAD Test®

If you purchase one of the following tests:

  • HS-Omega-3 Index by Omegametrix® GmbH, Am Klopferspitz 19, 82152 Martinsried, Germany,
  • Intest-Pro Gut Microbiome Test by Biomes GmbH, Schwarzkopfstrasse 1, 15745 Wildau, Germany
  • NAD Level Test by Jinfinity Inc., 1235 Walton Way, Augusta, GA 30901, USA

the following provisions shall apply:

We will send you the respective test kit. You will send your sample and register your test kit yourself with the respective company using the required information. The respective partner company listed above will then provide your results using the contact details supplied during registration. The above-mentioned tests are performed under the terms and conditions of the respective provider and under their sole responsibility.

cc) bloodAge Test

When ordering the bloodAge Test, you select a referring physician near your location on the website, with whom you subsequently arrange an individual appointment for the blood sample collection. The referring physician sends the blood sample to the laboratory at Hormonzentrum an der Oper, Maximilianstrasse 2, 80539 Munich, Germany, for analysis.

By purchasing the bloodAge Test, you consent to the test results being forwarded to the consulting referring physician you selected for the medical consultation included with the product. This includes, in particular, information relating to examination results as well as any incidental findings obtained during the evaluation.

dd) bioCoach Program

By purchasing the bioCoach Program, which provides customers with a personalized longevity lifestyle through a holistic approach consisting of improving medical parameters, supplementing the body's essential micronutrients, and implementing further measures for stress reduction and lowering biological age, you consent to your data being shared with various partners depending on the subscription selected and its individual components. Details are set out in the following subsections:

"Basic M6" and "Basic M12" Subscription

  • bioAge Test Premium: Agelabs AS, Oslo (see subsection aa)), repeated every 6 months
  • Gut Microbiome Test: Biomes GmbH, Wildau (see subsection bb)), repeated every 6 months
  • Recurring longevity consultation following the bioAge and Gut Microbiome Tests (see subsection aa)
  • 2 micronutrient products per month: Byrd GmbH, Berlin (see subsection a))

"Premium M12" Subscription

  • bioAge Test Premium: Agelabs AS, Oslo (see subsection aa)), repeated every 12 months
  • Gut Microbiome Test: Biomes GmbH, Wildau (see subsection bb)), repeated every 12 months
  • Recurring longevity consultation following the bioAge and Gut Microbiome Tests (see subsection aa)
  • 5 micronutrient products per month: Byrd GmbH, Berlin (see subsection a))
  • Longevity bloodAge Test: Hormonzentrum an der Oper, Munich (see subsection cc)), repeated every 12 months
  • Recurring longevity consultation following the Longevity bloodAge Test (see subsection cc)

By purchasing the bioCoach Program, you consent to the transfer of your health data, including data from your wearable devices together with all other information relevant to your consultation, to neotes' IT partner, Datarella GmbH, Oskar-von-Miller-Ring 36, 80333 Munich, Germany, for optimized data aggregation. Further information can be found in Section 12 of our General Terms and Conditions.

We would again like to point out that we process analysis results for scientific research purposes after removing all identifying and allocation characteristics. It is therefore no longer possible for us to associate this data with your person.

This processing is carried out on the basis of Article 6(1)(f) GDPR in conjunction with Article 9(2)(j) GDPR and Section 27(1) of the German Federal Data Protection Act (BDSG), based on our legitimate scientific interest in conducting the aforementioned research.

neotes Membership

By subscribing to a membership, you consent to your data being shared with partners for the respective purposes described below, depending on the membership plan selected:

Starter Membership

  • Free shipping (no minimum order value) – Byrd GmbH, Berlin (see subsection a))

Professional Membership

  • Month 1: bioAge Test Premium including longevity consultation: Agelabs AS, Oslo (see subsection aa))
  • Months 2 through 13: Receipt of up to three micronutrient products tailored to the customer's individual needs: Byrd GmbH, Berlin (see subsection a))
  • Month 14: Review of progress by repeating the bioAge Test Premium: Agelabs AS, Oslo (see subsection aa))

Expert Membership

  • Month 1: bioAge Test Premium including longevity consultation: Agelabs AS, Oslo (see subsection aa))
  • Months 2 through 13: Receipt of up to three micronutrient products tailored to the customer's individual needs: Byrd GmbH, Berlin (see subsection a))
  • Month 14: Review of progress by repeating the bioAge Test Premium: Agelabs AS, Oslo (see subsection aa))
  • Receipt of exclusive product gifts on special occasions: Byrd GmbH, Berlin (see subsection a))

Payment in the Online Store

For payment processing in our online store, we use payment service providers to whom you provide your data directly. The payment providers themselves inform you about the processing of your data.

Among others, we use PayPal, a service provided by PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg, as a payment service provider. If you select PayPal as your payment method, we will transmit the email address you provided during the ordering process to complete your order. The subsequent payment process is carried out exclusively through PayPal, over which we have no further influence. PayPal provides separate information regarding the collection, processing and storage of your data. You can find PayPal's Privacy Policy at www.paypal.com/de/webapps/mpp/ua/privacy-full. The transfer of your data to PayPal is justified pursuant to Article 6(1)(b) GDPR.

We also offer payment via Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (www.americanexpress.com/de/content/privacy-policy-statement.html), Klarna (www.cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/privacy), Google Pay (www.payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=buyertos&ldr=DE), Apple Pay (www.apple.com/de/privacy/), iDEAL (www.ideal.nl/en/disclaimer-privacy-statement/), Bancontact (www.bancontact.com/files/privacy.pdf), and QPay (www.qpay.com.np/privacypolicy.html). If you choose to pay using one of these payment service providers, the payment data you enter will be transmitted to the respective provider. Your data is transferred pursuant to Article 6(1)(b) GDPR. All data required for payment processing is used exclusively for processing the payment and is transmitted using SSL encryption.

Newsletter

When subscribing to our newsletter, your email address and first name are stored with your consent and used exclusively for our own marketing purposes until you unsubscribe from the newsletter. The necessary processing is carried out based on your informed consent (Article 6(1)(a) GDPR). We store your data until you withdraw your consent.

For this purpose, we use the so-called double opt-in procedure. This means that we will only send you our email newsletter after you have expressly confirmed your consent. We will send you a confirmation email asking you to confirm your subscription by clicking the link contained in that email. You may unsubscribe from the newsletter at any time without incurring any costs other than the transmission costs according to the basic rates. A notification in text form to the contact details listed under Section 13 (e.g. email or letter) is sufficient. In addition, every newsletter contains an unsubscribe link.

Contact

We offer you the opportunity to contact us via the email address provided above. In this case, you automatically provide us with your email address and, where applicable, your name, a subject line and the content of your message. We process this data solely to respond to your inquiry. This purpose also constitutes our legitimate interest in processing the data (Article 6(1)(f) GDPR).

We store your emails only for as long as necessary to process your inquiry directly and for a maximum period of three years in case you contact us again regarding your original inquiry. This does not apply if you initiate a contractual relationship with us through your email. In such cases, the storage period is determined by the respective contract. You will be informed separately about the data processing taking place in this context.

Recipients of the Data

Within our company, only those departments responsible for handling your request have access to your data. We also use external service providers where we cannot reasonably perform services ourselves. These external service providers primarily include IT service providers such as our hosting provider, email service provider and telecommunications providers.

Our email delivery service provider is located in the United States. However, the service provider is certified under the EU-US Privacy Shield, ensuring an adequate level of data protection for the processing of your personal data.

On our Website, we use Zendesk Chat, a live chat software provided by Zendesk Inc., 989 Market Street #300, San Francisco, CA 94102, USA. The software is used for processing and documenting messages and data submitted through the live chat.

Zendesk Chat serves the purpose of enabling direct real-time communication with visitors to the neotes GmbH Website. When accessing a page equipped with a Zendesk Chat component, the user's IP address is collected and transmitted in anonymized form.

Zendesk Chat uses cookies. The information generated by these cookies (see "Scope of Data Collection by Zendesk") regarding your use of our Website is stored. By using the live chat system, you consent to the processing of the data collected about you by Zendesk Chat in the manner described below and for the purposes stated above. Further details regarding the use of cookies can be found at https://support.zendesk.com/hc/en-us/articles/4408824378650-Zendesk-In-Product-Cookie-Policy.

Except where expressly stated elsewhere in this Privacy Policy, we do not transfer your data to countries outside the European Economic Area.

Cooperation with Data Processors

We also engage the following companies as our cooperation partners:

  • Age Labs (Oslo, Norway) to carry out the epigenetic examination and analysis of your blood samples. For this purpose, your pseudonymized data is transferred to Age Labs in Norway to perform these services. Age Labs acts solely on our instructions. Age Labs has been contractually obligated in accordance with Article 28 GDPR to comply with the applicable data protection provisions. Age Labs may not use your data for any other purposes. Furthermore, Age Labs is obliged to process this data in accordance with this Privacy Policy and the applicable data protection laws.
  • Biomes GmbH, Schwarzkopfstrasse 1, 15745 Wildau, Germany, for performing the Intest-Pro Gut Microbiome Test.
  • The laboratory of Hormonzentrum an der Oper, Maximilianstrasse 2, 80539 Munich, Germany, for determining the bloodAge Index.
  • Datarella GmbH, Oskar-von-Miller-Ring 36, 80333 Munich, Germany, for the optimized compilation of the customer's health data, including data from the customer's wearable devices, for the bioCoach Program.
  • We engage our logistics partner Byrd GmbH (Ritterstrasse 12-14, 10969 Berlin, Germany) for the shipment of our products. Byrd GmbH acts as the recipient of the data for the purpose of processing and shipping orders. For this purpose, the personal data you provide is transferred to Byrd GmbH to perform these services. Byrd GmbH acts solely on our instructions. Byrd GmbH has been contractually obligated in accordance with Article 28 GDPR to comply with the applicable data protection provisions. Byrd GmbH may not use your data for any other purposes. Furthermore, Byrd GmbH is obliged to process this personal data in accordance with this Privacy Policy and the applicable data protection laws.

Data Subject Rights

The General Data Protection Regulation (GDPR) grants you certain rights that you may exercise against us, provided that the applicable legal requirements are met. These include in particular:

  • Article 15 GDPR – Right of Access: You have the right to obtain confirmation as to whether we process personal data relating to you and, if so, information about that data and the details of the processing.
  • Article 16 GDPR – Right to Rectification: You have the right to obtain without undue delay the correction of inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
  • Article 17 GDPR – Right to Erasure: You have the right to request the immediate deletion of personal data concerning you.
  • Article 18 GDPR – Right to Restriction of Processing: You have the right to request the restriction of the processing of your personal data.
  • Article 20 GDPR – Right to Data Portability: Where processing is based on your consent or is necessary for the performance of a contract, you have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller without hindrance from us, or to have the data transmitted directly to another controller where technically feasible.
  • Article 77 GDPR in conjunction with Section 19 BDSG – Right to Lodge a Complaint with a Supervisory Authority: You have the right to lodge a complaint at any time with a supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement, if you believe that the processing of your personal data violates applicable data protection law.

The following applies in particular with regard to your right to object and your right to withdraw consent:

Article 21 GDPR – Right to Object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you where such processing is based on our legitimate interests, is necessary for the performance of a task carried out in the public interest, or is carried out in the exercise of official authority.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where the processing serves the establishment, exercise or defense of legal claims.

Where we process your personal data for direct marketing purposes, you have the right to object at any time to such processing. If you object to processing for direct marketing purposes, we will no longer process your personal data for those purposes.

Withdrawal of Consent: If you have given us your consent, you have the right to withdraw it at any time. Any processing carried out before your withdrawal remains lawful. To withdraw your consent, simply click the unsubscribe link included in every email or send a message to one of our email addresses. If you inform us that you no longer wish to receive emails from us, we will cease sending messages to the email address you have provided.

Changes to this Privacy Policy

As data protection law continues to evolve and due to technological or organizational changes, this Privacy Policy is regularly reviewed to determine whether amendments or additions are required. You will be informed of any changes, in particular, on the German version of our website at www.neotes.com. This Privacy Policy is effective as of August 2024.

No Obligation to Provide Data

You are under no contractual or legal obligation to provide us with personal data. However, without the data you provide, we are unable to offer you our services.

Existence of Automated Decision-Making (Including Profiling)

We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

III. Internet-Specific Data Processing / Cookies

To expand the functionality of our online services and make our Website more convenient for you to use, we use so-called "cookies." These "cookies" enable data to be stored on your computer when you access our Website. You can prevent cookies from being stored on your computer by adjusting the settings in your browser. Please note, however, that doing so may limit the functionality of our Website.

When using the Website, cookies are stored on your computer. Cookies are small text files that are stored on your hard drive and associated with the browser you use. They enable the party setting the cookie (in this case, us) to receive certain information. Cookies cannot execute programs or transmit viruses to your computer. They serve to make our Website more user-friendly and effective overall.

The Website uses cookies to the following extent: transient cookies (temporary use), persistent cookies (limited-term use), and third-party cookies.

Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. They store a so-called session ID that allows various requests from your browser to be assigned to the same session. This enables your computer to be recognized when you return to the Website. Session cookies are deleted when you log out or close your browser.

Persistent cookies are automatically deleted after a predefined period, which varies depending on the respective cookie. You may delete cookies at any time using your browser's security settings.

You can configure your browser settings according to your preferences and, for example, reject third-party cookies or all cookies. Please note that if you do so, you may not be able to use all functions of this Website. You can also configure your browser to require your consent each time before cookies are stored and activated on your computer. Detailed information regarding your browser settings can be found on your browser provider's website or in the documentation for the most commonly used browsers.

Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google Ireland Ltd., Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google Analytics uses cookies. The information generated by the cookie about your use of this Website is generally transmitted to and stored on a Google server in the United States. If IP anonymization is activated on this Website, your IP address will first be truncated by Google within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and shortened there. On behalf of the operator of this Website, Google will use this information to evaluate your use of the Website, compile reports on Website activity, and provide other services relating to Website and Internet usage to the Website operator. The IP address transmitted by your browser within the scope of Google Analytics will not be merged with other Google data.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software. Please note, however, that if you do so, you may not be able to use all features of this Website to their full extent. You can also prevent Google from collecting and processing the data generated by the cookie relating to your use of the Website (including your IP address) by downloading and installing the browser plug-in available at the following link: www.tools.google.com/dlpage/gaoptout?hl=de .

The legal basis for the use of Google Analytics is Article 6(1)(f) GDPR. Our legitimate interest lies in analyzing the use of our Website. The data is stored for 38 months.

Further information regarding the terms of use and data protection can be found at www.google.com/analytics/terms/de.html and at www.google.de/intl/de/policies.

Facebook Custom Audiences

We use Facebook Custom Audiences provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. This allows us to display targeted advertisements to you on Facebook if you have a Facebook user account. For this purpose, the Facebook Pixel establishes a direct connection between your browser and Facebook's servers and transmits your Website usage data to Facebook for analysis and marketing purposes. If you are a Facebook user, this data may be associated with your Facebook account. Through this tracking technology, Facebook may be able to track your activities across multiple websites. Your data may be processed by Facebook Ireland Limited on servers operated by Facebook Inc. in the United States. Since this service and the associated data processing are solely under Facebook's responsibility, we have no influence over any processing of personal data carried out by Facebook. Further information regarding the collection and use of your data by Facebook can be found in Facebook's Privacy Policy at www.facebook.com/policy.php.

If you wish to object to the use of Facebook Website Custom Audiences, you may change the corresponding settings in your Facebook user account at: www.facebook.com/ads/website_custom_audiences.

The legal basis for the use of Custom Audiences is Article 6(1)(f) GDPR. Our legitimate interest is to display advertising targeted to relevant audiences.

Use of the Remarketing or "Similar Audiences" Function of Google Inc.
We use the Remarketing or "Similar Audiences" function provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; "Google") on our Website. This function is used to analyze visitor behavior and interests.
Google uses cookies to analyze Website usage, which forms the basis for creating interest-based advertisements. The cookies record visits to the Website and anonymized data regarding Website usage. No personal data of Website visitors is stored. If you subsequently visit another website within the Google Display Network, you may be shown advertisements that are highly likely to take into account products and information that you previously viewed.
Your data may also be transferred to the United States. An adequacy decision of the European Commission exists for data transfers to the United States.

The processing is carried out on the basis of Article 6(1)(f) GDPR based on our legitimate interest in addressing Website visitors with targeted advertising by displaying personalized, interest-based advertisements to visitors of our Website when they visit other websites within the Google Display Network.

You have the right, on grounds relating to your particular situation, to object at any time to the processing of your personal data based on Article 6(1)(f) GDPR.

For this purpose, you can permanently disable Google's use of cookies by following the link below and downloading and installing the plug-in provided there: www.support.google.com/ads/answer/7395996?hl=de. Alternatively, you can disable the use of cookies by third-party providers by visiting the opt-out page of the Network Advertising Initiative at www.networkadvertising.org/choices and following the further opt-out instructions provided there.
Further information regarding Google Remarketing and Google's Privacy Policy can be found at: www.google.com/privacy/ads.

Berlin, August 2024