Cookie Policy

Privacy Policy

neotes GmbH, (hereinafter referred to as “we”) operates the websites accessible on the internet at www.neotes.com and the respective associated subdomains and subdirectories (hereinafter the “Website”).

With this privacy policy, we would like to inform you which data we process, in what form, when you visit our Website. In doing so, we also fulfil our obligation to provide information pursuant to Art. 13 of the General Data Protection Regulation (GDPR) to you.

Controller
The controller responsible under data protection law for the data processing taking place on our Website is

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

Within the company, Roman Kacer is named as the data protection officer.

Purposes and legal basis of data processing and storage duration

General use of the Website

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

  • your IP address
  • content accessed
  • information about data transmissions
  • date and time of access
  • the amount of data transmitted
  • your provider
  • the referrer and
  • your web browser/user agent used

We process this data for the purpose of and based on our legitimate interest in enabling you to access our site. The legal basis for data processing is therefore Art. 6(1)(f) GDPR. After your visit, your IP address is anonymized and the remaining data is stored in log files in non-personal form.

Opening a user account

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

  • email address
  • password

We use this data to set up a user account for you and provide you with the corresponding functions of the user account. The legal basis for this processing is Art. 6(1)(b) GDPR.

Purchase of products and services

a) Disclosure of data

For the operation of our Website and your purchase, it may be necessary for us 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 predominantly legitimate interests (Art. 6(1)(f) GDPR) within the EEA and concerns our customers. Byrd GmbH acts only on our instructions and has been contractually obliged within the meaning of Art. 28 GDPR to comply with data protection regulations.

If you wish to purchase one of our products, we give you the option to buy the item as a guest. For this we require the following data:

  • email address
  • first name
  • last name
  • street and house number
  • address supplement/company/c/o
  • postal code
  • city
  • country

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

This data is used to accept, process, and fulfil your order. The legal basis for this is Art. 6(1)(b) GDPR.

If you subscribe to our newsletter as part of the order, we use your email address after the purchase to send you advertising for our products, offers, or services. We use information about you, for example from previous purchases or surveys, to tailor the advertising to you. We also analyse usage data in these newsletters, such as clicked links, opened pages, and similar. You can object to this use at any time. Further details can be found below in the explanations of your data subject right to “objection.” The legal basis for this is Art. 6(1)(f) GDPR. Our legitimate interest is to send you advertising and gain insights from your use.

b) Diagnostics

aa) bioAge test

By ordering the products bioAge Basic and bioAge Premium, you agree that your submitted samples and the health-related data contained therein will be processed by neotes for the evaluation and provision of the analysis results. The data is shared in pseudonymized form with the partner Agelabs AS, Gaustadalleen 23A, 0373 Oslo, Norway. You may withdraw your consent once given at any time with effect for the future.

Please note that we may process the analysis results for scientific research purposes after removing all identifying and assignment features. It will then no longer be possible for us to assign the data to your person.

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

bb) HS-Omega 3® Index, Intest-Pro® gut flora 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 flora test by Biomes GmbH, Schwarzkopfstrasse 1, 15745 Wildau
  • NAD Level Test by Jinfinity Inc, 1235 Walton Way, Augusta, GA 30901, USA

the following provisions apply:

We will send you the respective test kits. You send your sample and register your test kit yourself with the required information at the respective company. The aforementioned partner company will then provide you with the results via the address given during registration. The aforementioned tests are carried out under the conditions of the respective provider and under their sole responsibility.

cc) bloodAge test

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

When purchasing the bloodAge test, you agree that the results of the test will be forwarded to the advising referring physician chosen by you for the medical consultation included in the product. This includes in particular information about examination results, but also any incidental findings obtained as part of the evaluation.

dd) bioCoach program

When purchasing the BioCoach program, which paves the way for the customer toward an individual longevity lifestyle through a holistic approach consisting of improving medical parameters, supplementing the body’s own vital nutrients, as well as further measures to reduce stress and lower biological age, you agree that, depending on the chosen subscription and its individual components, data will be shared with various partners. Details can be found in the following subsections:

“Basis M6” and “Basis M12” subscription

  • bioAge Test Premium: Agelabs AS, Oslo (see under aa)), recurring every 6 months
  • Gut flora test biomes GmbH, Wildau (see under bb)), recurring every 6 months
  • recurring longevity consultation after bioAge and gut flora tests (see under aa)
  • 2 micronutrients per month: Byrd GmbH, Berlin (see under a))

 

“Premium M12” subscription

  • bioAge Test Premium: Agelabs AS, Oslo (see under aa)), recurring every 12 months
  • Gut flora test biomes GmbH, Wildau (see under bb)), recurring every 12 months
  • recurring longevity consultation after bioAge and gut flora tests (see under aa)
  • 5 micronutrients per month: Byrd GmbH, Berlin (see under a))
  • longevity bloodAge test: Hormonzentrum an der Oper, Munich (see under cc)), repeated every 12 months
  • recurring longevity consultation after the longevity bloodAge test (see under cc)

By purchasing the bioCoach program, you agree that your health data, including data from your wearables and any further findings relevant to the consultation, will be transmitted to neotes’ IT partner, Datarella GmbH, Oskar-von-Miller-Ring 36, 80333 Munich, Germany, for the optimized compilation of information. More detailed information on this can be found in Section 12 of the Terms and Conditions.

We would like to point out again that we process the analysis results for scientific research purposes after removing all identifying and assignment features. It will then no longer be possible for us to assign the data to your person.

This is done on the basis of Art. 6(1)(f) GDPR in conjunction with Art. 9(4) GDPR in conjunction with Section 27(1) BDSG in light of our legitimate scientific interests in the above-mentioned research.

neotes membership

By booking a membership, you agree that, depending on the chosen subscription, data will be shared with partners for the respective stated purpose:

Starter membership

  • free shipping (no minimum order value) – Byrd GmbH, Berlin (see under a))

 

Pro membership

  • in month 1: performance of the bioAge Test Premium incl. longevity consultation: Agelabs AS, Oslo (see under aa))
  • in months 2 to 13: receipt of up to three micronutrients corresponding to the customer’s individual needs: Byrd GmbH, Berlin (see under a))
  • in month 14: review of progress by repeating the bioAge Test Premium: Agelabs AS, Oslo (see under aa))

 

Expert membership

  • in month 1: performance of the bioAge Test Premium incl. longevity consultation: Agelabs AS, Oslo (see under aa))
  • in months 2 to 13: receipt of up to three micronutrients corresponding to the customer’s individual needs: Byrd GmbH, Berlin (see under a))
  • in month 14: review of progress by repeating the bioAge Test Premium: Agelabs AS, Oslo (see under aa))
  • receipt of exclusive product gifts on special occasions: Byrd GmbH, Berlin (see under a))

 

Payment in the online shop

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

We use, among others, PayPal as a payment service provider, a service of PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg. If you select PayPal for payment processing, we will transmit the email address you provided to us during the ordering process to complete your order. The subsequent payment process takes place exclusively via PayPal, without any further influence on our part. PayPal informs you separately about the collection, processing, and storage of your data taking place there. You can find PayPal’s privacy policy at www.paypal.com/de/webapps/mpp/ua/privacy-full. Transmission to PayPal is justified on the basis of Art. 6(1)(b) GDPR.

We also offer payment via Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), and 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 payment through one of these payment service providers, the payment data you enter will be transmitted to the respective provider. The transmission of your data takes place on the basis of Art. 6(1)(b) GDPR. All data required for payment processing is used exclusively for carrying out payments and is transmitted via the “SSL” process.

Newsletter

When you subscribe to the newsletter, your email address and first name are stored with your consent and used exclusively for our own advertising purposes until you unsubscribe from the newsletter. The processing required for this is carried out on the basis of your informed consent (Art. 6(1)(a) GDPR). We store your data until revoked.

For this purpose, we use the so-called double opt-in procedure, i.e. we will only send you our email newsletter if you have expressly given us your consent to do so. To this end, we send you a confirmation email asking you to give your consent by clicking the link contained in the email. You can unsubscribe from the newsletter at any time without incurring any costs other than the transmission costs according to the basic rates. A message in text form to the contact details named in section 13 (e.g. email, letter) is sufficient for this purpose. Of course, you will also find an unsubscribe link in every newsletter.

Contact

We offer you the opportunity to contact us via our email address given above. In this case, you automatically provide us with your email address and, if applicable, your name, a subject, and the content of the message. We process this data in each case in order to be able to answer your inquiry. This purpose also constitutes our legitimate interest in data processing (Art. 6(1)(f) GDPR).

We store your emails in any case for as long as is necessary for the direct processing of your inquiry and for a maximum period of 3 years if you contact us again with regard to your original question. This does not apply if you initiate a contractual relationship with us in the email. In this case, the storage period is based on the underlying contract. In that case, you will be informed separately about the data processing taking place there.

Recipients of data

Within our company, only those departments that are responsible for handling the requests have access to your data. We use external service providers where we cannot or cannot reasonably provide services ourselves. These external service providers are primarily providers of IT services, such as our hosting provider, email provider, or telecommunications provider.

Our email delivery service provider is based in the USA. However, the service provider is certified under the EU-US Privacy Shield, so an adequate level of data protection is ensured when processing your personal data.

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

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

Zendesk Chat uses cookies. The information generated by the cookies (see “Scope of data collection by Zendesk”) about the use of our website is stored. By using the live chat system, the user agrees to the processing of the data collected about them by Zendesk Chat in the manner described below and for the purpose stated above. Further details on the use of cookies can be found at https://support.zendesk.com/hc/en-us/articles/4408824378650-Zendesk-In-Product-Cookie-Policy.

Otherwise, we do not transfer your data to third countries unless this is expressly mentioned elsewhere in this privacy policy.

Cooperation with processors

We also commission the following companies as our cooperation partners:

  • Age Labs (Oslo, Norway) to perform the epigenetic examination and analysis of your blood samples. For this purpose, your pseudonymized data will be transmitted to Age Labs in Norway to fulfil this task. It will act only on our instructions. Age Labs has been contractually obliged within the meaning of Art. 28 GDPR to comply with data protection regulations. Age Labs may not use your data for any other purposes. In addition, Age Labs is obliged to handle this data in accordance with this privacy policy and the applicable data protection laws.
  • Biomes GmbH, Schwarzkopfstrasse 1, 15745 Wildau to carry out the Intest-Pro gut flora test
  • Laboratory of Hormonzentrum an der Oper, Maximilianstrasse 2, 80539 Munich for determining the bloodAge Index.
  • Datarella GmbH, Oskar-von-Miller-Ring 36, 80333 Munich, Germany, to optimize the compilation of the customer’s health data, including the customer’s wearable data, for the bioCoach program.
  • We commission our logistics partner Byrd GmbH (Ritterstrasse 12-14, 10969 Berlin) to ship our products. Byrd GmbH is considered the recipient of the data for the purpose of processing and shipping orders. For this purpose, the personal data provided by you will be transmitted to Byrd GmbH for the fulfilment of this task. It will act only on our instructions. Byrd GmbH has been contractually obliged within the meaning of Art. 28 GDPR to comply with data protection regulations. Byrd GmbH may not use your data for other purposes. In addition, Byrd GmbH is obliged to handle this personal data in accordance with this privacy policy and the applicable data protection laws.

 

Data subject rights

The General Data Protection Regulation guarantees you certain rights, which you may assert against us - insofar as the legal requirements are met. These are detailed below:

  • Art. 15 GDPR – Right of access by the data subject: You have the right to request confirmation from us as to whether personal data concerning you is being processed and, if so, which data and the circumstances of the data processing.
  • Art. 16 GDPR – Right to rectification: You have the right to demand that we correct inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you also have the right to request the completion of incomplete personal data – including by means of a supplementary statement.
  • Art. 17 GDPR – Right to erasure: You have the right to demand that personal data concerning you be erased without undue delay.
  • Art. 18 GDPR – Right to restriction of processing: You have the right to request that we restrict processing.
  • Art. 20 GDPR – Right to data portability: In the event of processing based on consent or 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 those data to another controller without hindrance from us or to have the data transmitted directly to the other controller, insofar as this is technically feasible.
  • Art. 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 with a supervisory authority at any time, in particular in the Member State of your residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes applicable law.

In particular, the following applies to the right to object and the right to withdraw consent:

Art. 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 that is necessary on the basis of a legitimate interest on our part or for the performance of a task carried out in the public interest, or that is carried out in the exercise of official authority.

If you object to us, 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 the processing serves the establishment, exercise or defense of legal claims.

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

Withdrawal of consent: If you have given us consent, you have the right to withdraw it at any time. Any data processing we have carried out up to your withdrawal remains lawful in this case. For this purpose, you can simply click the link contained in each email and unsubscribe from the email service or send a message to one of our email addresses. If you tell us in this message that you no longer wish to receive emails in the future, we will no longer send any messages to the email address you provided.

Changes to the privacy notices

As data protection law develops and technological or organizational changes occur, our privacy notices are regularly reviewed for the need for adjustments or additions. You will be informed of changes in particular on our German website at www.neotes.com. These privacy notices are current as of August 2024.

No obligation to provide data

You are under no contractual or statutory 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 that produces legal effects concerning you or similarly significantly affects you.

III. Internet-specific data processing / cookies

In order to expand the functionality of our internet offering and make it more convenient for you to use, we use so-called “cookies.” With the help of these “cookies,” data can be stored on your computer when you access our website. You have the option of preventing cookies from being stored on your computer by adjusting the appropriate settings in your browser. However, this will restrict the functionality of our offering.

When using the Website, cookies are stored on your computer. Cookies are small text files that are stored on your hard drive and assigned to the browser you use and through which certain information flows to the entity that sets the cookie (in this case us). Cookies cannot execute programs or transmit viruses to your computer. They are used to make the internet offering overall more user-friendly and effective.

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

Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. These store a so-called session ID, which allows various requests from your browser to be assigned to the joint session. This means your computer can be recognized when you return to the Website. The session cookies are deleted when you log out or close your browser.

Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can delete the cookies in your browser’s security settings at any time.

You can configure your browser settings according to your wishes and, for example, refuse the acceptance of third-party cookies or all cookies. However, we would like to point out that you may then not be able to use all functions of this Website. In your browser settings, you can specify that cookies require your consent each time before they are stored on your computer and become active. Detailed information regarding your browser settings can be found on the providers’ websites or in these instructions for the most common browsers.

Google Analytics

This Website uses Google Analytics, a web analysis service of 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 a Google server in the USA and stored there. If IP anonymization is activated on this Website, however, your IP address will first be shortened by Google within member states of the European Union or in other contracting states 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 USA and shortened there. On behalf of the operator of this Website, Google will use this information to evaluate your use of the Website, to compile reports on website activity and to provide other services relating to website and internet use 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 cookies from being stored by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this Website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the Website (including your IP address) and from processing this data by downloading and installing the browser plugin available under the following link www.tools.google.com/dlpage/gaoptout?hl=de .

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

Further information on terms of use and privacy can be found at www.google.com/analytics/terms/de.html or at www.google.de/intl/de/policies.

Facebook Custom Audiences

We use Custom Audiences of Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. This allows our advertising to be shown to you there in a targeted manner if you have a user account with Facebook. For this purpose, the Facebook Pixel establishes a direct connection between your page and Facebook’s servers and transmits your usage data of our Website to Facebook for analysis and marketing purposes. If you are a Facebook user, this data may be assigned to your Facebook account. Through tracking, your activities may therefore be followed by Facebook across multiple pages. Your data may be processed by Facebook Ireland Limited on the servers of Facebook Inc. in the USA. Since the service and the data processing carried out via this service are solely within Facebook’s responsibility, we have no influence whatsoever on any possible processing of personal data. Further information on the collection and use of data by Facebook can be found in Facebook’s privacy notices at www.facebook.com/policy.php.

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

The legal basis for the use of Custom Audiences is Art. 6(1)(f) GDPR. Our legitimate interest lies in displaying targeted advertising to you.

Use of the remarketing or “similar audiences” function of Google Inc.
We use on our Website the remarketing or “similar audiences” function of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). This function serves to analyse visitor behaviour and visitor interests.
To carry out the analysis of website usage, which forms the basis for creating interest-based advertisements, Google uses cookies. The cookies record visits to the Website as well as anonymized data about the use of the Website. No personal data of website visitors is stored. If you subsequently visit another website in the Google Display Network, advertisements will be shown that, with high probability, take into account previously visited product and information areas.
Your data may also be transmitted to the USA. For data transfers to the USA, there is an adequacy decision of the European Commission.

Processing is based on Art. 6(1)(f) GDPR from the legitimate interest of addressing website visitors with advertising in a targeted manner by displaying personalized, interest-based advertisements to visitors of the provider’s website when they visit other websites in the Google Display Network.

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

You can permanently disable the use of cookies by Google 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 parties by visiting the Network Advertising Initiative opt-out page at www.networkadvertising.org/choices and implementing the additional opt-out information provided there.
Further information on Google Remarketing and the associated privacy policy can be found at: www.google.com/privacy/ads-

Berlin, August 2024