Privacy policy

Privacy policy

neotes GmbH (hereinafter referred to as “we”) operates the Internet pages accessible at www.neotes.com and the associated subdomains and subdirectories (hereinafter the “Website”).

With this privacy policy, we would like to inform you about what data we process and in what form when you visit our website. At the same time, we are fulfilling our duty to inform you in accordance with Art. 13 of the General Data Protection Regulation (GDPR).

Controller
The controller responsible under data protection law for the data processing that takes place on our website is

neotes GmbH
Immanuelkirchstrasse 14
10405 Berlin
Germany
cs@neotes.care

Within this, the following are appointed as data protection officers Roman Kacer

Purposes and legal basis of data processing and storage duration

General use of the website

Our host’s web server automatically records access to our website. This means that when you visit our site, data is automatically transmitted to us. This data consists of

• Your IP address
• Content that was accessed
• Information about the data transfers
• Date and time of retrieval
• The amount of data transmitted
• Your provider
• The referrer and
• The web browser/user agent you are using

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

Opening a user account

If you wish to create a user account, you must register. We process the following data to enable you to register via the website and create a user account for you:

• E-mail address
• password

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

Purchasing 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 the 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 para. 1 lit. f GDPR) within the EEA and concerns our customers. Byrd GmbH will only act on our instructions and has been contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR.

If you would like to purchase one of our products, we give you the option of buying the item as a guest. For this we need the following data:

• E-mail address
• First name
• Surname
• Street and house number
• Address suffix/company/C/O
• Zip code
• City
• Country

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

This data is used to receive, process and fulfill your order. The legal basis for this is Art. 6 para. 1 lit. b) GDPR.

If you subscribe to our newsletter when you place your order, we will use your e-mail address after your purchase to send you advertising about 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 analyze usage data in these newsletters, such as links clicked on, pages opened, etc. You can object to this use at any time. You can find more information on this below in the explanations on your right to object. The legal basis for this is Art. 6 para. 1 lit. f) GDPR. Our legitimate interest is to send you advertising and to 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 will be shared with our partner Agelabs AS, Gaustadalleen 23A, 0373 Oslo, Norway, in pseudonymized form. You can revoke your consent at any time for the future.

We would like to point out that we may process the analysis results for scientific research purposes by removing all identifying and attribution features. It is therefore no longer possible for us to assign the data to your person.

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

bb) HS-Omega 3® Index, Intest-Pro® intestinal flora test and NAD Test®

If you have one of the following tests

• HS-Omega-3 Index of Omegametrix® GmbH, Am Klopferspitz 19, 82152 Martinsried, Germany,
• Intestinal flora test Intest-Pro from Biomes GmbH, Schwarzkopfstrasse 1, 15745 Wildau
• NAD Level Test from 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 above-mentioned partner company will then provide you with the results via the address provided during registration. The above-mentioned tests are carried out under the conditions of the respective provider and under their sole responsibility.

cc) bloodAge test

When ordering the blood age test, you select a referring doctor in your area on the website, with whom you then arrange an individual appointment for a blood sample to be taken. The referring doctor will send the blood sample to the laboratory at the Hormonzentrum an der Oper, Maximilianstrasse 2, 80539 Munich for analysis.

By purchasing the bloodAge test, you agree that the results of the test will be forwarded to the referring physician of your choice for your medical consultation included in the product. This includes, in particular, information on the results of investigations, but also any random findings obtained during the evaluation.

dd) bioCoach program

By purchasing the BioCoach program, which paves the way to an individual longevity lifestyle through a holistic approach consisting of the improvement of medical parameters, the substitution of the body’s own vital substances and further measures to reduce stress and lower biological age, you agree that, depending on the selected subscription and its individual components, the data will be shared with various partners. The details can be found in the following subsections:

“Basis M6” and “Basis M12” subscription

• BioAge-Test Premium: Agelabs AS, Oslo (see under aa)), recurring test after every 6 months
• Intestinal flora test biomes GmbH, Wildau (see bb)), recurring test after 6 months
• Recurring longevity consultation after BioAge and intestinal 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 test after every 12 months
• Intestinal flora test biomes GmbH, Wildau (see under bb)), recurring test after every 12 months
• Recurring longevity consultation after BioAge and intestinal flora tests (see under aa)
• 5 micronutrients per month: Byrd GmbH, Berlin (see under a))
• Longevity-bloodAge-Test: Hormonzentrum an der Oper, Munich (see cc)), repeated after 12 months
• Recurring longevity advice according to the longevity-bloodAge test (see cc)

By purchasing the bioCoach program, you agree that your health data, including the data from your wearables and all other findings relevant to the consultation, will be transmitted to neotes’ IT partner, Datarella GmbH, Oskar-von-Miller-Ring 36, 80333 Munich, Germany, for optimized compilation. You can find more detailed information on this in § 12 of the GTC.

We would like to point out once again that we process the analysis results for scientific research purposes by removing all identifying and attribution features. It is therefore no longer possible for us to assign the data to you personally.

This is done on the basis of Art. 6 para. 1 lit. f) GDPR in conjunction with Art. 9 para. 4 GDPR. Art. 9 para. 4 GDPR in conjunction with. § Section 27 (1) BDSG against the background of our legitimate scientific interests in the aforementioned research.

neotes membership

By booking a membership, you consent to the data being shared with partners for the purpose stated in each case, depending on the subscription selected:

Starter membership

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

Professional membership

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

Expert membership

• in the 1st month: performance of the bioAge-Test Premium incl. longevity consultation: Agelabs AS, Oslo (see under aa))
• in the 2nd to 13th month: receipt of up to three micronutrients corresponding to the individual needs of the customer: Byrd GmbH, Berlin (see under a))
• in the 14th month: 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 store

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

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 for payment processing, we will send the email address you provided during the ordering process to complete your order. The subsequent payment process takes place exclusively via PayPal, without us having any further influence over it. PayPal will inform you separately about the collection, processing, and storage of your data there. You can find PayPal’s privacy policy at www.paypal.com/de/webapps/mpp/ua/privacy-full. The 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 select payment through one of these payment service providers, the payment data you enter will be transmitted to the respective service provider. The transmission of your data is based on Art. 6 para. 1 lit. b) GDPR. All data required for payment processing will be used exclusively for the execution of payments and transmitted via the “SSL” procedure.

Newsletter

When you register for the newsletter, your email address and first name will be stored with your consent and used exclusively for our own advertising purposes until you unsubscribe from the newsletter. The processing required for this is based on your informed consent (Art. 6 para. 1 lit. a) GDPR). We store your data until you withdraw your consent.

We use the so-called double opt-in procedure for this, i.e. we will only send you our e-mail newsletter if you have expressly given us your consent to do so. We will send you a confirmation e-mail in which we ask you to give your consent by clicking on the link contained in the e-mail. You can unsubscribe from the newsletter at any time without incurring any costs other than the transmission costs according to the basic rates. All you need to do is send a message in text form to the contact details given in section 13 (e.g. e-mail, letter). You will of course also find an unsubscribe link in every newsletter.

Contact us

We offer you the option of contacting us via our e-mail address above. In this case, you automatically provide us with your e-mail address and, if applicable, your name, a subject and the content of the message. We process this data in order to be able to answer your request. This purpose also constitutes our legitimate interest in data processing (Art. 6 para. 1 lit. f) GDPR).

We store your e-mails for as long as is necessary for the immediate processing of your request and for a maximum period of 3 years if you contact us again with reference 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 depends on the underlying contract. In this case, you will be informed separately about the data processing that takes place there.

Recipient of the data

Within our company, those departments have access to your data that are responsible for processing your request. We use external service providers if we cannot or cannot reasonably perform services ourselves. These external service providers are primarily providers of IT services, such as our hoster, email provider or telecommunications provider.

Our email service provider is based in the USA. However, the service provider is certified under the EU-US Privacy Shield, which ensures an adequate level of data protection 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, which is used to process and document messages and data received via live chat.

Zendesk Chat is used to enable direct, real-time communication with visitors to the neotes GmbH website. When a page containing a Zendesk Chat component is accessed, the user’s IP address is recorded and transmitted anonymously.

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 aforementioned purpose. 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 expressly mentioned elsewhere in this privacy policy.

Cooperation with processors

We also commission the following companies as our cooperation partners:

• Age Labs (Oslo, Norway) with the epigenetic testing and analysis of your blood samples. For this purpose, your pseudomized data will be transmitted to Age Labs in Norway to perform this task. This company will only act on our instructions. Age Labs has been contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR. Age Labs may not use your data for other purposes. In addition, Age Labs is obliged to treat this data in accordance with this privacy policy and the relevant data protection laws.
• Biomes GmbH, Schwarzkopfstrasse 1, 15745 Wildau with the performance of the Intest-Pro intestinal flora test.
• Laboratory of the Hormonzentrum an der Oper, Maximilianstrasse 2, 80539 Munich with the determination of 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 wearables for the bioCoach program.
• We commission our logistics partner Byrd GmbH (Ritterstrasse 12-14, 10969 Berlin) to ship our products. Byrd GmbH is 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 to fulfill this task. It will only act in accordance with our instructions. Byrd GmbH has been contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR. Byrd GmbH may not use your data for other purposes. In addition, Byrd GmbH is obliged to treat this personal data in accordance with this privacy policy and the relevant data protection laws.

Rights of data subjects

The General Data Protection Regulation guarantees you certain rights that you can assert against us, provided the legal requirements are met. In detail:

• Art. 15 GDPR – Right of information of the data subject: You have the right to request confirmation from us as to whether personal data concerning you are being processed and, if so, which data these are, as well as the specific circumstances of the data processing.
• Art. 16 GDPR – Right to rectification: You have the right to request that we immediately rectify any inaccurate personal data concerning you. Taking into account the purposes of the processing, you also have the right to request that incomplete personal data be completed, including by means of a supplementary statement.
• Art. 17 GDPR – Right to erasure: You have the right to request that we immediately erase personal data concerning you.
• 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 case of processing based on consent or for the fulfilment of a contract, you have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and to transmit this data to another controller without hindrance from us or to have the data transmitted directly to the other controller, where 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, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you violates applicable law.

The following applies in particular to the right to object and the right to withdraw consent:

Art. 21 GDPR – Right of objection: You have the right to object at any time to the processing of personal data concerning you which is necessary on the basis of a legitimate interest on our part or to safeguard a task in the public interest or which is carried out in the exercise of official authority, for reasons arising from your particular situation.

If you declare an objection 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 for the establishment, exercise or defense of legal claims.

If we process your personal data for direct marketing purposes, you have the right to object to this 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 your consent, you have the right to withdraw your consent at any time. In this case, all data processing that we have carried out up to your revocation remains lawful. To do this, you can simply click on the link contained in each e-mail and unsubscribe from the e-mail service or send a message to one of our e-mail addresses. If you inform us in this message that you do not wish to receive e-mails in future, we will no longer send any messages to the e-mail address you have provided.

Changes to the data protection information

As part of the ongoing development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes, in particular on our German website at www.neotes.com. This data protection notice is valid as of August 2024.

No obligation to provide data

You have no contractual or legal obligation to provide us with personal data. However, without the data you provide, we will not be able 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 adversely affects you.

III. Internet-specific data processing / cookies

We use so-called “cookies” to extend the functionality of our website and to make it more convenient for you to use. With the help of these “cookies”, data can be stored on your computer when you visit our website. You have the option of preventing the storage of cookies on your computer by making the appropriate settings in your browser. However, this will limit the functionality of our website.

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

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

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

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

You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out that you may then not be able to use all the 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 about your browser settings can be found on the websites of the providers or in these instructions for the most popular 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 usually transmitted to a Google server in the USA and stored there. However, if IP anonymization is activated on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of 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 truncated there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

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. 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 Google 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 Art. 6 para. 1 lit. f) GDPR. Our legitimate interest lies in evaluating the use of our website. The data is stored for 38 months.

Further information on terms of use and data protection 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 from Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. If you have a Facebook user account, our advertising can be displayed to you there. For this purpose, the Facebook Pixel establishes a direct connection between your page and the Facebook servers, and your website usage data is transmitted to Facebook for analysis and marketing purposes. If you are a Facebook user, this data can be associated with your Facebook account. Through tracking, Facebook may track your activities across multiple pages. Your data may be processed by Facebook Ireland Limited on Facebook Inc. servers in the USA. Since the service and data processing carried out via this service are solely the responsibility of Facebook, 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 policy 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 para. 1 lit. f) GDPR. Our legitimate interest lies in showing you target group-oriented advertising.

Use of the remarketing or “similar target groups” function of Google Inc.
We use the remarketing or “similar target groups” function of Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”) on our website. This function serves the purpose of analyzing visitor behavior and visitor interests.
Google uses cookies to carry out the analysis of website usage, which forms the basis for the creation of interest-based advertisements. Cookies are used to record visits to the website and anonymized data on the use of the website. No personal data of visitors to the website is stored. If you subsequently visit another website in the Google Display Network, you will be shown advertisements that are highly likely to take into account previously accessed product and information areas.
Your data may also be transferred to the USA. The European Commission has issued an adequacy decision for data transfers to the USA.

Processing is carried out on the basis of Art. 6 (1) lit. f GDPR for the legitimate interest of targeting visitors to the website with advertising by displaying personalized, interest-based ads to visitors to the provider’s website when they visit other websites in the Google Display Network.

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

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 parties by visiting the Network Advertising Initiative’s 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