Privacy Policy

Foxo Technology Pty Ltd

U.S. Privacy Policy

 

This Privacy Policy was last updated on October 29th 2024.

Foxo Technology Pty Ltd and its affiliates serve people residing in the United States. We have prepared this U.S. Privacy Policy (“Privacy Policy”) for our U.S. consumers, in addition to our General Privacy Policy, to inform Consumers of the rights they may have under applicable U.S. privacy laws. We will review and update this Notice at least annually.

 

Here at Foxo Technology Pty Ltd, we respect your privacy and information, and we thank you for coming to foxo.com (the “Website”) andusing the Foxo application (the “App”).

This Privacy Policy applies to U.S. users of our Website or App, and describes:

  • Information that we receive from you when you interact with the Website and App
  • How we use and process the information that we receive
  • If and why Personal Information may be disclosed to third parties
  • Your choices regarding the collection and processing of your Personal Information

This policy is not applicable to any information collected offline, through email or other electronic message, or through third party websites or services that you may access through the Website or App (“Third Party Services”).

Please read this Privacy Policy carefully. If you don’t agree with this Privacy Policy, do not use our Website or App. By accessing or using our Website or App, you agree that you have read this Privacy Policy and you understand, and consent to be bound by, the terms and conditions herein. If you have not done so already, please also review our Terms of Use. The Terms of Use contain provisions that limit our liability to you.

Changes to this privacy policy

We reserve the right to amend this privacy policy at any time. Whenever possible, we will provide you with advance written notice of our changes to this Privacy Policy. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of our Website or App after we make changes shall constitute your acceptance of those changes, so please check this Privacy Policy periodically for updates. The amended Privacy Policy supersedes all previous versions.

Information we collect about you

We receive and collect information that you directly submit to us or that we gather when you use our Website or App, including personal information such as your name, mailing address, telephone number, email address, photo identification, health data, and payment information, as well as non-personal information such as IP addresses, information that is passively or automatically collected through cookies, your browser or device, or other services, and information from third parties. We also collect information on your physical location, which may be provided by you or collected through the use of our Website, App, or other communication channels. In this Privacy Policy, we refer to all of the above as “Personal Information.” Organizations using Foxo's Patient or Referrer Connect modules may ask for further personal information to help identify you.

Cookies

A cookie is a small piece of data sent from a website and stored on your computer by your web browser. Cookies contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Services. Cookies are not themselves personally identifiable, but may be linked to Personal Information. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.

The file is added once you agree to store cookies on your computer or device, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow sites to respond to you as an individual. The Website and App can also tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences. We use other cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “data collection tools,” to help improve your experience with the Website and App. For example, data collection tools help us remember users and make the Website or App content or interface more relevant to them.

Specifically, the Website and App may use cookies to:

  • Analyze our Website and App traffic using an analytics package;
  • Identify if you are signed in to the Website or App;
  • Test content on the Website and App;
  • Store information about your preferences;
  • Recognize when you return to the Website or App.

Overall, cookies help us provide you with a better Website and App experience, by enabling us to monitor which pages you find useful and which you do not.

You can accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies if you prefer. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers (including some mobile web browsers) provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Website and App.

How we use your Personal Information

‍Foxo processes your Personal Information for legitimate business purposes, the fulfillment of our services to you, compliance with our legal obligations, and/or your consent. We use Personal Information to:

  • confirm your identity
  • send you notifications on missed activity
  • enable your access to the Foxo platform
  • provide you with information, products, or services you request;
  • fulfill the reason for which you shared such information;
  • communicate with you about and manage your account;
  • properly store and track your data within our system;
  • determine your eligibility for the services;
  • respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders;
  • protect our rights, privacy, safety, or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit our damages;
  • manage and improve our operations, the Website, and App, including the development of additional functionality;
  • manage identities, payment processing, and other transactions;
  • evaluate the quality of service you receive, identify usage trends, conduct research, and improve your experience;
  • keep our Website and App safe and secure;
  • send you information about changes to our terms, conditions, and policies; carry out our obligations and enforce our rights arising from any contracts entered into between users and us, including for collection of payments; provide you with email alerts, event registrations, promotions, and other notices concerning our products or services, or events or news, that may be of interest to you;
  • testing, research, analysis, and product development.

We may use your Personal Information to contact you with offers, promotions, and other marketing communications. We may also use cookies to provide relevant advertising or other communications or services.‍ You may opt out of receiving these messages at any time by following the unsubscribe link within the applicable message or by contacting us at privacy@foxo.com.

This Website and App use the following analytics program(s) to collect information about you and your behaviors: Facebook and Google Analytics.

To learn how to opt out, please visit the website(s) of the analytics program(s) used.

Disclosure of your Personal Information

We do not sell, share, or otherwise disclose your Personal Information for reasons other than those described in this Privacy Policy.

We may disclose your Personal Information to certain third parties, including:

  • your healthcare or other licensed medical providers;
  • our parent company, subsidiaries, and affiliates;
  • our third-party service providers, contractors, subcontractors, and business associates we use to support our business;
  • to any company we might merge with or acquire, or that acquires us, or in the event of structural change of our company of any form (e.g., a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding).

We may also disclose, without restriction, aggregated information about our users and information that does not identify any individual user. Our continued use of aggregated and de-identified data will comport with applicable law.

Accessing and changing your Personal Information

You can access, review, and update or change your account information through our Website or App. If you have any questions about how to access other Personal Information, or if you would like to correct or delete any Personal Information we collect and maintain, please contact us at privacy@foxo.com. We will accommodate requests as required by law. Otherwise, we will retain a record of your request, and your Personal Information will be maintained in accordance with this Privacy Policy and our data retention and deletion policies (“Retention Policies”).

How we keep your Personal Information secure

We retain information as long as it is necessary and relevant for our operations. We also retain Personal Information from closed accounts to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use, collect any fees owed, and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data Retention Policies.

We strive to use industry-standard data collection, storage, and processing practices and security measures to protect against any unauthorized access to, accidental loss of, or disclosure of your information. These safeguards may vary based on the sensitivity of the information that we collect and store.

Unfortunately, no security method or combination of methods is fool proof. We will always strive to do our best and to work with third-party service providers that strive to do the same, but we cannot warrant or guarantee the absolute security of any Personal Information that may be transmitted to or from our Website or App. There is no guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Therefore, any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or App, or your computer or mobile device.

We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of our Website or App. In order to protect you and your data, we may suspend your use of any of the Website or App, without notice, pending an investigation, if any breach of security is suspected.

Please note that we will never send you an email requesting confidential information, such as account numbers, usernames, passwords, or Social Security Numbers.

In the event of a data or security breach, we will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within our control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to us in connection with such security incident; (iii) as applicable, cooperate with any affected user or client in accordance with the terms of our contract with such user or client; and (iv) document and record actions taken by us in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations taken to prevent similar security incidents in the future. We will notify you of any data or security breaches as required by and in accordance with applicable law.

Account Deletion

If at any point you no longer agree to the use and disclosure of personal information, as described in these U.S. Privacy Terms, you can delete your User Account (“User Account”) by sending a deletion request to privacy@foxo.com with the following information:

  • Your name;
  • Your organization;
  • Your login email address; and
  • A statement that you are requesting account deletion.

Links to other sites

Our Website and App may contain links to third-party websites, services, applications, or other resources not operated by us. A link to any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. Any information you provide to these parties is not subject to the terms of this Privacy Policy. Please consult the privacy policies on these sites before you provide them with any of your personal information.‍

Do Not Track Disclosure

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT, and users cannot know how a given company responds to a DNT signal they receive from browsers. Foxo is committed to remaining apprised of DNT standards. However, Foxo does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Foxo to respond to signals or other mechanisms regarding the collection of your personal information.

Children under the age of 18

This Website and App are not for persons under the age of 18 (collectively, “Minors”). Minors are not authorized to use this Website or the App, or to provide any information through the Website or App. We do not solicit or knowingly collect information from Minors, and if we become aware of any such information being collected, we will take immediate action to delete it. Should you become aware that we have collected Personal Information from a Minor, please contact us at privacy@foxo.com.

Opt-out and unsubscribe

We may send communications, including emails, to you regarding your account, the Website, or the App. You can choose to filter any account, Website, or App update emails within your email settings, but we do not provide an option for you to opt out of these communications.

If you’d like to opt out of receiving offers, promotions, and other marketing communications, you may do so by emailing privacy@foxo.com.

Contacting us

If you’d like to receive additional information about our privacy practices, have questions, or would like to make a request, you may contact us at the below addresses.

privacy@foxo.com

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. Please see the CCPA Attachment for an explanation of your rights.

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:

Foxo Technology Pty Ltd
Mosaic Offices
Level 3. 826 Ann St.
Fortitude Valley. 4006