Privacy Policy

VERSION 3.0

EFFECTIVE DATE: APRIL 8, 2026

This Privacy Policy (“Privacy Policy”) applies to all products, programs, testing services, websites, pages, features, content, research, collection, testing, and analysis of biological samples (collectively, the “Service”) provided by Allora Health, Inc. d/b/a Evvy (“Evvy,” “we,” or “us”).

Evvy takes your privacy very seriously. By accessing or using the Service (as defined above), customers allow us to collect, store, and use their Personal Information that enables us to provide more accurate and personalized recommendations. This Privacy Policy is designed to help you (“you”, “customer”, or “user”) better understand how we collect, use, store, process, and transfer your information when using our Service. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

For individuals using the Service from the United States, this Privacy Policy does not apply to information that is protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). At present, we do not collect PHI. Evvy is not a covered entity or business associate, meaning data in the Evvy system is not considered PHI and data within Evvy is not subject to HIPAA. If PHI were brought into the Evvy system, this document outlines how Evvy would comply with the HIPAA privacy rule. Additionally, if in the future we begin providing services to health care providers in the United States that are “covered entities” under HIPAA, certain information we collect on their behalf will be PHI and will be governed by, and will be used and disclosed solely as permitted under, the Notice of Privacy Practices of Wheel Medical, P.A. and its affiliated clinicians (“Wheel Provider Group”) as well as any business associate agreement between Wheel Provider Group [or Evvy Provider Group] and Evvy, as required by law, to safeguard PHI. For more information about the privacy of PHI, please contact your clinician or Wheel Provider Group.

Please review this Privacy Policy carefully. If you choose to provide your personal information to us, by subscribing to or using any of the Service or by voluntarily interacting with us, we assume that you consent to our collecting, using and disclosing your personal information as set out in this Privacy Policy, as revised from time to time. If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their information as described in this Privacy Policy.

If you wish to withdraw your consent to our collection, use or disclosure of the personal information you provide to us, please see Section 10 of this Privacy Policy below. In some cases, withdrawal of your consent may mean that we will no longer be able to provide you the Service.

Updates to this Privacy Policy

From time to time, we may make changes to this Privacy Policy. When changes are made to this Privacy Policy, they will become immediately effective when published in a revised Privacy Policy posted on our website unless otherwise noted. We may also communicate the changes to this Privacy Policy through the Service or by other means. The Privacy Policy was last revised as of the date that appears at the top of this page.

What’s in this Privacy Policy?

What Information We Collect
User Content
How we use your Information
How we disclose your Information
Evvy Research
Children’s Privacy
Information Security Measures
Retention of Personal Information
Correction of Personal Information
Account Closure
Nevada Residents
California Residents
Contact Us

1. What Information We Collect‍

When you use our Service, Evvy collects and uses the types of personal information about you that are described below (“Personal Information”). Personal Information does not include publicly available information, anonymized or aggregated information where there is no serios possibility that it can be used to re-identify you, information covered by certain federal, state or provincial laws, and, if you are using our Service from Canada, does not include any business contact information. Evvy collects the following type of Personal Information:

A) IDENTIFIERS

For example, we collect your name, date of birth, password, shipping address, and contact information such as email address and telephone number that you provided to create your Evvy account (“Evvy Account” or “Account”).

B) PAYMENT INFORMATION

For example, we collect your billing address and payment information provided to us by our third-party payment processors (Evvy stores only the last 4 digits and the expiration date).

C) HEALTH AND OTHER SENSITIVE INFORMATION

For example, we collect information from you about your personal traits (e.g., eye color, height), ethnicity, disease conditions (e.g. Type 2 Diabetes), physical health-related information (e.g., pulse rate, cholesterol levels, visual acuity, medicine you currently take, habits such as smoking), diet related information (e.g., vegetarian, vegan, allergies, etc.), mental health related information (e.g. emotional conditions such as fear or anxiety), and family history (e.g., information similar to the foregoing about your family members). This information also includes:

Sample Data. “Sample Data” is molecular data created from the samples you provide to Evvy for testing and analysis. Sample Data analysis includes, but is not limited to, microbiome analysis. The laboratory we contract with will use your samples for testing, analysis and generation of Sample Data that will be used to generate Test Data.

Test Data. “Test Data” is information we extract from Sample Data. Test Data is used with other Personal Information you provide to us in conjunction with our data analysis methods to provide you personalized recommendations.

D) OTHER INFORMATION YOU PROVIDE TO US

For example, you may provide us with information in response to surveys, forms, questionnaires, email, features on our website and software applications, while participating in Research Studies and Research Participations (as described in our Terms of Service), engaging with our customer service (“Customer Service”), through social media or digital media channels, or while using the Service.

E) INTERNET OR OTHER ELECTRONIC ACTIVITY INFORMATION

Like most websites and other internet services, we may collect certain technical and device information about your use of the Service. For example, we collect information on how you use the Evvy website (e.g. IP address, location, browser type, domains, page views, etc.) or other online media owned by Evvy, collected through log files, cookies, and web beacon technologies (described below).

Cookies and Other Tracking Technologies. Evvy and its third-party service providers from whom it receives your information may use “cookies” and similar tracking technologies (such as web beacons, tags, scripts and device identifiers used for automatic collection of information), for a variety of purposes. Cookies are small data files that are stored on a user’s hard drive at the request of a website to enable the website to recognize and retain certain user information such as customer preferences and history.

Cookies may store a variety of information and may help us recognize when and how you use our Service, customize and improve your experience, provide security, analyze our interactions with our Service and its features, gather demographic information about our user base, make special offers of our Service, monitor the success of marketing programs.

We may also collect personal information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our website, and across third-party websites or service offerings when you leave our website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests. For example, we use [Google Ads and Google’s DoubleClick] to provide you with advertising based on your browsing history and search requests. We also use [YouTube] to provide you with personalized advertising based on your viewing content. We do not use any health information provided by you when engaging in interest-based advertising unless you have provided express consent for us to do so.

When Evvy receives reports from third parties on how certain functionalities of our website works, usage and statistical information such as the user’s browser type, operating system, device ID (only for IOS users), these third parties may collect personal information from you in connection with the services they provide and may place cookies, web beacons or other devices on your device to collect non-personal information which may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage of the Service and the other services tracked by these third parties. Evvy is not responsible for, and does not control, any actions or policies of any third-party service providers.

The information reports we receive from third party service providers may contain Personal Information or may be de-identified or aggregated, and we may also use these reports to improve our data analytics methods. If we combine cookies with, or link them to, any of your Personal Information, Evvy will treat this information as Personal Information.

If you wish to block, erase, or be warned of cookies, please refer to your browser instructions or help screen to learn about these functions. However, if you reject cookies or your browser or device settings does not accept cookies, you may not be able to use certain parts of our website or sign in to your Evvy Account and may not be able to access certain Service features.

Do Not Track Signals. Since there is currently no standard for these signals, Evvy does not respond to Do Not Track ("DNT") signals at this time and we do not alter our data collection and usage practices when we detect such a signal from your browser.

Google Analytics. Like many websites, we use Google Analytics for web behavior monitoring, a service that provides information about how many users visit our website and online resources, when they visit, and how they navigate our website. We also may use other Google Analytics tools, such as Demographics and Interest Reporting, which enable us to learn more about the characteristics and interests of the users who visit our website, and Remarketing with Google Analytics, which enables us to provide relevant advertising on different websites and online services.

To learn more about Google’s privacy practices, please go to Google Privacy Policy at: https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at: https://tools.google.com/dlpage/gaoptout.

F) AGGREGATED AND ANONYMIZED INFORMATION

We will de-identify and anonymize certain data collected in connection with your use of the Service, which may be stored and used separately from the data and Personal Information referred to above.

2. User Content

‍Some features of our Service may include functionality enabling you to post user content, whether publicly posted or privately transmitted, such as profiles, posts, emails, feedback, experiences, suggestions, notes, messages, photos, and videos (“User Content”) that may be made available to Evvy and other users of the Service.

You represent and warrant that you own the User Content or have the necessary licenses, rights, consents and permissions to provide use with the User Content and that its provision to Evvy and Evvy's use of the User Content in accordance with this Privacy Policy will not violate the copyrights, privacy rights, publicity rights, trademark rights, contract rights, intellectual property rights or any other rights of any third party.

You should be aware that any User Content you provide or post in public media may be read, collected, and used by others who access them, and we have no control over these media. Please exercise caution before and when you choose to share personal information on our blogs, forums or in any other public media.

3. How We Use your Information

Evvy will use and share your Personal Information in the ways that are described below and elsewhere in the Privacy Policy.

A) PROVIDE YOU WITH THE SERVICES

We use your information in accordance with this Privacy Policy for activities necessary for provisioning the Service that include testing and analysis of data, generating and delivering Test Results and recommendations, and improving our Service. These activities may include, but are not limited to: i) open and maintain your Evvy Account; ii) enable purchase of our Service (e.g., process payments); iii) communicate with you (e.g., informing you of policy changes, security updates or issues, etc.); iv) implement your requests (e.g. requests to Customer Service); v) facilitate use of our website (including authenticating your visits, providing personalized content, and tracking your use of our Service); vi) maintain our legal rights, including enforce our Terms of Service and other agreements, perform quality control and monitor, detect, investigate and prevent prohibited or illegal activities, spam and other security risks; vii) if you opt-in to Evvy Research, to perform research studies and research & development activities; viii) conducting data analysis to improve existing Service or develop new Service; ix) improving our data analytics to help us provide more precise and accurately personalized recommendations; and x) providing chatbots and other tools powered by artificial intelligence and similar technologies..

We may also use your information to fix bugs or issues, analyze use of our website, to improve or optimize the customer experience and Customer Service, or assess the efficacy of our marketing campaigns.

B) IMPROVE OUR SERVICE, ANALYSIS METHODS, AND OTHER INTERNAL BUSINESS PURPOSES

We are constantly working on improving our Service and enhancing the capacity and accuracy of our data analysis methods and internal artificial intelligence engines we use for the purpose of delivering more accurate and personalized recommendations to you. We do not use or share your personal information with any third party artificial intelligence engines or models that would require release of your personal information into a public database without your express consent.

We may use your Personal Information for our internal business purposes to improve our Service and operations, to improve our website and online presence, and to facilitate accessibility for you and our other users.

C) PROVIDE CUSTOMER SERVICE AND SUPPORT

When you contact Evvy customer service (“Customer Service”), we may use or request additional Personal Information, as necessary to verify your identity, answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. This includes chatbots and other tools powered by artificial intelligence and similar technologies In certain instances, we may require using one customer’s Personal Information to resolve another customer’s request. For example, if a customer reports behavior of another customer that violates our Terms of Service, we will separately process both customers’ Personal Information and respond separately to each customer as appropriate. We will not share your Personal Information with another customer or any third party without your specific consent.

D) SURVEYS AND TESTIMONIALS

We value our customers’ feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Service. We may use your Personal Information to send you surveys, questionnaires, and requests for testimonials that we use to optimize our Service and perform quality control activities. You are in control of the information you would like to share with us.

E) MARKETING AND COMMUNICATIONS

When creating an Evvy Account and using our Service, you may agree to subscribe to receiving Service-related promotional emails with information such as new features, add-ons, promotions, contests and other notifications about our Service.

You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link or send a request to our Customer Service (hello@evvy.com) using the details provided above.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of the Service, such as technical notices, purchase confirmations, important Evvy policies and deadlines applicable to use of kits and sample returns, or other matters.

We may also use the Personal Information you submit to us to personalize your user experience and to allow us to recommend or deliver the type of content, new features, or Service offering in which you are most interested. We may also use your Personal Information to compile usage statistics and other data regarding use of our Service and for other types of marketing and communication purposes, without asking for and receiving your explicit consent (e.g., targeted advertising that uses third party advertising networks and providers who help us deliver targeted online advertisements or measure the effectiveness of ad campaigns). We and our third-party service providers will not use your Sensitive Information for marketing and communication purposes.

F) OTHER PURPOSES

We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable privacy laws.

4. How We Disclose Your Information

In general, Evvy will not disclose Personal Information to third parties, except as described below.

A) WITH EXPRESS WRITTEN PERMISSION

Evvy may disclose your Personal Information to third parties in accordance with our Terms of Service or where you have otherwise provided express written consent for sharing (e.g. if you consent to participate in Evvy Research).

B) FACILITATE BUSINESS OPERATIONS

Evvy may disclose Personal Information as stated in the Terms and this Privacy Policy to partners, vendors, or service providers (e.g., credit card processors, Sample collection services, electronic data processors, supplements and probiotics+prebiotics manufacturers, fulfillment and logistics service providers, customer service accelerators, accredited reference laboratories, genotype and microbiome testing labs, and healthcare providers), eCommerce store providers, and payment gateways that process and/or store such information in order to help Evvy provide, or improve the Service or any part of it. In these instances, the protection of your Personal Information will be subject to the service agreements or privacy policies of the specific Evvy partner or service provider. We require our service providers to agree to data security and confidentiality provisions regarding the use of our data, including your Personal Information.

C) AS REQUIRED BY LAW

Under certain circumstances, Personal Information may be subject to disclosures pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. You acknowledge and agree that Evvy is free to preserve and disclose any and all Personal Information to law enforcement agencies or others regulatory agencies that oversee manufacturing and logistics service, if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (i) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry); (ii) obligations that Evvy may owe pursuant to ethical, regulatory (such as Food and Drug Administration), and other professional rules, laws, and regulations; (iii) enforce Terms of Service; (iv) respond to claims that any content violates the rights of third parties; or (v) protect the rights, property, or personal safety of Evvy, its employees, its customers (including you), and the public. In the event Evvy is required by law to disclose Personal Information, Evvy will notify you through the contact information provided to Evvy in advance, unless doing so would violate the law or a court order.

D) SHARING WITH THIRD PARTIES

Unless required by law or a court order, or as specifically stated in the Terms and this Privacy Policy, Evvy will not release your Personal Information to any third party without first receiving your consent. Specifically, Evvy does not share your Personal Information with third parties, in the following ways, without your explicit consent: i) sell, lease, or rent them; ii) release to any public databases or any third-party artificial intelligence or machine learning models; and iii) with insurance companies, educational institutions, government agencies, or employers.

We may share your Personal Information, without explicit consent, to the extent necessary, with third parties: i) in order to perform business operations that help deliver the Service to you, such as our third-party service providers (e.g., Sample collection services, laboratory service, inventory controllers that ship Kits, supplements and probiotics + prebiotics manufacturers, logistics operators, IT service providers, customer service optimizers, etc.); ii) for marketing and communication purposes (where we have your consent to do so) and iii) if the third party is a clinical partner that (a) referred you to us, (b) you interacted with through the Service, or (c) you otherwise designate, we may share Personal Information and your results with that clinical partner.

E) TO YOUR AUTHORIZED REPRESENTATIVE

To the extent permissible under applicable laws, when a customer has lost capacity or passed away, we will only give their Account information to individuals who are legally authorized to make decisions on their behalf, such as an executor, a personal representative, or a beneficiary of a deceased's estate. The person requesting the information must complete an authorization form and provide evidence and legal documentation indicating they are allowed to act on behalf of the individual before we will provide any information.

F) BUSINESS TRANSITIONS

In the event Evvy goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. In such a case, Personal Information would remain subject to the terms of the pre-existing or the current Privacy Policy.

G) AGGREGATED INFORMATION

We may share aggregated or de-identified, non-customer specific data and information derived from Personal Information with other entities for the purpose of performing activities that may help us provide and improve our Service.

5. Evvy Research

“Evvy Research” is a research program operated by Evvy to make new discoveries about the microbiome that is overseen by an independent ethics review board. Evvy Research is an opt-in program, meaning that participation is entirely voluntary. Evvy Research may be sponsored by, conducted on behalf of, or in collaboration with third parties.

You are not required to participate in Evvy Research to make use of the Service.

6. Children’s Privacy

The Service is not directed, designed, or intended to attract individuals under the age of 18. In the event Evvy is notified or becomes aware that the Service has been used by an individual under the age of 18 to store information of that individual without parental consent, Evvy shall be and is authorized to delete, in its entirety, with no notice to you, any of the information stored by that individual or by you on that individual’s behalf. Evvy also reserves the right to revoke any license to use the Service, which is being used or has been used by a child under the age of 18.

7. Information Security Measures

Evvy uses a number of physical, technical, and administrative measures to keep your Personal Information safe and secure. By employing these safeguards, we aim to prevent unauthorized access, minimize accidental disclosure, maintain data accuracy and integrity, and ensure appropriate use of Personal Information in accordance with current technological and industry standards. However, please understand that no method of transmission over the Internet or method of storing data is 100% secure. Therefore, we cannot guarantee that our security measures will always be effective. A breach of security measures can result in such risks as phishing and identity theft. In such cases, we act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by applicable laws.

In addition, protecting Personal Information is a responsibility shared between you and Evvy. In this regard, we ask all users of our Service to be responsible for keeping their login IDs, passwords, and other authentication information used to access the Service in a secure manner and maintain strict confidentiality. You should not share Account and authentication information with any third parties and should inform Evvy immediately of any prohibited use of your Account or authentication information. Evvy cannot secure and assumes no liability for Personal Information that is released by our customers to third parties, such as physicians, insurance companies, or healthcare service providers.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “Contact Us” section below.

8. Retention of Personal Information, International Transfer and Storage

We will retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

By choosing to have Evvy extract the molecular level data from your Samples as part of the Service, you consent to have Evvy access, analyze, and store your Personal Information using the same or more advanced technologies, in a manner consistent with our Terms and this Privacy Policy. Unless we notify you otherwise, we will store your Samples and data from the Samples for at least ten (10) years, but may, in our sole discretion, to the extent permitted by law, retain such Samples and data for a longer period of time. All of the same safeguards applicable to Personal Information will be provided, to any further use of your Samples, as in our Terms of Service and this Privacy Policy.

We will keep the personal information that we collect at our offices and data centres in Canada and the United States. In addition, and unless prohibited by law, we may send Personal Information outside of Canada and the United States for our business purposes, including for process and storage by service providers. While your Personal Information is outside of Canada or the United States, it is subject to the laws of the country in which it is located -- which may have different data protection laws than Canada or the United States. Those laws may require disclosure of your Personal Information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information in the “Contact Us” section below.

9. Updating or Correction of Personal Information

We expect you, from time to time, to supply us with updates to your Personal Information, when required. We will not routinely update your Personal Information, unless such a process is necessary.

You may make a written request to review access any Personal Information about you that we hold, and we will provide you with any such Personal Information to the extent required by applicable laws.

You may also correct or challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is incorrect, inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose.

We will not charge any costs for you to access your Personal Information in our records without first providing you with an estimate of the approximate costs, if any. To make a correction to the Personal Information we have on file, You may update or make a request to correct the Personal Information we have on file using the information stated below:

‍Submit online: Send in a request on “Correcting Personal Information” using support@evvy.com

Submit by Mail: ‍

Evvy Customer Service (Correction of Personal Information)
169 Madison Ave
#2064
New York, NY 10016

10. Account Closure

If you no longer wish to use the Service, or have your Personal Information processed by us in order to provide you the Service, you may close your Account and have your Account information deleted by sending our Customer Service a request using the information specified below.

Submit online: Send in a request on “Account Closure” using support@evvy.com

Once we receive your request, we will send an email to the email address linked to your Account detailing our Account Closure Policy and requesting that you confirm your closure request. Once you confirm your request to close your Account and delete your Account information, your Account will no longer be accessible. When your request is processed, it cannot be cancelled, undone, withdrawn, or reversed.

When closing an Account, Evvy removes or deletes Personal Information associated with that Account, except that, to the extent necessary and permitted by law, Evvy may still retain Personal Information (i) for accounting, audit, and compliance purposes; (ii) for compliance with legal retention requirements; (iii) to fulfill contractual obligations, or exercise or defend legal claims; (iv) already used for Evvy Research, if you have opted-in.

11. Nevada Residents

Pursuant to Nevada Privacy Law (“NPL”), Nevada residents may direct a business that operates an internet website not to sell certain Personal Information about you. Evvy does not sell your Personal Information to third parties.

12. California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We do not share your Personal Information with third parties for their own direct marketing purposes.

13. Third-Party Websites and Service

We may provide links to third-party websites for your convenience and information. We may also make opportunities available to you to purchase, subscribe to, or use other products and online services from third parties with different privacy practices, and those other products and online services are governed by their respective privacy statements and policies. This Privacy Policy does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third-party privacy policies prior to using third-party websites, products or services.

14. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy, would like to request a current or previous version, or would like more information regarding our process for updating this Privacy Policy, you can contact us using the following options:

Contact us by email: support@evvy.com

Contact us by mail:

Evvy Customer Service (Correction of Personal Information)
169 Madison Ave
#2064
New York, NY 10016