Throne, Inc. (“Throne,” “we,” or “us”) wants you to be familiar with how we collect, use, and disclose personal information. This Privacy Policy describes our practices in connection with personal information that we collect through:

• Websites operated by us from which you are accessing this Privacy Policy; 
• Software applications made available by us for use on or through computers and mobile devices; 
• Your Throne device and its sensors; 
• Our social media pages and apps; and
• Email messages that we send to you that link to this Privacy Policy or other communications with you.

Collectively, we refer to the websites, apps, Throne device, social media pages, and emails as the “Services.”

Privacy Overview

Through the Throne device, we collect audio and visual data from your toilet and its contents, and use and analyze such data, with the help of artificial intelligence (AI), to provide you with insights about your health. In addition to the details in this Privacy Policy, here are some key privacy points:

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• We do not sell your health information. Our business model is to provide products and services you choose to use, not to make money by selling your data.
• A Throne device is active only for known Throne members through Bluetooth pairing or personal button press. 
• We take measures to avoid collecting images of human anatomy. Throne’s optical sensor faces downward into the bowl. Additionally, we employ privacy filters to reduce risk of capturing images of human anatomy.
• We implement safeguards designed to secure audio and visual data. For example, we transmit raw audio and visual data to our cloud for analysis using encryption.
• De-identified data helps improve Throne. We may de-identify your data and your insights by removing your name and other similar direct identifiers  from such information, and use that information to develop and improve our products, including the AI that powers our Services.
• Third-party research studies are opt-in. From time to time, we may invite you to share your health information with third-party research organizations with which we partner. Participation in these studies is voluntary, and your decision will not affect your access to our Services.

COLLECTION OF PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. We collect Personal Information through, or in connection with, the Services, including:

Personal Information from your Throne device:

Audio and Visual Information

Your Throne device includes acoustic and optic sensors that detect and record audio of your urinary flow, and captures video of the contents of your toilet, along with other bathroom biosignals. 

Note: The Services are not intended or designed to collect images of human anatomy. We have implemented controls designed to limit their collection, but there is always a possibility that such images could be inadvertently collected. 

Health Information and Insights

We use and analyze the audio and visual data that we obtain from your Throne device to develop insights and provide you information about your gut and digestive patterns, stool consistency, hydration levels, and urinary health. Note: Our insights are wellness-focused and not designed for diagnosing or treating medical conditions. 

Please see our Consumer Health Data Privacy Statement for more information.

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Other Personal Information we receive from you:

Account Information

Such as the username and password you use to access the Services.

Identifiers

Such as first and last name, prefix, email address, telephone number, and postal address.

User Content

Such as reviews about our Services and other content that you may create or share with us during our relationship, including posts on our social media and comment sections.

Preferences 

Such as language, interests, and other feedback/preferences that you might express during your use of our Services.

Marketing Data

Such as your choices regarding our newsletters, surveys, and other marketing/advertising displayed or provided to you, and preferred methods of such promotional communication.

Photos and Videos

Such as photos and videos submitted by you while using our Services, including from your mobile device depending on the device permissions that you provide. 

Health Information

Such as data related to a health condition and other health-related information that can be used to make inferences about your gut, hydration, or urinary health, which we may collect from you and from health and fitness devices or apps you choose to connect (in addition to the information that we collect from the Throne device as described above). Please see our Consumer Health Data Privacy Statement for more information.

Commercial, Payment, and Transaction Information

Such as details of your communications with us, details of your claims, complaints, queries in general, transaction information, and purchase history, including purchases considered, credit or debit card, which includes details like the cardholder’s name, primary account number, and expiration date.

Other Information

Other information you choose to provide to us, including in connection with our journaling feature.

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Other Personal Information collected automatically through your use of our Services: 

Online Activity Data

Pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

This includes data obtained through cookies and similar technologies, as described below.

Mobile/Computer Device Information

Your device’s operating system type and version, manufacturer and model, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), advertising ID, and general location information.

This includes data obtained through cookies and similar technologies, as described below.

Location & Bluetooth

To enable hands-free connection with your Throne device, our app uses Bluetooth Low Energy (BLE) and related operating-system frameworks. BLE scanning can require the Location permission (including “Allow all the time”) so the system allows background scans. We access only approximate device location signals as needed to perform BLE scans. We do not collect, store, or transmit precise GPS coordinates. Bluetooth beacons from nearby Throne devices and phones are processed on-device to derive a simple proximity event (e.g., “near your Throne”). We do not use your precise device location for advertising or analytics. If an event is recorded, we store a timestamp of the connection, not your location. You can disable Bluetooth or revoke the app’s permission in your device settings, but certain features may not function.

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We may collect information automatically through the following technologies:

Cookies

Cookies are pieces of information stored directly on the device that you are using that allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We, our advertising partners, and our service providers may use the information for security purposes, to facilitate navigation, display information more effectively, engage in targeted advertising, conduct analytics, and personalize your experience.

We do not currently respond to browser do-not-track signals. 

You can read more information about cookies at http://www.allaboutcookies.org/manage-cookies/index.html. 

Local Storage Technologies

These technologies provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

Pixel Tags

Also known as web beacons and clear GIFs, pixel tags may be used to, among other things, track the actions of users of the Services (including email recipients), conduct targeted advertising, measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

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Other sources from which we collect Personal Information: 

Social Media 

Such as profile pictures, social media account ID, and other public social media profile information, including lists of friends/followers on social media. 

Third-Party Logins 

When you link, connect, or login to our Services with a third-party service (e.g., Google or Facebook), you direct the service to send us information as controlled by that service or as authorized by you via your privacy settings on that service.

Other Third Parties

We may collect information from sources such as publicly available databases, marketing partners, third-party providers, network partners, and data brokers.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

Processing Purpose and Examples of Related Activities

Administering the Services: Providing the Services’ functionality to you, such as arranging access to your registered account; analyzing and providing insights regarding your gut health (including digestive patterns and hydration levels); verifying your information; responding to your inquiries and fulfilling your requests, such as when you contact us via one of our online contact forms or otherwise (e.g., when you send us questions or comments, or when you request other information about our Services); to send you administrative information, such as information regarding the Services and changes to our terms, conditions, and policies; and/or to allow you to send Services-related content to another person through the Services if you choose to do so.

Hands-free device recognition and secure pairing: To detect when you are near your Throne device, recognize your paired mobile device, and connect your mobile device to your Throne device securely using Bluetooth.

Operations and general business: Administering our Services (including troubleshooting and diagnostic testing, conducting performance analyses of our systems and Services, testing new system features to evaluate their impact, system and log maintenance, technical support, system debugging, and hosting data); and facilitating mergers, acquisitions, and other reorganizations and restructurings of our business (including prospective transactions).

Marketing: Sending you newsletters, event invitations, and mailings that we think may be of interest to you; fulfilling your event registration requests; and providing services, including providing events. We may also send you marketing communications by SMS, email, and telephone, subject to any consent requirements under applicable law.

Targeted advertising: Engaging advertising partners, including third-party advertising companies and social media companies, to display ads to you on other websites and online services. These companies may use cookies and similar technologies to collect information about your interaction over time across the Services, our communications, and other online services, and use that information to serve online ads that they think will interest you. We may also share information about our users with these companies to facilitate interest-based advertising to our or similar users (known as a “lookalike audience”) on other online platforms. Please note that we do not use or disclose your health information for the purposes of targeted advertising.

Personalizing our Services: Personalizing our interactions with you and providing you with information and/or offers tailored to your interests, such as delivering content via our Services that we believe will be relevant and interesting to you.

Improving and developing Services that we may provide to you: Conducting data analysis, for example, monitoring and analyzing Services use and using data analytics to improve the efficiency of our Services; developing new Services; considering ways to enhance, improve, repair, maintain, or modify our Services; identifying usage trends, for example, understanding which parts of our Services are most interesting to users; determining the effectiveness of our promotional campaigns, so we can adapt our campaigns to the needs and interests of our users; and operating and expanding our business activities.

Relationship building and engagement: Facilitating and responding to any social sharing and posts on our Services and other customer relationship building activities.

Aggregation and/or anonymization: Aggregating and/or anonymizing Personal Information so that it will no longer be considered Personal Information.

Security and fraud prevention: Conducting audits, verifying that our internal processes function as intended and are compliant with legal, regulatory, or contractual requirements; monitoring for and preventing fraud; and for security purposes, including maintaining system security and on-site security of our premises.

Legal and compliance: Fulfilling our legal and compliance-related obligations, including complying with applicable laws; complying with legal processes; responding to requests from public and government authorities; meeting national security or law enforcement requirements, compliance with requirements set by industry-specific supervisory bodies. Enforcing our terms and conditions and standards; protecting our operations; protecting the rights, privacy, or property of Throne; responding to auditors; and allowing us to pursue available legal remedies and make insurance claims, defend claims, and limit the damages that we may sustain.

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Disclosure of Personal Information

We disclose Personal Information:

Recipients

Examples and/or Purposes

Third-party service providers

Including service providers that provide website hosting, IT and related infrastructure, email delivery, analytics, and other services for the following purposes: 

• Administering the Services
• Improving the Services
• Operations and general business
• Security and fraud prevention
• Marketing
• Personalizing our Services
• Aggregating and/or anonymizing Personal Information
• Relationship building and engagement
• Conferences, visits, and other events
• Legal and compliance

Advertising networks

• Improving the Services
• Marketing and targeted advertising
• Personalizing our Services
• Relationship building and engagement

We do not share health information with advertising networks.

Business partners

• Event co-sponsors
• Third parties in connection with licensing, joint development, or similar arrangements 

Law enforcement, public, regulatory, and government authorities, courts, tribunals, or third parties where necessary to comply with applicable law and regulations

• Emergency and incident response
• Security and fraud prevention
• Legal and compliance
• Responding to a request or providing information to public and government authorities
• Responding to law enforcement requests and orders or providing information to law enforcement
• For dispute resolution purposes
• To enforce our terms and conditions
• To protect our rights, privacy, safety, property, and/or that of our affiliates, you or others

Professional advisors, such as accountants, actuaries, auditors, experts, consultants, lawyers, banks, and financial institutions

• Security and fraud prevention
• Legal and compliance
• Improving the Services

Research organizations

With your consent, we may disclose your Personal Information, including health information, with third-party health research organizations.

Third parties, such as an acquiring entity and its advisors, in connection with a sale or business transaction

We may disclose or transfer your Personal Information in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

At your direction

You may also choose or direct us to share your Throne videos and insights, and other Personal Information, with third parties and other individuals through the Services.

Further, you may elect to disclose Personal Information on the Services, including our message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our social media), or through which you are able to send messages through the Services. Please note that any information you post or disclose in this context may be available to other users and the general public. 

MARKETING CHOICES

You have choices regarding marketing-related communications. If you no longer want to receive marketing-related communications from us on a going-forward basis, you may opt-out by following the unsubscribe instructions in any such message. 

We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing from us, we may still send you important administrative messages, from which you cannot opt out.

ACCOUNT DELETION

You can delete your Throne account at any time by contacting support@thronescience.com – please use subject “DELETE MY ACCOUNT”. We will delete your data or otherwise render your data inaccessible to Throne personnel and others, except for any information that we are required to retain under applicable laws.

SECURITY

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. 

Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the CONTACT US section below.

ARTIFICIAL INTELLIGENCE

We leverage first- and third-party AI technologies to analyze the information that we obtain from your Throne device in order to provide you with insights regarding your health. We may de-identify your information and these insights by removing your name from such information, and use such de-identified information to develop and improve our AI technologies.

THIRD-PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. 

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our apps or our social media pages.

THIRD-PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to make payments using third-party payment services with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of eighteenthirteen (183). If we learn that we have collected Personal Information through our Services from a child under 18, we will delete it.We collect Personal Information online from children under age thirteen only with the consent of the child’s parent or guardian.

JURISDICTION AND CROSS-BORDER TRANSFER

We are located in the United States. We may store and process your Personal Information in any country where we have facilities or in which we engage service providers. By using the Services, you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

RETENTION 

We retain Personal Information for as long as needed or permitted for the purposes for which it was collected as outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law. 

Updates to this Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

Contact Us

If you have any questions about this Privacy Policy, please contact us at legal@thronescience.com. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

Consumer Health Data Privacy Statement

Last Updated: [Date]

Pursuant to the Washington My Health My Data Act and the Nevada Consumer Health Privacy Law, Throne, Inc. (“we,” “us,” or “our”) is providing the following details regarding the categories of consumer health data that we collect, use, and share about Washington and Nevada consumers. This Consumer Health Data Privacy Statement (the “Privacy Statement”) supplements our Privacy Policy. 

Sources and Categories of Consumer Health Data

For purposes of this Privacy Statement, “consumer health data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status.

The consumer health data we may collect from you includes: 

Health conditions, treatment, diseases, or diagnosis, such as information about digestive or urinary issues and information you disclose or insights we derive from the information captured from your Throne device. Note: Our insights are wellness-focused and not designed for diagnosing or treating medical conditions. 

Social, psychological, behavioral, and medical interventions, such as information you provide about diet, stress, or hydration changes and details about behavior or routine adjustments made in response to our insights.

Health-related surgeries or procedures, such as information you share about past digestive or urinary procedures and information you disclose about relevant surgeries when seeking support for changes in your bathroom patterns.

Use or purchase of prescribed medication, such as medication or supplement information you report that may affect digestion or urinary function and information you provide to contextualize changes in stool or hydration patterns.

Bodily functions, vital signs, symptoms, or measurements, such as stool frequency, stool form, and hydration or urinary flow measurements based on urine color, urine volume, or flow rate, as well as any other information captured from your Throne device.

Diagnoses or diagnostic testing, treatment, or medication, such as diagnostic or treatment information you submit to help interpret our trends and information you report about clinician guidance relevant to your gut or urinary patterns. Note: Our insights are wellness-focused and not designed for diagnosing or treating medical conditions.

Reproductive and sexual health information, such as information you provide about menstrual cycles or hormonal changes.

Information that could identify your attempt to seek health care services, such as information you provide about sharing our insights with a clinician.

Any inferences of the above categories of health data derived or extrapolated from non-health information.

Any other health information you decide to provide to us, including through our journaling feature or through connected wearable devices and apps.

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How We Use and Share Consumer Health Data

We collect, use, and share consumer health data to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: 

• Develop, improve, and maintain our products and services;
• Personalize our products and services;
• Conduct research, analytics, and data analysis;
• Undertake quality and safety assurance measures;
• Conduct risk and security monitoring;
• Detect and prevent fraud;
• Perform identity verification;
• Perform accounting, auditing, and other internal functions, such as internal investigations;
• Comply with legal obligations and internal policies;
• Maintain records; and
• Exercise and defend legal claims.

We may also use consumer health data and share it with a third party in the context of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We may share each of the categories of consumer health data listed above with the following categories of third parties: 

• Our service providers;
• At your direction;
  
  • We may share your consumer health data with research organizations with your consent, or with other individuals or third parties at your direction.
• Public and governmental authorities; and
• Other third parties.
  
  • In certain circumstances, it may be necessary to provide consumer health data to other third parties, for example, to comply with applicable law or to protect the rights, safety or property of us, you, and others.

We do not sell consumer health data, as defined in the Washington My Health My Data Act and the Nevada Consumer Health Privacy Law.

Individual Rights

If you are a Washington or Nevada consumer, you may make the following requests regarding your consumer health data, subject to applicable law and certain exceptions:

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1. Request to Know

You may request that we disclose:

• Whether we are collecting, sharing, or selling your consumer health data; and 
• The third parties to whom we have shared or sold your consumer health data. 

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2. Request to Withdraw Consent

You may request to withdraw consent for the collection or sharing of your consumer health data. 

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3. Request to Delete

You may request that we delete your consumer health data.

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4. Request to Access

If you are a Washington consumer, you may request that we provide you with:

• The email address or other online mechanism you can use to contact the third parties with whom your consumer health data is shared or sold; and
• A copy of your consumer health data. 

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5. Request to Amend

If you are a Nevada consumer, you may request that we make changes to your consumer health data.

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To make a rights request, please contact us at legal@thronescience.com. We will verify and respond to your request consistent with applicable law. We may need to request additional information from you in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your consumer health data. If you make a Request to Delete, we may ask you to confirm your request before we delete your consumer health data.

If we refuse to take action on your request, you may appeal this refusal by contacting us at legal@thronescience.com. 

Changes to This Privacy Statement

We may change or update this Privacy Statement from time to time. When we do, we will post the revised Privacy Statement on this page with a new “Last Updated” date.

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