This policy document was last updated on October 9, 2009.

PogoHealth LLC. is concerned about protecting the privacy of our Members and site visitors and their personally identifiable health information. Our business depends on the trust that our clients offer us. We are committed to maintaining and protecting that trust.

The following privacy policy applies to the services offered on the pogohealth.com. pogohealtheducation.com, websites (collectively called PogoHealth). PogoHealth provides security for electronic transactions associated with the PogoHealth service and reports, and we promote editorial practices consistent with our organization's informational and educational mission and goals.

If you have any questions or concerns regarding this statement, please contact us at: info@PogoHealth.com. You may also contact us by U.S. mail at: PogoHealth LLC, 2510 Meridian Parkway, Durham NC, 27713

Definitions

"Member(s)" means any person or persons using, or that have subscribed to, PogoHealth Products or Services.

"PogoHealth" means PogoHealth LLC.

Privacy Policy and Agreement

When users choose to provide information about themselves, we maintain this information in strict confidence and use it only for the purpose for which it was supplied. The following policy statement explains how PogoHealth uses and discloses personal information collected from and provided by you or other members under your subscription or FREE membership. Any personal information collected or provided to us through the PogoHealth website will be treated with care and is subject to the policy set forth below.

THE PURPOSE OF THIS PRIVACY POLICY (THE "POLICY") IS TO HELP YOU UNDERSTAND THE KINDS OF INFORMATION WE MAY GATHER ABOUT YOU WHEN YOU VISIT THE SITES OR USE ANY OF OUR SERVICES, HOW WE MAY USE THAT INFORMATION, IN WHICH MANNER WE WILL DISCLOSE IT, AND HOW YOU CAN CORRECT AND/OR UPDATE THE INFORMATION. PLEASE NOTE THAT BY USING THE SERVICES OR VISITING THE SITES, YOU SIGNIFY YOUR AGREEMENT WITH THIS POLICY. IF YOU DO NOT AGREE TO THE TERMS OF THIS POLICY, PLEASE DO NOT USE THE SERVICES, AND REFRAIN FROM VISITING THE SITES.

The PogoHealth service is not intended or designed to be used by children under the age of 12 until such time as pediatric questionnaires are available to address the specific needs of children. Use of our site by children of any age should be initiated, supervised and/or administered by their parent(s), guardians, physician, or other healthcare provider(s).

Information We Collect (and why we collect it)

Health Profile Information

We collect a variety of health information for those Members and site visitors who complete any PogoHealth health profile interview(s) for themselves, or their family members.

During the automated PogoHealth evaluation and recommendation, Members and site visitors may reveal to us the name of the individual for whom the evaluation is being conducted, but they are not required to do so. Revealed names are used by PogoHealth only to place the subject's name on the final PogoHealth reports for purposes of clarity when the report is printed. Members and site visitors are welcome to provide aliases or no name, if they choose. Any individually identifiable user information provided is kept strictly confidential and is used solely for the purpose for which it was supplied.

During the automated PogoHealth interviews, evaluations, analysis, and generation of reports, site visitors and members are also invited to provide detailed information about medications and supplements being taken (or contemplated), coexisting medical problems, gender, date of birth, Pogo physiometric information, genetics, lifestyle, disease/condition, certain laboratory test results, etc. These data are used to analyze and report on recommendations of nutrients, identification of supplements containing identified nutrients, and reviews of supplements by the PogoHealth service.

During the automated PogoHealth analysis and reports, Members and site visitors may also be invited to provide self-described ethnicity information from one of two Federal categories and self-described racial information from one of five Federal categories. Provision of ethnic and racial information is not required for the PogoHealth service to function correctly. However, because the service available from PogoHealth may be interpreted as being "Clinical Research" under Federal regulation, and because PogoHealth strives to comply with "NIH (National Institutes of Health) Policy on Reporting Race and Ethnicity Data for Subjects in Clinical Research," we may allow Members and site visitors the option of providing ethnicity and racial information if they so choose.

During the automated PogoHealth analysis and evaluation you may decide to voluntarily provide personal contact information. We may use this information, when appropriate, to contact and correspond with you, to respond to your inquiries and as otherwise permitted by law. If you provide us with your email or mailing address, we may send you, as per your opt-in preferences, information and updates you requested. We may from time-to-time also send newsletters and information about PogoHealth and its products and services. Your personal health information is kept strictly confidential and can be accessed only with your password and login ID. PogoHealth will not use or disclose your personal health information, or the results of our analysis, without your express consent. You can choose to authorize access to your information for your physician, pharmacist or other healthcare-related professionals.

General information is used internally in connection with our business to improve the web site, including our marketing and advertising efforts, and to make your use of the web site as enjoyable and efficient as possible.

We use your email address to provide you with additional information you have opted in to receive including advisories, promotions, and/or updates on the site, and PogoHealth and its licensors reserve the right to contact you with urgent health related advisories about specific products that have appeared on your product shopping list, provided however, that we shall have no obligation to do so, and no liability for failure to do so.

Genetic Information

Testing: PogoHealth may in the future outsource genetic testing to a third party. Strict quality control and privacy criteria are maintained for genetic tests: The test must provide useful information for use in the PogoHealth analysis. PogoHealth will not provide tests for single-gene diseases directly to the public.

PogoHealth does not provide genetic services for forensic or paternity testing. All information and samples provided by any individual to PogoHealth remain the property of that individual. Samples will be destroyed after testing. No information relating to the individual will be supplied to any third party without the explicit written consent of that individual. In accordance with United States federal policy and state laws, personal genetic information shall not be disclosed to insurers or employers without the prior written consent of the individual.

Administrative and Credit Card Information

For those Members and site visitors who choose to purchase our services and/or products; we request information necessary to authorize a credit card payment. We disclose this financial information to our merchant account partner, a nationally prominent payment processor and digital security company, so that credit card transactions can be processed. Personal and financial information provided to place an order is protected on a secure server. When processing your credit card payment, you will be asked for the card type, card number, expiration date, and your card's billing address. PogoHealth and our payment processor will transmit credit card numbers in an encrypted format using industry-standard, secure-socket- layer encryption. When your credit card transaction is completed your credit card number will be deleted or changed to encrypted data on a server with no direct access to the Internet.

We also maintain other general records about services we have sold in order to assist Members with requests for help, requests for additional information, requests for refunds, etc.

PogoHealth, LLC owns and operates the PogoHealth websites and we are the sole owner of this information collected on the web site. We will not sell, share, or rent this personally identifiable information to a third party in any way other than as authorized by you or as disclosed in this privacy policy. PogoHealth reserves the right to sort, analyze, mine, share or sell non-personally identifiable aggregated data at its discretion.

We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities and may, in our sole discretion, disclose personal information or other information to satisfy any law, regulation, subpoena, or government request. We reserve the right to release personal information or other information about users who we believe are engaged in illegal activities or are otherwise in violation of our Terms of Service, even without a subpoena, warrant, or court order, if we believe, in our sole discretion, that such disclosure is necessary or appropriate to operate our web site or to protect the rights or property of PogoHealth websites, our affiliates, or our officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors. We also reserve the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

Affiliates

We have formed affiliations with other entities that may be a portal to the PogoHealth interviews, results, and reports. These relationships are created through portals to the PogoHealth site and the information is not transferred back to the affiliate site in any way unless agreed to by you when registering as an initial member. Even where it may seem that the pages may have the same appearance as those on the affiliate website, you are, in fact, protected by the privacy policy on the PogoHealth sites and your information resides in and is not shared with the affiliate unless you have opted in to share all or part of this information, or where you have agreed to link in to the affiliate site and have certain information transferred.

Other Information

We maintain records of individuals who contact us (via email, by phone, and written correspondence) in case we need to contact them later. However, we do not provide this information to anyone else unless Members give us permission. For instance, when we provide a link to a product site where you may purchase supplements. We do not sell supplements, nor do we make any profits, revenues, or any other monetary or non-monetary compensation from any product supplement companies.

Collection and Transfer of Information

If PogoHealth becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice to our Members before any personal information is transferred and becomes subject to a different privacy policy.

For quality control purposes, our research clinicians do review some of the evaluations, recommendations and reports generated by PogoHealth to assess their accuracy and completeness. We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who have reported particular diseases or health conditions, the types of medications or supplements taken, etc. Such information is recorded and collected into groups so as not to identify you individually.

PogoHealth automatically collects certain non-identifiable information regarding its users, such as the Internet Protocol (IP) address of your computer, the date and time you accessed our site, your operating system and web browser, the address of the website that linked to our site and the section of our site that you visited. This information does not identify you personally and is used to improve our processes, products, and services to better serve our Members. Your non-identifiable information is not disclosed to others and is archived for future use.

We do track, in an anonymous fashion, the general frequency with which we serve web pages. We use this information to determine what topics and content may or may not be of interest to our site visitors and Members, in order to ensure that we are continually providing services that are most valuable to our Members.

Cookies

We do use session variables (also called temporary cookies) so that information provided by Members and site visitors is correctly presented from one page to the next. Once a session has ended (after approximately 15 minutes of inactivity on the PogoHealth site or once a user's web browser is closed), all session variables are automatically removed and destroyed. Cookies enhance the convenience and use of the site. You may chose to decline cookies if your browser permits, however, if you reject a cookie, certain functions and conveniences of the PogoHealth site may not function as intended.

For site visitors accessing PogoHealth from a search engine partner such as Google, they place a 30-day persistent "cookie" on the site visitor's computer so that Google can provide statistics to us regarding advertising effectiveness. These cookies are automatically removed and destroyed after 30 days. No personally identifiable information is exchanged during this process.

Communications Security

PogoHealth is an Internet based company and security, privacy, and protection of information transmitted over the Internet are critical concerns.Where appropriate, your sensitive information (such as a credit card number) on our registration or order forms will be encrypted using secure socket layer technology (SSL). However, the possibility exists for unauthorized individuals to intercept any email message sent over the Internet. PogoHealth utilizes Internet-based forms to collect the personal health/lifestyle data needed to prepare an analysis. These forms are hosted on a secure server. However, no method of transmission over the internet or method of electronic storage is 100 percent secure. Although the possibility exists that unauthorized individuals may intercept your communications with us, the utilization of a secure server decreases the risk of compromise of personal information.

Contacting You

In addition, site visitors and members may "opt in" to receive advisories, promotions specific to their profile, updates, and information on relevant topics. We will send emails as often as requested by our members.

Members can "opt out" of such notices at any time. (All emails we send include opt-out instructions). Members can also opt out by sending an email to optout@pogohealth.com. For the fastest response, include the email address you would like to remove from the PogoHealth mailing list in the body. Members may also opt out by changing their 'preferences' in their 'my account' PogoHealth page.

What We Don't Do
We do not retain any records of member credit card numbers following completion of credit card purchases. We do not spam site visitors or Members.

We do not sell, rent, share, or otherwise disclose mailing lists or other personally identifiable information to third parties in any way other than disclosed in this policy.

We do not use invisible images (also called: "1x1 pixel gifs", "web bugs", "action tags", and "web beacons").

We do not sell personal data on users or their personally identifiable navigation patterns unless you have opted in to allow this use.

Editorial Policies

The information available from the PogoHealth service is written and maintained by healthcare professionals and is based on review of the scientific and medical literature. PogoHealth and its healthcare professionals write some of the information in-house. Thomson Reuters (an electronic drug information company from whom we license drug information) healthcare professionals write other information. At all times, the authors of the content of PogoHealth strive to provide a balanced review of the clinical characteristics of drugs based on information published in mainstream medical journals and other resources.

Other Disclosures

PogoHealth provides information that is independent of the views and opinions of pharmaceutical manufacturers, pharmacies, and other such entities.

PogoHealth may provide links to other websites that may provide information of interest or value to PogoHealth members. Inclusion of other sites by links does not imply any endorsement of the material or information on the other sites. Users should review the terms and conditions and privacy policy of each linked site before sharing personal, financial, health-related or other confidential information.

PogoHealth accepts no requests or payments for specialized treatment of specific supplements, drug products or services.

Other Information on Our Policies

We may update our policies in the future. Changes to our privacy policy are at our sole discretion and may be made without any prior notice. We encourage you to return from time to time to review updates. If you have any comments or questions regarding PogoHealth's Privacy Policy, please contact us.

PogoHealth LLC, 2510 Meridian Parkway, Durham NC, 27713 Tel: 919-536-7646