Privacy Policy

Effective Date: 09/29/2023


  • We give you full control to decide how your Personal Information is used and with whom it is shared.
  • We will not share your Personal Information with employers, insurance companies, public databases or 3rd party marketers without your explicit consent.
  • We encrypt all sensitive information and conduct regular assessments to identify security vulnerabilities and threats.
  • We exceed industry data protection standards and maintain a HIPAA compliant Website.
  • We break everything down into easy-to-understand language so that each choice you make is an informed choice.


TWILIGHT TECHNOLOGIES, INC. ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.This policy describes the types of information we may collect from you or that you may provide when you visit the website (our "Website") or otherwise use our services (the “Services”), as well as our practices for collecting, using, maintaining, protecting, and disclosing that information.This policy applies to information we collect:

  • On this Website or through the use of our Services.
  • In email, text, and other electronic messages between you and the Website.
  • Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy).

Information We Collect About You and How We Collect It

We try not to speak in legalese, but there are some useful definitions we use to describe data we collect in providing the services to you.When we say Personal Information, we use this as a general term to refer to the different data categories we describe in this section that either personally identify you or are about you. Your Personal Information can be either:

  • Individual-level Information: information about a single individual, such as their medical history, diseases or other traits or characteristics.
  • De-identified Information: information that has been stripped of identifying data, such as name and contact information, so that an individual cannot reasonably be identified.

Aggregate Information is different from Personal Information.

Aggregate Information is not Personal Information because Aggregate Information does not contain information about, nor can it reasonably be linked to, a specific individual. Aggregate Information is information about a group of people, such as an analysis or evaluation of a group. Aggregate Information describes the group as a whole in such a way that no specific individual may be reasonably identified. For example, the number of Twilight customers with a specific variant or health condition is Aggregate Information.

Here are the types of Personal Information we collect:

  • Registration Information: information you provide during account registration or when purchasing the services, such as a name, user ID, password, date of birth, billing address, shipping address, payment information (e.g., credit card), account authentication information, or contact information (e.g., email, phone number).
  • Health Information: information regarding your medical history, including your Medicare Claims file, which allows us to process and parse data into what we call a Member Illumination Report and interface in our application.
  • Self-Reported Information:​ information you provide to us including your gender, disease conditions, health-related information, traits, ethnicity, family history, or anything else you provide to us within our service(s).
  • Web-Behavior Information: information on how you use our services or about the way your devices use our Services is collected through log files, cookies, web beacons, and similar technologies (e.g., device information, device identifiers, IP address, browser type, location, domains, page views).

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details,  IP addresses, and information collected through cookies, and other tracking technologies.
  • From third parties, for example, from Medicare.

Information You Provide to Us  

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is only statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Web Beacons. Pages of our Website [and our emails] may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or [opened an email] and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

We do not collect Personal Information automatically, but we may tie this information to Personal Information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

We try not to speak in legalese, but there are some useful definitions we use to describe data we collect in providing the services to you.When we say Personal Information, we use this as a general term to refer to the different data categories we describe in this section that either personally identify you or are about you. Your Personal Information can be either:

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

Now that we’ve covered the types of information we collect and how we collect it, let’s review how we may use it. As a reminder, we will not use your Personal Information for personalized or targeted marketing and/or advertising without your explicit consent.

We use your information to:

  • To present our Website and its contents to you.
  • To provide our services, including to develop, operate, improve, maintain, and safeguard our services, including developing new product tools and features.
  • To analyze and measure trends and usage of the services.
  • To fulfill any other purpose for which you provide it.
  • To conduct Twilight research, if you choose to participate. - To develop and improve new and current products and services (e.g., analytics). As used herein, “analytics” means the process of examining data to draw conclusions from that information.
  • To communicate with you, including customer support, or to share information about our services or other offers or information we think may be relevant to you.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it. To allow you to participate in interactive features on our Website.In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

What Twilight Research Participation Means for You

Twilight has an opt-out research program, meaning that for eligible customers, taking part in Twilight Research is completely voluntary. Here are key points about Twilight Research, how Research uses personal information, and other ways we safeguard your privacy.

Before explaining how Research uses Personal Information, let’s cover a few basics:

What is Twilight Research?  

The purpose of Twilight Research is to make new discoveries about the factors behind diseases and traits. “Twilight Research” means research activities performed by Twilight, either independently or jointly with third parties. Twilight Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, including non-profit foundations and academic institutions.

What if I do not want to participate in Research?

If you are eligible to participate in Research, you choose whether to participate or not, and you can change your mind any time. Customers never need to participate in Research to use Twilight. Nothing changes about your core Twilight experience if you do not participate in Research. We will not use your information for Research if you opt-out of Twilight Research. You can opt-out of Twilight Research by logging into your account and adjusting your user preferences in your account profile, or by sending us an email with your request to

How does Twilight protect my information in Research?

Twilight Research analyses are conducted with information that has been stripped of your identifying Personal Information.

If you choose to consent to the Main Research Consent:

  • Your de-identified Personal Information may be used for Research.
  • We may share summaries of research results, which do not identify any particular individual, with qualified research collaborators and in scientific publications.
  • We may inform you of research opportunities for which you may be eligible. We will not share individual-level Personal Information without your explicit consent. To change your preferences for these communications, go to your Account Settings.

How We Share Your Information:

We appreciate the level of trust you put in us. Here’s how we do, and do not share your information.

Who we share with:

  • Service providers:
    Our service providers and contractors help us provide our services and act on our behalf to get things done. We implement procedures and maintain contractual terms with each service provider and contractor to protect the confidentiality and security of your Personal Information. For example, some of the things we use service providers and contractors to help us with include: clinical review by one of our clinical partners to ensure the report is medically accurate and relevant; customer care support; cloud storage, IT, and security; marketing and analytics; and more. Learn more about cookies, analytics, and advertising partners we use on our services in our Cookie Policy.
  • Your sharing choices:
    You may direct us to share your Personal Information with friends, family members, doctors or other healthcare professionals, and/or any other individuals or entities who may or may not be using our services. If you share your Personal Information with a third party, they may use your Personal Information differently than we do under this Privacy Statement. Please make such choices carefully and review the privacy policies of all other third parties involved.
  • Commonly owned entities, affiliates and change of ownership:
    If we are involved in a merger, acquisition, bankruptcy, reorganization, or sale of assets, your Personal Information may be accessed, sold or transferred as part of that transaction and this Privacy Policy will apply to your Personal Information as transferred to the new entity. We may also disclose Personal Information about you to our corporate affiliates to help operate our services and our affiliates’ services.

Third parties related to law, harm, and the public interest:

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TWILIGHT TECHNOLOGIES, INC., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection. Health information, however, will not be disclosed.

This includes exchanging information with other companies and organizations for the purposes of fraud protection.We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Who we DO NOT share with:

You can rest assured, we will not voluntarily share your Personal Information with:

  • Public databases
  • Insurance companies or ​employer​s
  • Law enforcement, absent a valid court order, subpoena, or search warrant

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising:
    You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your cookie settings, visit cookies settings page on your browsers website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising:
    If you do not want us to share your contact information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by logging into the Website and adjusting your user preferences in your account profile, or by sending us an email with your request to
  • Promotional Offers from the Company:
    If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

    We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional Personal Information rights and choices. Please see Your State Privacy Rights for more information.

Accessing and Correcting Your Information

You can review and change your Personal Information by logging into the Website and visiting your account profile page. You may also send us an email at to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Retention of Personal Information

We retain Personal Information for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations. We delete Individual-level Personal Information of dormant accounts after 5 years and delete Individual-Level Personal Information of permanently disabled (closed) accounts after 30 days.  We may retain De-identified Personal Information indefinitely.

Data Security

We have implemented industry-leading measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Information security measures include: secure storage, encryption of digital records in transit and at rest, and system backups. All information you provide to us is stored on our secure servers behind firewalls. We regularly review our data protection practices to consider appropriate new technological and other safeguards.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. 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.Health Information uploaded to your account can include genetic or family history information that may be relevant to other family members. You should only share access to your account with individuals you trust, and you accept all responsibility for disclosures that are made to them.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information on the Website. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Website, through any of its features, register on the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to learn more about California residents' privacy rights, visit

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. To exercise any of these rights please contact our privacy officer via email at To appeal a decision regarding a consumer rights request please contact us via email at

Notice to Virginia Residents:

The VCDPA provides Virginia residents with the right to receive certain disclosures regarding the personal data we process about them. This CCPA Notice provided any and all needed disclosures under the VCDPA. If you are a Virginia resident, the VCDPA grants you the right to: (1) confirm whether or not we are processing your personal data to access such personal data; (2) correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data; (3) delete personal data you have provided or we have obtained about you; (4) obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and (5) opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. The rights and how to exercise them are detailed under this CCPA Notice and are applicable for Virginia residence as well and you may exercise your rights as detailed above.

If you have an account with us, we may require you to use the account to submit the VCDPA request. We may require specific information from you to help us confirm your identity and process your VCDPA request. If we denied a request, you may appeal our decision, and within 60 days of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the Virginia Attorney General at

Nevada Residents Notice:

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We currently do not sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the primary email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. If you do not agree to the the changes to our privacy policy and wish to opt-out of receiving the Services, please contact us via email at

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, please email Twilight’s Privacy Administrator at, call us at 443-255-6527, or send a letter to:

Privacy Administrator
Twilight Technologies, Inc.
4608 ½ Roland Ave
Baltimore, MD 21210