Privacy Policy
Effective Date: January 1, 2026
Last Updated: January 1, 2026
Table of Contents
Introduction
NGSMEDIA LLC, doing business as CeruLabs, together with its subsidiaries and affiliates (collectively, "Company," "us," "we," or "our") is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Policy describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our "Digital Properties"); in-person events and purchases; and other online and offline interactions.
This Privacy Policy applies to information we collect about individual consumers, such as general website visitors ("Individuals") as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions ("Business Contacts"). However, this Privacy Policy does not apply to:
- •Information about our current/former employees, applicants, and other individuals who interact with us for employment-related purposes.
- •Information that is subject to the Health Insurance Portability and Accountability Act ("HIPAA").
- •Information that we process on behalf of and under the instructions of our business customers (as a processor), including information we process on behalf of medical practices subject to HIPAA or equivalent state laws.
Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.
Changes: We may update this Privacy Policy from time to time. Any updated Privacy Policy will be effective when posted to our Digital Properties. Please check this Privacy Policy periodically for updates.
1. Sources of Personal Data
We collect Personal Data about you from the following sources:
Directly from you
We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; interact with us in person; sign up for offers or newsletters; communicate with us; place or customize orders for cerumen (earwax) testing kits; or sign up for an account or other services.
Data collected automatically and through tracking technologies
We may automatically collect information or inferences about you when you interact with our Digital Properties, such as through cookies and other tracking technologies. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information. For more information about cookies and other tracking technologies, please see Section 5 (Cookies and Other Tracking Technologies).
From third parties
We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, affiliate marketing partners, social media companies, and other parties who interact with us.
From publicly available sources
We may collect Personal Data about you from publicly available sources, such as public profiles and websites.
We may combine information that we receive from the various sources described in this Privacy Policy, including third party sources, and use or disclose the combined information for the purposes identified below.
2. Types of Personal Data We Collect
We may collect the following types of Personal Data about you. Except as otherwise specified, we may collect this Personal Data from both Individuals and Business Contacts.
A. Identifiers
Such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
B. Records about you
Such as signatures; physical characteristics or a description of you; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments.
C. Demographic information
Such as age (including birthdates) and gender (including gender identity).
D. Commercial information
Such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
E. Biological Samples
Such as cerumen (earwax) samples you submit for analysis through our testing kits.
F. Internet or other electronic network activity information
Such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties.
G. Non-precise geolocation data
Such as approximate location derived from IP addresses.
H. Audio, electronic, visual, or other sensory information
Such as photographs you choose to provide and audio/video recordings during our interactions.
I. Professional or employment-related information
(For Business Contacts) Such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
J. Inferences
Drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
K. Sensitive Personal Data
Including health information derived from cerumen analysis (such as biomarker levels, inflammation indicators, and other wellness metrics) and related health data.
3. How We Use Personal Data
We may use Personal Data for the following purposes:
To provide you or your company products and services
Such as making our Digital Properties, products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request (including cerumen testing kits and analysis results); providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you; and providing similar services or otherwise facilitating your relationship with us.
For our internal business purposes
Such as operating our Digital Properties and customizing the content; maintaining internal business records, such as accounting, document management, and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
For our internal research and product improvement purposes
Such as verifying or maintaining the quality or safety of our products or services; developing and improving our products or services, including developing or training algorithms or AI tools for cerumen analysis; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
For legal, safety, or security reasons
Such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers', and other third parties' safety, property, or rights; detecting, preventing, and responding to security incidents and health and safety issues; and protecting against malicious, deceptive, fraudulent, or illegal activity.
In connection with a corporate transaction
Such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
For marketing and targeted advertising
Such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising to you; to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email, or by contacting us using the information in the Contact Information section below.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
4. How We Disclose Personal Data
We may disclose Personal Data to third parties, including the categories of recipients described below:
Affiliates and subsidiaries
Including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
Laboratory Partners
Including certified laboratories that analyze cerumen samples to provide you with health insights and biomarker results. We do not control the privacy practices of these partners, so we encourage you to consult their privacy notices.
Service providers
That work on our behalf to provide the products and services you request or support our relationship with you, such as our testing and analysis laboratory partners, IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
Professional consultants
Such as accountants, lawyers, financial advisors, and audit firms.
Vendors necessary to complete transactions you request
Such as shipping companies and logistics providers.
Law enforcement, government agencies, and other recipients
For legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use and other agreements or policies; and to protect ours, our customers', or third parties' safety, property, or rights.
Other entities in connection with a corporate transaction
Such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
Business partners
That may use Personal Data for their own purposes, such as advertisers, ad platforms and networks, social media platforms, third parties whose cookies and tracking tools we use, commercial data partners, and partners who collaborate with us on promotional opportunities.
The public
Such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
Entities to which you have consented to the disclosure
When you explicitly authorize us to share your information with specific third parties.
Important: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes; all the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.
6. Data Security and Data Retention
Security Measures
Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.
Data Retention
Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures.
Post-Termination Retention
Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest.
Biological Sample Handling
Cerumen samples submitted for testing are processed by our certified laboratory partners. After analysis is complete, samples are disposed of in accordance with applicable regulations and laboratory protocols unless you specifically request sample retention for future testing.
7. Children's Privacy
The Digital Properties are not directed at, marketed to, nor intended for, children under 13 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 13 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 13, please contact us at the address in the Contact Information section below, and we will take prompt steps to delete the information.
8. External Links
Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.
9. Contact Information
If you have questions regarding this Privacy Policy, please contact us:
10. Supplemental Information for Residents of California, Colorado, Oregon, Delaware, and Other U.S. States
Data Subject Rights
Depending on our relationship with you (i.e., whether you are an Individual or a Business Contact), and in which state you reside within the United States (including California, Colorado, Oregon, or Delaware), you may have certain rights regarding Personal Data, which you may exercise by emailing us at privacy@cerulabs.com.
You may have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed your Personal Data and why. You may also request the specific pieces of Personal Data we have collected about you.
You may have the right to request that we delete Personal Data that we have collected from you.
You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
You may have the right to limit the use and disclosure of Sensitive Personal Data, including health information derived from cerumen analysis.
You may have the right to opt out of selling, sharing, and targeted advertising (as such terms are defined under applicable laws).
Non-Discrimination
We will not discriminate against you for exercising your privacy rights.
Verification
In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request.
We may collect your name and email to locate you in our records.
We collect information necessary to locate you in our records and verify your identity and that you are a resident of a state that provides for these rights, which may include first and last name, email address, telephone number, and relationship to us.
Authorized Agents
Authorized agents may exercise rights on your behalf by submitting a request to privacy@cerulabs.com. If you designate an authorized agent to submit a request, we may seek additional information from the authorized agent or reach out to you directly to verify your identity or to confirm that you provided the authorized agent permission to submit the request.
Appeal
If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us at privacy@cerulabs.com. We will inform you in writing of our response to your appeal.
California Shine the Light
If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the "Shine the Light law") with third parties for those third parties' direct marketing purposes by emailing privacy@cerulabs.com.
Disclaimer
THIS WEBSITE DOES NOT PROVIDE MEDICAL ADVICE
The information, including but not limited to, text, graphics, images and other material contained on this website are for informational purposes only. No material on this site is intended to be a substitute for professional medical advice, diagnosis or treatment. Always seek the advice of your physician or other qualified health care provider with any questions you may have regarding a medical condition or treatment and before undertaking a new health care regimen, and never disregard professional medical advice or delay in seeking it because of something you have read on this website.
The products on this website are not cleared or approved by the U.S. Food and Drug Administration as medical devices intended to treat, diagnose, prevent, mitigate, or cure any disease or condition.
By using CeruLabs, you acknowledge that you have read, understood, and agree to the data practices described in this Privacy Policy, including the collection and processing of your biological samples and health-related information.