This Privacy Policy explains how Pico Health Inc. d/b/a ModernGut ("ModernGut," "Company," "we," "us," or "our") collects, uses, discloses, and protects personal information in connection with our website at moderngut.com and moderngut.mykajabi.com, online courses, videos, written course materials, free articles and blog posts, Q&A webinars and replays, newsletters, account features, purchases, communications, advertising, analytics, templates, resources, and related online or offline offerings that link to this Privacy Policy (collectively, the "Services").
This Privacy Policy is incorporated by reference into our Terms of Use.
This Privacy Policy applies to personal information we process through the Services. It does not apply to third-party websites, platforms, payment processors, course-hosting providers, analytics services, advertising platforms, social media platforms, or other third-party services that we do not control.
ModernGut provides content concerning gastroenterology, digestive health, and related healthcare topics, including diagnosed conditions such as irritable bowel syndrome, for general informational and educational purposes only. ModernGut does not provide medical diagnosis, treatment, or individualized medical advice through the Services. ModernGut does not currently intend to ask users to provide personal health information, symptoms, diagnoses, diet information, medications, supplements, lab results, treatment history, wellness goals, or similar information through intake forms, quizzes, surveys, assessments, or personalization features.
Please do not submit personal health information, diagnoses, symptoms, medications, lab results, treatment information, insurance claim information, or other sensitive health information through webinar questions, support requests, social media comments, direct messages, or other communications. If you voluntarily provide health-related information despite those instructions, ModernGut may process that information as described in this Privacy Policy and any applicable consumer health data notice.
The personal information we collect depends on how you interact with us and the Services.
Account Information. If you create an account, we may collect your name, email address, username, password, and other account credentials or profile information.
Purchase and Payment Information. If you purchase a course or other offering, we may collect information associated with the purchase, such as your name, email address, billing details, transaction information, purchase history, course purchase history, and refund information. Payments are processed by third-party payment processors, including Kajabi Payments, built in partnership with Stripe, or another payment processor disclosed at checkout. Your payment transaction may be governed by the applicable payment processor's terms of service, privacy policy, and other agreements, and you may be required to enter into a direct relationship or separate agreement with the payment processor to complete your transaction. ModernGut does not directly collect or store full payment card numbers, but payment processors may make certain payment-related information available to us, such as customer name, email address, billing details, card brand, last four digits of the payment card, transaction amounts, and purchase history.
Course and Service Information. We may collect information about the courses, resources, or Services you access, including course access, course progress, course completion, offer-level sales, email performance, page interactions, and related usage information.
Webinar Information. If you are eligible for a Q&A webinar, we may collect registration information, attendance information, replay-access information, and written questions submitted before or during the webinar. Users are instructed not to include personal health information in webinar questions. Questions may be screened, declined, deleted, or not answered if they contain personal health information.
Communications. If you contact us, request support, subscribe to newsletters, respond to emails, or otherwise communicate with us, we may collect your name, email address, contact details, and the contents of your communications.
Newsletter and Marketing Information. If you submit your email through the website, social media automation, lead forms, or other sign-up flows, you may receive marketing emails from ModernGut, subject to your right to unsubscribe. We may collect your name, email address, marketing preferences, discount code, sign-up source, and related interaction data. If you use a discount code distributed by a GI clinic, we may record the code and distribution source to administer the discount. ModernGut does not provide compensation to the clinic or receive compensation from the clinic in connection with that distribution arrangement, and does not disclose customer information to the clinic for that purpose.
Testimonials and Feedback. If you provide feedback or a testimonial, we may collect the information you provide. Testimonials may include a user's first name and last initial, city and state, and description of the user's experience with ModernGut, subject to applicable consent requirements.
Social Media and Direct Message Interactions. If you interact with ModernGut through social media, comments, or direct message automation, including through Instagram or Facebook DM automation, we may collect information you provide and information made available by the relevant social media platform. Social media platforms also process your information under their own terms and privacy policies.
Business Contacts, Contributors, and Partnerships. We may collect personal information from healthcare professional contributors, webinar hosts, service providers, and other business contacts.
Job Applications. If you apply for a job or contractor role, we may collect application materials and related information.
When you use the Services, we and our service providers may automatically collect information such as IP address, browser type and settings, device type, operating system, device identifiers, approximate location derived from IP address, referring and exit pages, pages/videos/courses/emails/features viewed, dates and times of access, links clicked, course progress and completion data, cookie identifiers, local storage data, and information used to detect fraud, maintain security, debug, and improve the Services.
ModernGut and its service providers use technologies necessary to operate, secure, and maintain the Services; provide course access, checkout, video hosting, email, and communications; measure performance and usage; and detect, prevent, and debug security or technical issues.
At launch, ModernGut uses Kajabi for its website, courses, checkout, email functionality, contacts, and platform reports; Kajabi Payments, provided through Stripe, for payments; Plausible for cookieless analytics on the public website and checkout; MailChimp as its marketing contact database; and ManyChat for social-media direct-message lead capture. Kajabi and its service providers may also use platform-level video-hosting, performance-monitoring, error-monitoring, security, and infrastructure services, including Wistia, RudderStack, Datadog, Sentry, Cloudflare, and Amazon Web Services.
ModernGut does not deploy advertising, retargeting, conversion-tracking, or third-party marketing pixels or tags at launch. ModernGut does not use Meta Pixel, TikTok Pixel, Google Ads conversion tracking, Google Analytics, a tag manager, or a server-side conversions API. Because ModernGut provides digestive-health educational content, certain interactions with our Services, including course purchases, course engagement, or health-related page views, may indicate an interest in digestive-health topics.
We may receive personal information from Kajabi, Kajabi Payments, Stripe, MailChimp, ManyChat, social-media platforms, service providers, and other sources, depending on how you interact with the Services and your privacy settings with those third parties.
We may use personal information to provide, operate, maintain, secure, and improve the Services; create and manage accounts; provide access to courses, videos, written materials, articles, webinars, replays, templates, and resources; process purchases, payments, refunds, and transactions; track course access, progress, preferences, and completion; administer webinar eligibility, registration, question submission, attendance, and replay access; respond to communications; provide newsletters and marketing communications; personalize or improve your experience; develop new offerings; conduct analytics and internal research; debug errors; prevent fraud or abuse; enforce our Terms; protect rights and safety; comply with legal obligations; and manage business transactions.
We may use aggregated or de-identified information and limited service-usage information to understand performance and improve the Services. ModernGut does not use personal information for advertising, retargeting, or cross-context behavioral advertising at launch.
We may create de-identified or aggregated information and use it for analytics, research, business, product-development, marketing, or other lawful purposes. We will not attempt to re-identify de-identified information except as permitted by applicable law.
We may disclose personal information as described below.
We may disclose personal information to service providers that perform services on our behalf, including Kajabi (website, courses, checkout, email functionality, contacts, and platform reports), Kajabi Payments and Stripe (payment processing), Plausible (cookieless analytics), MailChimp (marketing contact management), and ManyChat (social-media direct-message lead capture). Kajabi's platform service providers may include Wistia, RudderStack, Datadog, Sentry, Cloudflare, and Amazon Web Services.
ModernGut does not sell personal information or consumer health data and does not share personal information or consumer health data for cross-context behavioral advertising. ModernGut does not deploy advertising, retargeting, conversion-tracking, or third-party marketing pixels or tags at launch. If you interact with ModernGut through a social-media platform or direct-message feature, the applicable platform and ManyChat may process information as described in their respective privacy policies and as necessary to provide the interaction you request.
ModernGut may maintain public social media channels where members of the public can comment on posts or interact with ModernGut. Information you post publicly or submit through social media platforms may be visible to others and is also subject to the applicable platform's terms and privacy policies. ModernGut does not control how social media platforms process your information.
If you provide a testimonial and consent to its publication, we may disclose the testimonial along with approved identifying information, such as first name, last initial, city and state, and description of your experience with ModernGut. ModernGut discourages testimonials containing personal health information, before-and-after claims, disease-treatment claims, or misleading typicality claims.
We may access, preserve, or disclose personal information if we believe in good faith that doing so is necessary or appropriate to comply with law or legal process; protect rights, property, or safety; enforce our Terms; detect or prevent fraud, security, or technical issues; investigate suspected or actual illegal activity; collect amounts owed; or complete a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or transition of service.
ModernGut does not currently intend to ask users to provide personal health information through intake forms, questionnaires, quizzes, surveys, assessments, or personalization features. ModernGut also does not provide individualized recommendations based on user responses.
However, because the Services concern digestive health and related healthcare topics, some personal information may relate to or reveal health-related interests. Examples may include course purchase history, course engagement, page views, webinar participation, marketing interactions, or other information associated with health-related educational content.
Depending on applicable law, health-related information may be considered "sensitive personal information," "consumer health data," or another protected category of personal information. ModernGut uses and discloses such information as described in this Privacy Policy and any applicable consumer health data notice or addendum.
Users should not submit personal health information in webinar questions, support requests, social media comments, direct messages, or other communications. If users voluntarily submit health-related information despite those instructions, ModernGut may process that information to respond to the communication, administer the Services, maintain safety and compliance, and otherwise as described in this Privacy Policy.
ModernGut is not intended to be a HIPAA-covered entity or business associate in connection with the Services, and information submitted through the Services may not be subject to HIPAA.
ModernGut is based in California and operates a commercial website and online service. California law may require ModernGut to maintain a conspicuously posted privacy policy describing the categories of personal information collected, the categories of third parties with whom personal information may be shared, the effective date of the policy, the process for material changes, and certain disclosures regarding online tracking.
ModernGut currently expects annual revenue below $25 million and does not expect to collect personal information from 100,000 or more California consumers or households in a year. ModernGut does not currently sell personal information.
California residents may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, if ModernGut meets the applicable statutory thresholds. Nothing in this Privacy Policy is intended to concede that ModernGut is currently subject to the CCPA/CPRA. If and to the extent those laws apply, California residents may have the right to request that ModernGut disclose the categories and specific pieces of personal information it has collected about them, delete certain personal information, correct inaccurate personal information, opt out of certain sales or sharing of personal information, limit certain uses or disclosures of sensitive personal information, and not be discriminated against for exercising their privacy rights.
To exercise any rights that may be available under applicable California privacy laws, residents may contact ModernGut using the contact information provided in this Privacy Policy. ModernGut will review and respond to verifiable consumer requests as required by applicable law, subject to any permitted exceptions or limitations.
Depending on where you live and applicable law, you may have rights regarding your personal information, which may include the right to access or know personal information, request correction, request deletion, request portability, opt out of certain processing such as targeted advertising, sale, or sharing, limit certain uses or disclosures of sensitive personal information, withdraw consent, and appeal certain decisions.
To exercise privacy rights, please contact us using the information in the "Contact Us" section below. We may need to verify your identity before responding to your request. We will not discriminate against you for exercising privacy rights, but some Services may not be available if we cannot process information necessary to provide them.
You may unsubscribe from promotional emails by using the unsubscribe link in the email or contacting us. You may continue to receive transactional, account, security, legal, or administrative communications.
You may be able to manage cookies through your browser or device settings. Some platform and service features may rely on cookies or similar technologies and may not function properly if you disable them. Plausible's analytics service is designed to operate without cookies.
Some browsers may transmit "Do Not Track" signals. Because there is not yet a common industry or legal standard for responding to Do Not Track signals, ModernGut does not currently respond to those signals unless required by law.
This section applies to consumer health data to the extent required by applicable law, including for Washington consumers. "Consumer health data" may include personal information linked or reasonably linkable to you that identifies your past, present, or future physical or mental health status. In connection with ModernGut's digestive-health educational Services, this may include information you voluntarily submit in communications, course purchases and access, course engagement, webinar participation, or interaction with health-related pages or content when linked or reasonably linkable to you.
We collect and use this information to provide and administer the Services you request; process purchases and provide course access; respond to communications and support requests; maintain security, prevent fraud, and debug; comply with law; and otherwise as described in this Privacy Policy. We collect it directly from you, automatically through your use of the Services and Kajabi platform functionality, and from service providers and social-media platforms when you interact with ModernGut through those platforms.
We may disclose consumer health data to service providers that process it on our behalf to provide the Services, including Kajabi, Kajabi Payments and Stripe, MailChimp, ManyChat, Plausible, and Kajabi's platform subprocessors, including Wistia, RudderStack, Datadog, Sentry, Cloudflare, and Amazon Web Services. We do not sell consumer health data, and we do not share consumer health data for cross-context behavioral advertising.
Washington consumers may request to confirm whether ModernGut collects, shares, or sells consumer health data concerning them; access that data; withdraw consent from future collection or sharing where consent is the basis for processing; request deletion; and appeal a refusal to act on a request. To submit a request or appeal, contact us at [email protected]. We may verify your identity before acting on a request and will respond as required by applicable law.
See also our State Consumer Health Data Addendum.
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Services, maintain accounts, process transactions, provide one-year course access, administer refunds, maintain webinar access, comply with legal obligations, resolve disputes, enforce agreements, protect rights and safety, maintain security, conduct audits, and pursue legitimate business purposes.
When personal information is no longer needed, we will delete, de-identify, or aggregate it in accordance with applicable law and our retention practices.
We use reasonable administrative, technical, and physical safeguards designed to protect personal information. However, no method of transmission over the internet or method of electronic storage is completely secure. We cannot guarantee absolute security.
If we learn of a security incident affecting your personal information, we will provide notice as required by applicable law.
ModernGut is based in the United States. If you access the Services from outside the United States, your personal information may be transferred to, stored in, or processed in the United States or other countries where we or our service providers operate. Data protection laws in those countries may differ from the laws where you live.
ModernGut does not currently intend to direct advertising, country-specific domains, local pricing, or localized services to the EU, UK, Canada, or other non-U.S. jurisdictions. ModernGut may receive a small amount of organic international enrollment. If ModernGut later targets users outside the United States or materially expands international enrollment, additional privacy disclosures and compliance measures may be required.
The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, please contact us, and we will take appropriate steps to delete the information if required by law.
The Services may contain links to third-party websites, applications, platforms, payment processors, course-hosting providers, analytics providers, advertising platforms, social media platforms, or other services. We do not control and are not responsible for the privacy practices, security, or content of third-party services. You should review the privacy policies of any third-party services you use.
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice as required by applicable law. The updated Privacy Policy will be effective when posted unless otherwise stated. Your continued use of the Services after the effective date means you acknowledge the updated Privacy Policy.
If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise privacy rights, please contact us at:
Pico Health Inc. d/b/a ModernGut
1301 N Broadway STE 32039
Los Angeles, CA 90012