Effective Date: May 1st, 2017
1. Effective Date; Changes. This Policy applies to all information collected by or provided to us in connection with the Service. When we make any material changes to this Policy, we will change the Effective Date above and will inform you by e-mail sent to the address associated with your Service account and/or through the Service the next time you login. We will treat your continued use of the Service following such notice as your acceptance of the changes.
2. Third Parties. The Service may contain, and we may send to registered users, offers from third parties or links to third-party websites to the extent of your consent. This Policy does not apply to information that you may provide to or that may be collected by third parties. We encourage you to request that such third parties provide you with their applicable privacy policies and other terms and conditions before engaging with or making a purchase from such third parties.
3. Collected Information.
Information You Submit.
- User Materials. We collect such information as you transmit or upload through or in connection with the Service, including, any information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials - other than Genetic Information and Self-Reported Information-generated by you and transmitted, whether publicly or privately, to or through the Service (collectively, “User Materials”).
- Registration Information. When you log-in to or create an account with the Service, we collect the information you provide in the applicable form. This information includes personally identifiable information such as your name, username, e-mail address and password (“Registration Information”). When we refer to “personally identifiable information” in this Policy, we mean information that we can directly associate with a specific person or entity without additional information. To the extent you decline to share certain personally identifiable information with us, we may not be able to provide some or all of the features and functionalities found on the Service.
- Genetic Information. When you use our Screening Service (as defined in our Terms of Service), we collect information regarding your genotype, generated through processing of your saliva or blood (as applicable) sample by us or by our contractors, successors, or assignees; or otherwise processed by and/or contributed to us (“Genetic Information”).
- Self-Reported Information. We also collect information you provide on our Informed Consent form and other forms available on or through the Service, including, without limitation, all information about yourself, including your disease conditions, health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your Service account.
- Sensitive Information. Genetic Information, information about your health and certain Self-Reported Information such as racial and ethnic origin and sexual orientation which we collect in connection with the Service is referred to herein as “Sensitive Information.”
Information Collected Automatically. When you use the Service, we automatically gather certain non-personally identifiable information from you. This includes usage information, such as information on when, how often and for how long you use the Service and the content you submit and view. This also includes server log data such as the IP address or operating system, or the webpage you were visiting before you came to our Service (collectively, “Web Behavior Information”). As described below, we collect this information through a number of means, including server logs, cookies and other online tracking mechanisms. We may associate such non-personally identifiable information with the personally identifiable information that you provide in connection with the Service. But if we do so, we will treat the combined information as personally identifiable information.
Analytics Services. We use third party analytics services to help us analyze usage of our Service. Through this, such third parties receive certain information regarding your usage of the Service.
Social Networking Information. You may create a Service account by logging in through a social networking service such as Facebook (such sites, “Social Apps”). Integration with Social Apps allows you to automatically populate your Service profile with information and content from your Social Service account profile, to invite your Social Service connections to join the Service. It also may allow us to better target our advertising within such Social Apps (to the extent enabled by the applicable Social Service). Additionally, we may use unique identifiers available from Social Apps to track your usage of that Social App with respect to the Service. We will use, store and disclose such information and content in accordance with this Policy. Please remember that the manner in which Social Apps use, store and disclose your information and content (including with respect to any choices you may have to limit or control disclosure to us) is governed by the terms and conditions and privacy policies of each Social Service and any applicable privacy settings you may be able to control, and not the Company.
4. Use of Information.
We use the personally identifiable and non-personally identifiable information that we collect about you as follows:
- We will use submitted information for the purposes for which you provided the information, including, for example, to create and maintain a Service account for you or respond to a question that you e-mail to us. We also use submitted information and collected information as necessary to provide the features and functionality of the Service to you.
- We may send you e-mails regarding updates or modifications to the Service.
- We use submitted information and collected information to personalize the content that you and others see based on personal characteristics or preferences.
- We may analyze collected information relating to your use of the Service in order to help us improve the Service.
- We may use submitted information and collected information to help troubleshoot problems, provide you with required notices, enforce our Terms of Service or to alert you to changes in our policies or agreements that may affect your use of the Service.
- We may combine personally identifiable information collected through the Service with other information that we collect about you in other contexts—such as our communications with you via e-mail, phone or postal mail. We will handle such combined information in accordance with this Policy.
- We use submitted information to process and deliver your genetic testing results;
- We use submitted and collected information to perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and to perform quality control activities.
You may be able to opt-in, opt-out or otherwise adjust your preferences of having your information used for certain of these activities.
5. Disclosure of Information.
We disclose the personally identifiable and non-personally identifiable information that we collect about you as follows:
- We may provide advertisers and other third parties with aggregated, non-personally identifiable information about our user base and its usage patterns.
- The Company uses contractors and third-party service providers to provide the Service to our users and help us understand the use of the Service. These contractors and third-party service providers may collect information sent through the Service for use on our behalf. For example, we work with third-party laboratories and contractors to process and analyze your saliva or blood (as applicable) sample for purposes of generating your Genetic Information. NOTE: Our service providers act on our behalf. While we implement procedures and contractual terms to protect the confidentiality and security of your information, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.
- We may report aggregated data relating to activity on the Service to third parties or the general public. This is any information that has been stripped of your Registration Information (e.g., your name and contact information) and aggregated with information of others so that you cannot reasonably be identified as an individual ("Aggregate Information"). We may combine such data with data obtained from third-party sources in order to generate such reports. This Aggregate Information is different from "individual-level" information. Individual-level Genetic Information or Self-Reported Information consists of data about a single individual's genotypes, diseases or other traits/characteristics information. For example, Aggregate Information may include a statement that "30% of our female users share a particular genetic trait," without providing any data or testing results specific to any individual user. We may provide such Aggregate Information in commercial arrangements with our business partners. In contrast, individual-level Genetic Information could reveal whether a specific user has a particular genetic trait, or all of the Genetic Information about that user. We will ask for your consent to share individual-level Genetic Information or Self-Reported Information with any third-party, other than our service providers as necessary for us to provide the Services to you.
- We will use and disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so; to investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our terms and conditions; or in other circumstances where we believe is necessary to protect the rights, safety or property of Company, our users, and third parties.
6. Viewing and Amending Information. You can log into your Service account and view or amend your user account information at any time. Please note that while changes to your account information are reflected promptly in active user databases, our servers may retain previously provided information. Note that changes to, or deletion of, your Service account user information does not affect any other information collected by the Company, which the Company may retain and continue to use or disclose in accordance with this Policy.
7. Choices Regarding Third-Party Offers. To the extent we send you commercial e-mails regarding third-party marketing or promotional materials, we will give you the ability to opt-out of receiving such e-mails in accordance with applicable law. We will not provide your personally identifiable information to third parties for their own marketing purposes without your consent.
8. Online Behavioral Advertising. The Service may enable third-party tracking mechanisms to collect your non-personally identifiable information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Service to send online ads for Company services to you on non-Company websites. For information about such practices and your choices, visit the Network Advertising Initiative website at http://www.networkadvertising.org/understanding-online-advertising or the Digital Advertising Alliance website at http://www.aboutads.info.
The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out at http://www.networkadvertising.org/choices/, or of companies participating in the Digital Advertising Alliance program by opting out at http://www.aboutads.info/choices.
9. Security. The personally identifiable information we collect about you is stored in limited access servers. We will maintain reasonable safeguards to protect the security of these servers and your personally identifiable information. However, no security measures are 100% effective and we cannot guarantee the security of your personally identifiable information.
10. Transfer As Corporate Asset. In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Company, the information we possess (including personally identifiable information) shall be transferred as a corporate asset to the acquiring entity, provided that such entity will continue to handle such information in accordance with this Policy.
11. Transfer to the U.S. or other Countries. The Company is established in and uses facilities in the United States. Your information will be stored and processed in the United States or other countries where Company has facilities. By using the Service, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards.
12. Children Under 13. The Company does not knowingly collect information from children under 13 and the Service is intended for adults over the age of 18. If you are a parent and believe that your child under the age of 13 has used the Service and provided personally identifiable information to us through the Service, please contact us at firstname.lastname@example.org and we will work to delete that Service account and any such personally identifiable information.