These "Privacy
Highlights" provide an overview of some core components of our data
handling practices. Please be sure to review the Full Privacy Statement.
Information
We Collect
We generally collect the
following information:
·
Information we receive when you use our Services. We collect Web-Behavior
Information via cookies and other similar tracking technologies when you use
and access our Services (our website, mobile apps, products, software and other
services).
·
Information you share directly with us. We collect and process your information when you
place an order, create an account, register your GenoSolutions kit, complete Clinical Questionnaire, and
contact Customer Care. This information can generally be categorized as
Registration Information, Self-Reported Information, and/or User Content as
defined in our full Privacy Statement.
·
Information from our DNA testing services. With your consent, we extract your DNA from your
buccal swab and saliva sample and analyze it to produce your Genetic
Information (the As, Ts, Cs, and Gs at particular locations in your genome) in
order to provide you with GenoSolutions reports.
How We
Use Information
We generally process Personal
Information for the following reasons:
·
To provide our Services. We process Personal Information in order to provide our Service,
which includes processing payments, shipping kits to customers, creating
customer accounts and authenticating logins, analyzing buccal swab or saliva sample
and DNA, and delivering results.
·
To analyze and improve our Services. We constantly work to improve and provide new
reports, tools, and Services. We may also need to fix bugs or issues, analyze
use of our website to improve the customer experience or assess our marketing
campaigns.
Control:
Your Choices
·
To delete your GenoSolutions account and data, at any time.
Access
To Your Information
Your Personal Information may
be shared information in the following ways:
·
With our service providers, including our genotyping laboratory, as necessary for
them to provide their services to us.
GenoSolutions will not sell,
lease, or rent your individual-level information to any third party or to a
third party for research purposes without your explicit consent.
·
We do not share
customer data with any public databases.
·
We will not provide
any person’s data (genetic or non-genetic) to an insurance company or employer.
·
We will not provide
information to law enforcement or regulatory
authorities unless required by law to comply with a valid court order,
subpoena, or search warrant for genetic or Personal Information.
How We
Secure Information
GenoSolutions implements
measures and systems to ensure confidentiality, integrity, and availability of
GenoSolutions data.
·
De-identification/Pseudonymization, encryption, and data segmentation. Registration Information
is stripped from Sensitive Information, including genetic and phenotypic data.
This data is then assigned a random ID so the person who provided the data
cannot reasonably be identified. GenoSolutions uses industry standard security
measures to encrypt sensitive personal data both when it is stored
(data-at-rest) and when it is being transmitted (data-in-flight). Additionally,
data are segmented across logical database systems to further prevent
re-identifiability.
·
Limiting access to essential personnel. We limit access of information to authorized
personnel, based on job function and role. GenoSolutions access controls
include multi-factor authentication, single sign-on, and a strict
least-privileged authorization policy.
·
Detecting threats and managing vulnerabilities. GenoSolutions uses state
of the art intrusion detection and prevention measures to stop any potential
attacks against its networks. We have integrated continuous vulnerability
scanning in our build pipeline and regularly engage third party security
experts to conduct penetration tests.
Risks
and Considerations
There may be some consequences
of using GenoSolutions Services that you haven't considered.
·
You may discover things about yourself and/or your family members that may
be upsetting or cause anxiety and that you may not have the ability to control
or change.
·
In the event of a data breach it is possible that your data could be
associated with your identity, which could be used against your interests.
Full Privacy Statement
This Privacy Statement applies
to all websites owned and operated by GenoSolutions, Inc ("GenoSolutions"),
including www.genosolutions.net, and any other websites, pages, features,
or content we own or operate, and to your use of the GenoSolutions mobile app
and any related Services. Our Privacy Statement is designed to help you better
understand how we collect, use, store, process, and transfer your information
when using our Services.
Please carefully review
this Privacy Statement and our Terms of Service. By using our
Services, you acknowledge all of the policies and procedures described in the
foregoing documents. If you do not agree with or you are not comfortable with
any aspect of this Privacy Statement or our Terms of Service you should
immediately discontinue use of our Services.
1. Key
Definitions
1.
Aggregate Information: information that has been combined with that of other users and analyzed
or evaluated as a whole, such that no specific individual may be reasonably
identified.
2.
De-identified Information: information that has been stripped of your Registration
Information (e.g., your name and contact information) and other identifying
data such that you cannot reasonably be identified as an individual, also known
as pseudonymized information.
3.
Individual-level Information: information about a single individual's genotypes, diseases
or other traits/characteristics, but which is not necessarily tied to
Registration Information.
4.
Personal Information: information that can be used to identify you, either alone or in
combination with other information. GenoSolutions collects and stores the
following types of Personal Information:
a.
Registration Information: information you provide about yourself when registering for and/or
purchasing our Services (e.g. name, email, address, user ID and password, and
payment information).
b.
Genetic Information: information regarding your genotypes (i.e. the As, Ts, Cs, and Gs at
particular locations in your genome), generated through processing of your buccal
swab or saliva sample by GenoSolutions or by its contractors, successors, or
assignees; or otherwise processed by and/or contributed to GenoSolutions.
c.
Self-Reported Information: information you provide directly to us, including your
disease conditions, other health-related information, personal traits,
ethnicity, family history, and other information that you enter into surveys,
forms, or features while signed in to your GenoSolutions account.
d.
Sensitive Information: information about your health, Genetic Information, and certain
Self-Reported Information such as racial and ethnic origin, sexual orientation,
and political affiliation.
e.
User Content: all information, data, text, software, music, audio, photographs,
graphics, video, messages, or other materials - other than Genetic
Information and Self-Reported Information-generated by users of GenoSolutions
Services and transmitted, whether publicly or privately, to or through
GenoSolutions.
f.
Web-Behavior Information: information on how you use GenoSolutions Services collected through log
files, cookies, web beacons, and similar technologies, (e.g., browser type,
domains, page views).
2.
Information we collect
a. Information you provide
directly to us
i.
Registration Information. When you purchase our Services or create a
GenoSolutions account and register your kit, we collect Personal Information,
such as your name, date of birth, billing and shipping address, payment
information (e.g., credit card) and contact information (e.g. email, phone
number and license number).
ii.
Self-Reported Information. You have the option to provide us with additional
information about yourself through surveys, forms, features and applications.
For example, you may provide us with information about your personal traits
(e.g., height, weight, smoking habit, amount of drinking, depression, stress,
etc.).
iii.
Third party sign in. You may create a GenoSolutions account and/or sign in to our
Services using an account you created with a third party service, such as
Google. If you provide authorization to GenoSolutions, we will collect and use
the information you share with us via that third party service (such as your
email address, name, and date of birth as specified in your third party service
account) in accordance with this Privacy Statement. You are responsible for
managing your credentials for your third party service account, and for
maintaining the security of your third party service account. GenoSolutions
does not have access to the credentials for your third party service account.
If you choose to use third party sign in and you lose access to your
credentials for your third party service account, you may not be able to access
your GenoSolutions account. You may manage authorization for third party sign
in through your GenoSolutions Account Settings or through your third party
service account.
b. Information related to our
genetic testing services
i.
Buccal swab or saliva sample. To use our genetic testing services, you must
purchase, or receive as a gift, a GenoSolutions Personal Genetic Service
testing kit, create an online account and register your kit, and ship your buccal
swab or saliva sample to our third party laboratory. Our laboratory will
extract your DNA from your buccal swab or saliva sample for analysis. Your buccal
swab sample and DNA are destroyed after the laboratory completes its work,
subject to the laboratory's legal and regulatory requirements.
ii.
Genetic Information. Information regarding your genotype (e.g. the As, Ts, Cs,
and Gs at particular locations in your genome), your Genetic Information, is
generated when we analyze and process your buccal swab or saliva sample, or
when you otherwise contribute or access your Genetic Information through our
Services. Genetic Information includes the GenoSolutions results reported to
you as part of our Services, and may be used for other purposes, as outlined in
Section 3 below.
c. Web-Behavior Information
collected through tracking technology (e.g. from cookies and similar
technologies)
We and our third party service
providers use cookies and similar technologies (such as web beacons, tags,
scripts and device identifiers) to:
i.
help us recognize you when you use our Services;
ii.
customize and improve your experience;
iii.
provide security;
iv.
analyze usage of our Services (such as to analyze your interactions with
the results, reports, and other features of the Service);
v.
gather demographic information about our user base;
vi.
offer our Services to you;
vii.
monitor the success of marketing programs; and
viii.
serve targeted advertising on our site and on other sites around the
Internet.
We may receive reports based
on the use of these technologies from third party service providers as de-identified,
Individual-level Information or as Aggregate Information (as described in
section 4.c). We and our third party service providers do not use your
Sensitive Information, such as Genetic Information and Self-Reported Information, for targeted advertising.
d. Other Types of Information
We continuously work to
enhance our Services with new products, applications and features that may
result in the collection of new and different types of information. We will
update our Privacy Statement and/or obtain your prior consent to new
processing, as needed.
3. How
we use your information
GenoSolutions will use and
share your Personal Information with third parties only in the ways that are
described in this Privacy Statement.
a. To
provide you with Services and analyze and improve our Services
We use the information
described above in Section 2 to operate, provide, analyze and improve our
Services. These activities may include, among other things, using your
information in a manner consistent with this Privacy Statement to:
i.
open your account, enable purchases and process payments, communicate with
you, and implement your requests (e.g., referrals);
ii.
enable and enhance your use of our website and mobile application(s),
including authenticating your visits, providing personalized content and
information, and tracking your usage of our Services;
iii.
contact you about your account, and any relevant information about our
Services (e.g. policy changes, security updates or issues, etc.);
iv.
enforce our Terms of Service and other agreements;
v.
monitor, detect, investigate and prevent prohibited or illegal behaviors
on our Services, to combat spam and other security risks; and
vi.
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 performing quality control
activities.
b. To process, analyze and deliver your genetic
testing results
As described above, to receive
results through the Personal Genetic Service, you must create a GenoSolutions
account, register your kit, and submit your buccal swab or saliva sample to our
contracted genotyping laboratory, which processes and analyzes your sample to
provide us with your raw Genetic Information. Once we receive your raw Genetic
Information from the laboratory, we further analyze it to provide you with our
health reports, dependent on the Service purchased. GenoSolutions continuously
works to improve our Services based on our research and product development,
and genetic associations identified in scientific literature. If you are
eligible to receive additional reports or updates in the future, you may be notified
of or may directly access these updates.
Our legal basis for processing
your Sensitive Information for the purposes described above is based on your
consent. You may withdraw your consent at any time by deleting your Account via
your Account Settings, however, the withdrawal of your consent will not affect
the lawfulness of processing based on consent before its withdrawal.
c. To
provide customer support
When you contact Customer
Care, we may use or request Personal Information, including Sensitive Information,
as necessary to answer your questions, resolve disputes, and/or investigate and
troubleshoot problems or complaints. In some instances, we may be required to
process one customer’s Personal Information to resolve another customer’s
dispute or request. For example, if a customer reports behavior that violates
our Terms of Service, we will separately process both customers’ Personal
Information and respond separately to each individual as appropriate. We will
not share your Personal Information with another customer without your consent.
Our legal basis for processing
your Personal Information for the purpose described above depends on the nature
of the customer support request. Our legal basis can be to satisfy our
contractual or legal obligations and/or our legitimate interest to improve our
Services.
d. To
provide you with marketing communications
By creating a GenoSolutions
account, you are agreeing that we may send you product and promotional
emails or notifications about our Services, and offers on new products,
services, promotions or contests. By creating a GenoSolutions account, you are
agreeing that we may send you. You can unsubscribe from receiving these
marketing communications at any time. If you want to opt out of marketing
communications, please email GenoSolutions(info@genosolutions.net).
4.
Information we share with third parties
a. General service providers.
We share the information
described above in Section 2 with our third party service providers, as
necessary for them to provide their services to us and help us perform our
contract with you. Service providers are third parties (other companies or
individuals) that help us to provide, analyze and improve our Services. While
GenoSolutions directly conducts the majority of data processing activities
required to provide our Services to you, we engage some third party service
providers to assist in supporting our Services, including in the following
areas:
i.
Order fulfillment and shipping. Our payment processor processes certain
Registration Information, such as your billing address and credit card
information, as necessary to enable you to purchase a GenoSolutions kit from
the GenoSolutions.com online store. Our distribution centers ship your kit(s)
to you, and in some cases help return your kit safely to our third party
laboratory so your sample can be processed.
ii.
Customer Care support. Our Customer Care team uses a number of tools to help organize and
manage the requests we receive. These tools help to ensure we provide timely,
high quality support.
iii.
Cloud storage, IT, and Security. Our cloud storage providers provide secure
storage for information in GenoSolutions databases, ensure that our
infrastructure can support continued use of our Services by GenoSolutions
customers, and protect data in the event of a natural disaster or other
disruption to the Service. Our IT and security providers assist with intrusion
detection and prevention measures to stop any potential attacks against our
networks. We have these third party experts perform regular penetration tests
and periodically audit GenoSolutions’s security controls.
iv.
Marketing and analytics. When you use our Services, including our website or mobile app(s),
our third party service providers may collect Web-Behavior Information about
your visit, such as the links you clicked on, the duration of your visit, and
the URLs you visited. This information can help us improve site navigability
and assess our Marketing campaigns. Per applicable data protection regulations,
our International websites present visitors with a cookie opt in to allow the
processing described above via Functionality and Advertising Cookies.
NOTE: Our service providers
act on GenoSolutions's behalf. We implement procedures and maintain contractual
terms with each service provider to protect the confidentiality and security of
your information. However, we cannot guarantee the confidentiality and security
of your information due to the inherent risks associated with storing and
transmitting data electronically.
b.
“Targeted advertising” service providers
We permit third party advertising networks and
providers to collect Web-Behavior Information regarding the use of our Services
to help us to deliver targeted online advertisements ("ads") to you.
They use cookies and similar technologies, to gather information about your
browser's or device's visits and usage patterns on our Services and on other websites
over time, which helps to better personalize ads to match your interests, and
to measure the effectiveness of ad campaigns. For more information about our
marketing practices, please review our Cookie Policy.
c. Aggregate
information
We may share Aggregate Information, which is
information that has been stripped of your name and contact information and
combined with information of others so that you cannot reasonably be identified
as an individual, with third parties. This Information is different from
"Individual-level" information and is not Personal Information
because it does not identify any particular individual or disclose any
particular individual’s data. 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. In contrast, Individual-level Genetic
Information or Self-Reported Information consists of data about
a single individual's genotypes, diseases or other traits/characteristics
information and could reveal whether a specific user has a particular genetic
trait, or consist of all of the Genetic Information about that user.
GenoSolutions 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.
d. Information
we share with commonly owned entities
We may share some or all of your Personal Information with
other companies under common ownership or control of GenoSolutions, which may
include our subsidiaries, our corporate parent, or any other subsidiaries owned
by our corporate parent in order to provide you better service and improve user
experience. Generally, sharing such information is necessary for us to perform
on our contract with you. We may provide additional notice and ask for your
prior consent if we wish to share your Personal Information with our commonly
owned entities in a materially different way than discussed in this Privacy
Statement.
e. As
required by law
Under certain circumstances your Personal Information
may be subject to processing pursuant to laws, regulations, judicial or other
government subpoenas, warrants, or orders. For example, we may be required to
disclose Personal Information in coordination with regulatory authorities in
response to lawful requests by public authorities, including to meet national
security or law enforcement requirements. GenoSolutions will preserve and
disclose any and all information to law enforcement agencies or others if
required to do so by law or in the good faith belief that such preservation or
disclosure is reasonably necessary to: (a) comply with legal or regulatory
process (such as a judicial proceeding, court order, or government inquiry) or
obligations that GenoSolutions may owe pursuant to ethical and other
professional rules, laws, and regulations; (b) enforce the
GenoSolutions Terms of Service and other policies; (c) respond to
claims that any content violates the rights of third parties; or (d) protect
the rights, property, or personal safety of GenoSolutions, its employees, its
users, its clients, and the public. View our Transparency Report for
more information.
f. Business
transactions
In the event that
GenoSolutions goes through a business transition such as a merger, acquisition
by another company, or sale of all or a portion of its assets your Personal
Information will likely be among the assets transferred. In such a case, your
information would remain subject to the promises made in any pre-existing
Privacy Statement.
5. Your
choices
a. Access
to your account
We provide access to your
GenoSolutions data within your GenoSolutions account. You can access and
download data processed by GenoSolutions within your Account Settings and
within applicable Reports, Tools, and features. If you lose access to your
GenoSolutions account or account email address, please contact Customer Care for
assistance. If you lose access to your GenoSolutions account, in certain
circumstances, we may require that you submit additional information sufficient
to verify your identity before providing access or otherwise releasing
information to you. If you choose not to submit the required documentation, or
the information provided is not sufficient for the purposes sought,
GenoSolutions will not be able to sufficiently verify your identity in order to
complete your request.
You may access, correct or
update most of your Registration Information on your own within your
Account Settings.
b. Sharing outside of
the GenoSolutions Services
In general, it can be
difficult to contain or retrieve Personal Information once it has been shared
or disclosed. GenoSolutions will have no responsibility or liability for any
consequences that may result because you have released or shared Personal Information
with others. Likewise, if you are reading this because you have access to the
Personal Information of a GenoSolutions customer through a multi-profile
account, we urge you to recognize your responsibility to protect the privacy of
each person within that account. Users with multi-profile accounts (i.e., where
multiple family members register their kits to one account) should use caution
in setting profile-level privacy settings.
c. Account deletion
If you no longer wish to
participate in our Services, or no longer wish to have your Personal
Information be processed, you may delete your GenoSolutions account and
Personal Information within your Account Settings. Once you confirm your
request to delete your account and data, your account will no longer be
accessible while we process your request. Once you confirm your request, this
process cannot be cancelled, undone, withdrawn, or reversed. When your account
is deleted, all associated Personal Information is deleted and any stored
samples are discarded, subject to the following limitations:
i.
Legal Retention Requirements. GenoSolutions and our third party genotyping
laboratory will retain your Genetic Information, date of birth, and sex as
required for compliance with applicable legal obligations. GenoSolutions will
also retain limited information related to your account and data deletion
request, including but not limited to, your email address, account deletion
request identifier, and record of legal agreements for a limited period of time
as required by contractual obligations, and/or as necessary for the
establishment, exercise or defense of legal claims and for audit and compliance
purposes.
6.
Security measures
GenoSolutions takes seriously
the trust you place in us. GenoSolutions implements physical, technical, and
administrative measures to prevent unauthorized access to or disclosure of your
information, to maintain data accuracy, to ensure the appropriate use of
information, and otherwise safeguard your Personal Information.
·
GenoSolutions produces secure applications by design. GenoSolutions
incorporates explicit security reviews in the software development lifecycle,
quality assurance testing and operational deployment.
·
De-identification/Pseudonymization. Registration Information is stripped from
Sensitive Information, including Genetic and Self-Reported Information. This
data is then assigned a randomly generated ID so an individual cannot
reasonably be identified.
·
Encryption. GenoSolutions
uses industry standard security measures to encrypt Sensitive Information both
at rest and in transit.
·
Separation of Environments. GenoSolutions ensures processing, production, and
research environments are separated and access is restricted. Data, including
Registration Information, Genetic Information, and Self-Reported Information
are segmented across logical database systems to further prevent
re-identifiability.
·
Limiting access to essential personnel. We limit access to Personal Information to
authorized personnel, based on job function and role. GenoSolutions access
controls include multi-factor authentication, single sign-on, and strict
least-privileged authorization policy.
·
Detecting threats and managing vulnerabilities. GenoSolutions uses state
of the art intrusion detection and prevention measures to stop any potential
attacks against its networks. We have integrated continuous vulnerability
scanning in our processes and regularly engage third party security experts to
conduct penetration tests.
·
Incident Management. GenoSolutions maintains a formal incident management program
designed to ensure the secure, continuous delivery of its Services.
·
Managing third party service providers. GenoSolutions requires service providers to
implement and maintain accepted industry standard administrative, physical and
technical safeguards to protect Personal Information.
Your
Responsibility. Please
recognize that protecting your Personal Information is also your
responsibility. We ask you to be responsible for safeguarding your password,
secret questions and answers, and other authentication information you use to access
our Services. You should not disclose your authentication information to any
third party and should immediately notify GenoSolutions of any unauthorized use
of your password. GenoSolutions cannot secure Personal Information that you
release on your own or that you request us to release.
Your information collected
through the Service may be stored and processed in the United States or any
other country in which GenoSolutions or its subsidiaries, affiliates or service
providers maintain facilities and, therefore, your information may be subject
to the laws of those other jurisdictions which may be different from the laws
of your country of residence.
7.
Children's privacy
GenoSolutions is committed to
protecting the privacy of children as well as adults. Neither GenoSolutions nor
any of its Services are designed for, intended to attract, or directed toward
children under the age of 18. A parent or guardian, however, may collect a buccal
swab or saliva sample from, create an account for, and provide information
related to, his or her child who is under the age of 18. The parent or guardian
assumes full responsibility for ensuring that the information that he/she
provides to GenoSolutions about his or her child is kept secure and that the
information submitted is accurate.
8.
Linked websites
GenoSolutions provides links
to third party websites operated by organizations not affiliated with
GenoSolutions. GenoSolutions does not disclose your information to
organizations operating such linked third party websites. GenoSolutions does
not review or endorse, and is not responsible for, the privacy practices of
these organizations. We encourage you to read the privacy statements of each
and every website that you visit. This Privacy Statement applies solely to
information collected by GenoSolutions and our service providers on our behalf.
9.
Changes to this Privacy Statement
Whenever this Privacy
Statement is changed in a material way, a notice will be posted as part of this
Privacy Statement and on our website for 30 days. After 30 days the changes
will become effective. In addition, all customers will receive an email with notification
of the changes prior to the change becoming effective. GenoSolutions may
provide additional "just-in-time" disclosures or additional
information about the data collection, use and sharing practices of specific
Services. Such notices may supplement or clarify GenoSolutions’s privacy
practices or may provide you with additional choices about how GenoSolutions
processes your Personal Information.