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GenoTypica, LLC
Privacy Policy

Last modified: June 22, 2023

Introduction

GenoTypica, LLC (the "Company" or "We") provides genome analysis and related research services, related products, services and content though the Company’s website, www.genotypica.com (the “Website”). The Company is committed to protecting your privacy and ensuring your data is collected in a responsible manner which is secured by organizational standards and safeguards. This Statement of Privacy applies to the Company's website, www.genotypica.com ("Website"), and governs data collection and usage.

This privacy policy has been compiled to better communicate how We describe the data We collect in providing our Services. Below are key definitions pertaining to the Company and the use of data:

  1. "Personally identifiable information" ("PII") is being collected and used. PII, as used in United States privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.
  2. “Biometric Data” as used in United States privacy law and information security, is information that identifies and individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other identifying data.
  3. “De-identified Information” as used in United States privacy law and information security, is information which has been stripped of all linking data such as name, or other contact information making the data collected untraceable to any individual.
  4. “Genetic Information” is information collected by the Company that comprises the DNA code of your genes. When you complete a sample, the Company utilizes techniques to isolate DNA from the sample setting forth a genomic analysis that identifies your genotype.
  5. “Self-Reported Information” is the information you provide to us, either through the Services or through a third-party and other information about you that you enter into surveys, forms or features while submitting a sample to us or that you authorize a third-party to provide to us.
  6. “Services” as used herein refers to the Company’s products, software, services, apps and Website (including text, graphics, images and other material) as accessed from time to time by you.
  7. PII, Biometric Data, Genetic Information, and Self-Reported Information is collectively referred to as “Personal Information.”

Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your PII, Biometric Data, and De-identified information in accordance with our Website. By using the Website, you consent to the data practices described in this privacy policy.

This policy applies to information we collect:

  • On the Website;
  • In email, text, and other electronic messages between you and the Website;
  • Through any mobile and/or desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website; and
  • When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Use offline or through any other means, including on any other website operated by the Company or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on 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, you must not access the 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 Section below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this policy periodically for updates.

Children Under the Age of 18

In compliance with federal and state law, we require parental or legal guardian consent to collect samples from users who are under the age of 18. If we learn we have collected or received PII or Biometric Data from an individual under the age of 18 without parental or legal guardian consent, we will promptly delete all information and destroy the sample provided.

HIPAA and GINA

The Company shall comply to the extent applicable with the 1996 Health Insurance Portability and Accountability Act (HIPAA) and the 2008 Genetic Information Nondiscrimination Act (GINA).

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number and any other identifier by which you may be contacted online or offline; provided, however, that users are only required to submit an e-mail address and answer some general non-identifiable questions to use the Company’s Services;
  • that is about you, but individually does not identify you;
  • your biometric information contained in a specimen which you submit; and/or
  • about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us;
  • By analyzing genetic information contained in cheek cell samples submitted by you; and/or
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

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, purchasing or subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website or seek support from Customer Service.
  • 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.
  • Your search queries on the 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, logs, 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.

The information we collect automatically is statistical data and may 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.
  • 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.
  • Web Beacons. Pages of our Website and our e-mails 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).
  • Google Analytics. We use Google Analytics, including Google Analytics Demographics and Interest Reporting to collect information about our Website users. This data helps us make informed website improvements and make the website more useful to you. The types of information collected may include the date and time of your visit; the website pages that you view; the address of the website you came from prior to your visit to the Website; and your age, gender and interests (as indicated by Google). Using Google Ad Settings you may opt out of Analytics for Display Advertising and customize Google Display Network ads. You may also use Google Analytics’ currently available opt-outs for the web. For additional details on Google’s own Privacy Policy, please visit https://policies.google.com/privacy?hl=en.

Third-Party Use of Cookies and Other Tracking Technologies

We use Google Ads to advertise our Services across the Internet. Google Ads remarketing will display relevant advertisements tailored to you based on what parts of the Website you have viewed by placing a cookie on your computer or device. This cookie does not in any way identify you or give access to your computer or device. The cookie is used to say, "this person visited this page, so show them advertisements relating to that page." Google Ads remarketing allows us to tailor our marketing to better suit your needs and only display advertisements that are relevant to you. For additional details on Google’s own Privacy Policy and how you can opt out of Google's use of cookies, please visit https://policies.google.com/privacy?hl=en.

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.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • 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 Services we offer or provide through it.
  • To allow you to participate in interactive features on our Website.
  • To analyze and improve our Services.
  • In any other way we may describe when you provide the information.
  • For Company’s internal research purposes, with your consent. If you choose to consent to participate in research, our researchers can include your de-identified Genetic Information and Self-Reported Information in a large pool of de-identified customer data for analyses aimed at making scientific discoveries.
  • For any other purpose with your consent.

Disclosure of Your Information

We may share your personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To our service providers, allowing them to provide their services to us.
    • NOTE: Our service providers act on GenoTypica’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.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.

We will not sell, lease, or rent your individual-level information to a third party for any reason. We will not provide any person’s data (genetic or non-genetic) to an insurance company or employer.

We may disclose your personal information:

  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce or apply our 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 the Website, our users, our customers, or others.

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 Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

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.

Accessing and Correcting Your Information

You may also send us an email at support@genotypica.com to request access to, correct or delete any personal information that you have provided to us. 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.

Additional Privacy Rights for Residents of Certain States

California, Colorado, Connecticut, Utah and Virginia have enacted laws which permit users of our Website that are residents in these respective states 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 support@genotypica.com

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions and biometric information will be encrypted using SSL technology. We regularly review security practices and update to match industry standards. We limit access to biometric information to essential personnel.

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.

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. IN THE EVENT OF DATA OR INFORMATION COMPROMISE, GENOTYPICA LLC WILL PROMPTLY ATTEMPT TO NOTIFY YOU IN COMPLIANCE WITH FEDERAL AND STATE LAW.

Your information collected through the Website may be stored and processed in the United States or any other country in which GenoTypica 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.

UK Resident Additional Privacy Statement

Residents of the United Kingdom have the following rights under the General Data Protection Regulation (GDPR) and certain other privacy and data protection laws, as applicable:

Right to Access The right to be provided with a copy of your personal information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your personal information
Right to be Forgotten The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object The right to object:
  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

US Resident Additional Privacy Statement

Residents of California, Colorado, Connecticut, and Virginia have the following rights, to exercise free of charge, under the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Virginia Consumer Data Protection Act (“VCDPA”):

Disclosure of Personal Information We Collect About You You have the right to know:
  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.
Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale [or disclosure] of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale [or disclosure] of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: [URL].
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your personal information.

Sensitive Personal Information. We process sensitive personal information collected about you only to provide the Services, including to:

  • Maintain the quality and safety of the Services;
  • Improve the Services;
  • Detect security incidents;
  • Resist and prosecute malicious, deceptive, fraudulent, or illegal actions directed at GenoTypica, and;
  • Maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide analytic services, and provide storage.

We may also process this sensitive personal information as needed to help ensure people’s physical safety and as required by applicable law.

Non-discrimination. We will not discriminate against you for exercising any of your rights under applicable US privacy regulations.

How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please:

  • Call us, at 402-858-7290; or
  • Email us at support@genotypica.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by phone or email, you will need to provide us with:

  • Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this 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.