Genebase Systems Inc. and its testing laboratories and affiliates (collectively “Genebase”, “us”, “we”, or “our”) are committed to respecting and protecting your privacy and personally identifiable information (“Personal Information”). This Privacy Policy describes how your Personal Information is collected, used, and shared in connection with your access and use of www.genebase.com and its subdomains (collectively, the “Site”), including any services and functionality offered by us through the Site (collectively, the “Services”). Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in our other policies (e.g., our Terms of Use Agreement). By visiting, accessing, or using the Site or Services, you consent to the collection and use of your Personal Information in accordance with the Terms of Use Agreement and this Privacy Policy. We reserve the right to amend, supplement, or otherwise change this Privacy Policy, at any point and for any reason. Any changes to this Privacy Policy will be in effect as of the “Last Updated” date referenced above. We encourage you to review this Privacy Policy from time to time to be informed of how we are protecting your information. If you do not agree to a change, you may terminate your Site account and/or discontinue your use of the Services. Your continued use of the Site or Services after the “Last Updated” date will constitute your acceptance of this Privacy Policy and such changes.
1. Collecting Your Personal Information
This Privacy Policy applies to all Personal Information collected about you when you access the Site and use our Services, including, but not limited to, your name, email address, mailing address, telephone number, registration information, and information defined as “Protected Health Information” under the Health Insurance Portability and Accountability Act (“HIPAA”) regulations. When you visit, use, or navigate the Site, we automatically collect certain information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the Site and other technical information. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes. We may use cookies, web beacons, local shared objects, and similar technology in connection with your use of the Site (“Cookies”). Cookies may have unique identifiers, and reside, among other places, on your computer, and on our web pages. Cookies may transmit information about you and your use of the Site, such as your browser type. You can disable some (but not all) Cookies in your device or browser settings but doing so may affect your ability to use the Site.
2. How We Use Your Personal Information
We may use your information for a number of purposes including:
- to provide you with our Services that you request, such as to facilitate the transfer of your biological sample(s) to the laboratories for analysis;
- to assist you with your questions about our Services;
- to contact you about the administration of any functions of the Site or Services that you use;
- to respond to subsequent requests you may make of us;
- to carry out our obligations arising from any contracts entered into between you and us;
- to resolve disputes, investigate and help combat spam, malware, malicious activities or security risks;
- to notify you of any changes to our Site, Services, or policies;
- to use your de-identified information to help us administer, support, and improve our business;
- for healthcare operations;
- to comply with applicable laws and regulations;
- to assist in enforcing our Terms of Use and policies; and
- for any other purpose which are reasonably necessary to provide the Services that you have requested or consented to.
We have not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell personal information in the future belonging to website visitors, users and other consumers.
3. Disclosure of Your Personal Information
We may share your Personal Information with service providers, Health Consultants, laboratories, partners, and other trusted third parties where it is necessary to provide the Services that you have requested or consented to, or for other purposes as described in this Privacy Policy. These agents, contractors or partners are restricted to only access your Personal Information to perform tasks required for the Services, and are obligated to not use or disclose your Personal Information for any other purpose. We may be required to disclose your Personal Information if we believe that is reasonably necessary to: (a) respond to and comply with applicable local, state or federal laws and regulations (e.g. in response to a court order or subpoena); (b) protect the rights, property and safety of Genebase, its employees, its users, and the public; (c) enforce the agreements entered into between you and Genebase; and (d) investigate, prevent and address fraud and other illegal activity, security, or technical issues.
4. Storing Your Personal Information
The information that we collect from you may be transferred to, and stored at, a destination outside of your country of domicile. It may also be processed by our staff and affiliates operating outside of your country of domicile, who may be engaged in, among other things, the fulfilment of any requests and the provision of support services. The Personal Information you provide to us may be stored on our servers or those of our third-party service providers. By submitting your Personal Information, you agree to this transfer, storing or processing. We take steps we believe reasonably necessary so that your Personal Information is treated securely and in accordance with this Privacy Policy. If you no longer wish to access or use our Services, you may contact us at privacy@genebase.com to request the deletion of your Account and associated Personal Information. Upon receipt of your request, Genebase will verify your identity and delete your Account and associated Personal Information, except to the extent applicable law requires the retention of such information.
5. Do Not Track Disclosure
Most web browsers, such as Google Chrome, Firefox, Safari, and Internet Explorer, include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we currently do not change our tracking practices in response to the DNT settings in your web browser. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy. Our third party partners, such as web analytics companies, collect information about your online activities over time and across the Site. These third parties may not change their tracking practices in response to the DNT settings in your web browser, and we do not obligate these parties to honor these settings.
6. Data Security
We follow industry standards on information security technologies and procedures to help protect your sensitive information from unauthorized access, use or disclosure. We secure your personal data on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When sensitive information is collected on our Site and/or transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol. However, no method of transmission over the internet or method of electronic storage is 100% secure. Even though we strive to provide the most secure environment for the processing of your personal data, we cannot completely rule out the possibility of unauthorized access, use or disclosure. In the case of such a personal data breach, we will inform the competent supervisory authority without undue delay and act swiftly to address the situation. If the personal data breach is likely to harm you, we will also inform you about the personal data breach without undue delay.
7. Children’s Privacy
We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Site. In addition, the Services are not directed to individuals under 18 years of age, and we request that they not provide Personal Information through the Services. We do not knowingly collect, maintain, or use Personal Information from children under 18 years of age. If we learn that Personal Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@genebase.com, and we will take steps to immediately delete that information.
8. Information for California Residents
This section applies only to California residents. The California Code of Regulations defines a “resident” as:
- every individual who is in the State of California for other than a temporary or transitory purpose and;
- every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
This section describes how we collect, use and share Personal Information of California residents online and offline in our capacity as “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. This section does not apply if we do not collect any Personal Information about you, or if the Personal Information we collect is not subject to the CCPA (for example, CCPA does not apply to the protected health information governed by HIPAA). We may have collected the following statutory categories (as defined by CCPA) of Personal Information in the past twelve (12) months:
- identifiers such as name, address, unique personal identifier, email address, phone number, Internet Protocol address, or other similar identifiers;
- personal information categories listed in the California Customer Records statue, such as name, signature, address telephone number, credit card number, debit card number, or medical information. (Some Personal Information included in this category may overlap with other categories).
- protected classification characteristics under California or federal law, such as gender, age, race, national origin, ancestry, sex (including gender, pregnancy, sexual orientation, and gender identity), genetic information, and medical condition);
- commercial information such as records of products or services purchased, obtained, or considered by you;
- internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction on the Site; and
- inferences such as information about your interests, preferences, and favorites, and the “profile” we create with such information.
We may use or disclose your Personal Information for the business purposes listed in the “How We Use Your Personal Information” section of this Privacy Policy. The categories of third parties with whom we may share your Personal Information are listed in the “Disclosure of Your Personal Information” of this Privacy Policy. As a California resident, you may exercise the following CCPA rights listed above as follows:
- Right Against Discrimination: You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
- Right to Know: You have the right to request access to the specific pieces of Personal Information we have collected about you during the twelve (12) months before your request.
- Right to Delete: You have the right to request us to delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
You may request a notice from us describing what categories of Personal Information (if any) we have shared with third parties during the preceding calendar year. You may request such notice once a year and free of charge. In accordance with California law, we take reasonable precautions to verify the identities of those California residents submitting CCPA requests, or to learn more about how their Personal Information is processed. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. To make a CCPA request, please send us an Email at privacy@genebase.com with subject line “California Shine The Light Request” so that we can process your request. Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For example, we may ask you to provide certain information so that we can match the information you provide with the information we already have stored. We may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as where applicable.
9. Geographical Restriction
Unless expressly and specifically stated otherwise on the Site, the Site and Services are intended for use solely within the United States and is directed to users solely located in the United States. We make no representation that the Site and Services are appropriate or available for use in locations outside the United States or all territories within the United States. Those who choose to access the Site from other locations are responsible for compliance with local laws. We reserve the right to limit, in our sole discretion, the provision of any feature, product, or service to any person from other geographic areas.
10. Contact Us
If you have any questions, comments, or requests regarding this Privacy Policy, please contact our Data Protection Officer at privacy@genebase.com.
