Privacy Policy

Last Updated: April 30, 2020

Introduction. The privacy of our users (“you” or “User”) is important to us. IDbyDNA Inc., and its subsidiaries and affiliates (“IDbyDNA”, “we”, “our” or “us”), has created this Privacy Policy (the “Policy”) to let you know how Personal Information is collected and further processed when you visit our website, idbydna.com (the “Website”), and use the IDbyDNA services that are operated via the Website and via our platforms and apps, including but not limited to the Explify Platform (the “Platform”) and the Explify RVOP app (the “App”), available in Illumina, Inc.’s BaseSpace Sequence Hub (together with the Website, our “Services”).

 

Please read this Policy carefully so that you understand your rights in relation to your Personal Information, and how we will collect, use and process your Information and how you can contact us if you have any questions or concerns. By using the Services you agree to the use of your Personal Information as described in this Policy. If you do not agree with this Policy or any part thereof, you should not access or use any part of the Services. If you change your mind in the future, you must stop using the Services and you may exercise your rights in relation to your Information as set out in this Privacy Policy.

 

What Information Is Collected?

In this Policy, “Personal Information” means any information related to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).

 

We collect Personal Information about you from the different sources listed below:

 

A. Information You Provide to Us

 Registration Information. IDbyDNA collects the following Personal Information from you when you register to use our Services: your first and last name, email address, organization, and optionally your phone number and any other information we collect. If you use the App, we will also collect your BaseSpace user ID, session ID, and authentication token.

 

Communications. If you contact us directly, we will receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.

 

Biological Data. Some of our Services facilitate the transfer of Biological Data from our Users to IDbyDNA. We collect Biological Data from our Users’ end users sent to us by our Users through collection kits or data files submitted via the Platform or the App. We use this information only to provide services to our Users, to improve our products and services, and to publish aggregated, anonymized reports. Biological Data submitted to us shall not include any additional data, such as date of birth, name or patient ID.

 

Careers. If you decide that you wish to apply for a job with us, you may contact us through the link available on the Website. We will collect the information you choose to provide such as your name, contact information, and education and employment experience. If you are considered for a job with us, we will collect further information from you including your resume, and any information you choose to provide and that is generated about you as part of the interview process.

 

B. Information We Collect When You Use Our Services

Location Information. When you use our Services, we may infer your more general location information (for example, your IP address may indicate your more general geographic region).

 

Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type and server logs, operating system version, application installations, device identifiers, and advertising identifiers.

 

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with and use of our Services, like the dates and times of your use of our Services.

 

Information from Cookies. We and third party partners collect information using cookies, pixel tags, or similar technologies (“cookies”) (see below for more information in How we Use Cookies and Similar Technologies). Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters.

 

C. Information We Receive from Third Parties

Information from third parties.  We obtain Information about you from third parties, such as:

  • If you apply for a job with us and we consider you for a position, we will use resources such as LinkedIn to view publicly available information about you and may also follow up for references.
  • Illumina information. If you use the App, we will receive account information for the BaseSpace Sequence Hub including user name from Illumina.

 

How We Use The Personal Information We Collect

We use the information we collect for the following purposes:

  • Providing you with the Services. We use your Personal Information to operate, provide and maintain our Services. In particular, we will use your Personal Information, including your registration, payment and communication information to perform our contractual obligation towards you to allow you to create an account, upload or share any Biological Data, generate and provide you with reports, purchase and use our Services, and to maintain a record of such purchase(s) and use and contact you (including via text or email) in case of any issue with your account or update on your use of the Services.
  • Improving or monitoring usage of our Services. It is in our legitimate interests to improve our Services for our Users, which includes conducting troubleshooting, testing and research and to keep the Services secure. When doing so we may use Information that we automatically collect about you, such as identifiers and usage information.
  • Monitoring and analyzing trends and use of our Services. It is in our legitimate interests to analyze the use of our Services. When doing so, we will process Information that we automatically collect about you or that is generated about you when you use the Services.
  • Providing you with support and to respond to your requests and complaints. If you reach out to us for support, or otherwise communicate with us, we will perform our contractual obligation towards you by using your Personal Information to respond and resolve your queries and facilitate support. The Personal Information we process when doing so includes your correspondence with us, your name, contact details, and, to the extent applicable to your query or complaint, transaction and usage information.
  • Processing your job application. If you apply for a job with us, we will perform our pre-contractual obligation towards you to consider you for a role, progress your application and to contact you regarding the same.  The Personal Information we process when doing so includes your name, contact details, application and resume details, any other information you choose to provide, and data from third parties including publicly available resources and referees.
  • Marketing. For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
  • Enforcing our Terms of Use (and any other agreement we have in place with you), preventing fraud, complying with legal obligations and defending IDbyDNA against legal claims or disputes. It is in our legitimate interests to enforce our terms and policies, to ensure the integrity of our Services, to comply with applicable laws and to defend ourselves against legal claims or disputes. Where we do so, we will use the Information relevant to such a case. Some processing may also be necessary to comply with a legal obligation placed on IDbyDNA, for example to keep records of transactions.
  • Publication of Aggregated and Anonymized Data. We collect, use and share aggregated data such as statistical or demographic data for our purposes. Aggregated data may be derived from your Information but is not Information as this data will not directly or indirectly reveal your identity. For example, we may aggregate data about your use of our Services. However, if we combine or connect aggregated data with your Information so that it can directly or indirectly identify you, we will treat the combined data as Information which will be used in accordance with this Policy.
  • For other purposes for which we provide specific notice at the time the information is collected.

 

How we use Cookies and Similar Technologies

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive.

 

Our Website and Platform use cookies to collect information about your browsing activities and to distinguish you from other users of our Website and Platform. This aids your experience when you browse our Website, and also allows us to improve the functionality of our Website and Platform.

 

We use the following cookies:

  • Strictly necessary cookies. Some cookies are strictly necessary to make our Website available to you; for example, to perform your login functionality and for user authentication and security. We cannot provide you with the Platform without this type of cookies.

 

  • Functional cookies. These are used to recognize you when you return to our Platform. This enables us to personalize our content for you, greet you by name and remember your account preferences.

 

  • Analytical or performance cookies. We also use cookies for analytics purposes in order to operate, maintain, and improve our Website and Platform. We use third party analytics providers, including Google Analytics, to help us understand how Users engage with the Services. Google Analytics uses first-party cookies to track User interactions which helps show how Users use our Services. This information is used to compile reports and to help us improve our Services. The reports disclose Website trends without identifying individual visitors. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

You can block cookies by setting your internet browser to block some or all or cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

 

Is Personal Information Shared or Disclosed?

We disclose Personal Information about you with the following recipients and in the following circumstances:

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services, such as:

  • App and website service providers, such as Illumina, who provides the BaseSpace Sequence Hub;
  • Analytics providers, who help us to understand our user base and how our Services are used, such as Google Analytics; and
  • Cloud service providers who we rely on for data storage, disaster recovery and to perform our obligations to you, such as Amazon Web Services.

 

Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

 

Marketing. IDbyDNA does not rent, sell, or share Personal Information it collects about you to or with third parties for their direct marketing purposes, unless we have your permission.

 

As Required By Law and Similar Disclosures. IDbyDNA may disclose Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (1) conform to the edicts of the law or comply with legal process served on IDbyDNA or our Services; (2) enforce our Terms of Use and other agreement; (3) prevent or resolve security or technical issues; (4) protect and defend the rights or property of IDbyDNA; or (5) act in urgent circumstances to protect the personal safety of Users of our Services or the public.

 

Merger, Sale, or Other Asset Transfer. If IDbyDNA is involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Personal Information as part of that transaction.

 

Consent. We may also disclose information from or about you or your devices with your permission.

 

Your Choices And Rights

Marketing Communications. You can unsubscribe from promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.

 

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and in the United States we do not respond to such signals.

 

Update Your Information. Your Personal Information may be corrected, amended, or deleted either by using the appropriate settings features of our Services or by sending a request by e-mail to info@idbydna.com

 

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

 

In certain circumstances if you are in certain jurisdictions, you have the following rights in relation to your Personal Information that we hold.

 

  • Access. You have the right to access the Personal Information we hold about you, and to receive an explanation of how we use it and who we share it with.

 

  • Correction. You have the right to correct any Personal Information we hold about you that is inaccurate or incomplete.

 

  • Erasure. You have the right to request for your Personal Information to be erased or deleted.

 

  • Object to processing. You have the right to object to our processing of your Information where we are relying on a legitimate interest or if we are processing your Information for direct marketing purposes.

 

  • Restrict processing. You have a right in certain circumstances to stop us processing your Information other than for storage purposes.

 

  • Portability. You have the right to receive, in a structured, commonly used and machine-readable format, Information that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Information to a third party.

 

  • Withdrawal of consent.  You have the right to withdraw your consent at any time, where we are relying on your consent as a basis for processing.

 

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request, and will inform you if that is the case. For more information on your rights, please email info@idbydna.com.

 

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

 

The Security Of Your Information.

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.

 

Children’s Privacy

We do not knowingly collect personal information directly from children under 18 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at info@idbydna.com.

 

International Transfers

We will transfer your Information outside of the European Economic Area, including to the US. When we do so, we shall ensure that relevant safeguards are in place to afford adequate protection for your Information. Further details regarding the relevant safeguards can be obtained from us on request.

 

Changes To This Privacy Policy.

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through our Services, we will attempt to notify you through the Services, by email, or other means.

 

Complaints

If you wish to lodge a complaint about how we process your Information, please contact us at info@idbydna.com. We will endeavor to respond to your complaint as soon as possible. In some circumstances you may also lodge a claim with the Information Commissioner’s Office in the UK (at +44 0303 123 1113) or the data protection supervisory authority in the EU country in which you live or work (for example the Irish Data Protection Commissioner at +353 578 684 800), where you believe we have infringed data protection laws.

 

Contacting IDbyDNA

For questions or concerns about this Privacy Policy, please contact us at info@idbydna.com or write to us at:

 

IDbyDNA Inc.

675 Arapeen Drive, Suite 301

Salt Lake City, UT, 84108

 

Alternatively, please contact our EU representative at datenschutz@rickert.net or write to:

 

Rickert Rechtsanwaltsgesellschaft mbH

Kaiserplatz 7-9

53113 Bonn

Germany