PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.
We collect your personal information when you i) register an account on our website, ii) enter information on our website, iii) provide your DNA samples and/or iv) navigate our webpages.
I. Information you provide directly to us or through a third party:
- Registration Information. When you purchase our Services or create a Genebank account, we collect Personal Information, which may include 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).
- 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., eye color, height), ethnicity, disease conditions (e.g., Type 2 Diabetes), other health-related information (e.g., pulse rate, cholesterol levels, visual acuity), and family history information (e.g., information similar to the foregoing about your family members). Before you disclose information about a family member, you should make sure you have permission from the family member to do so.
- User Content. Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission ("User Content"). For example, User Content includes any discussions, posts, or messages you send on our Forums.
- Referral information and sharing. When you refer a person to Genebank or choose to share your Genebank results with another person, we will ask for that person's email address. We will use their email address solely, as applicable, to make the referral or to communicate your sharing request to them, and we will let your contact know that you requested the communication. By participating in a referral program or by choosing to share information with another person, you confirm that the person has given you consent for Genebank to communicate (e.g., via email) with him or her. The person you referred may contact us at via email to request that we remove this information from our database.
II. Information related to our genetic testing services:
- Saliva sample and biobanking. To use our genetic testing services, you must purchase, or receive as a gift, a Genebank Personal Saliva Collection Kit, create an online account and register your kit, and ship your saliva sample to us or our third party laboratory. Your DNA will be extracted from your saliva sample for analysis. During kit registration you are asked to review our Terms of Service and Research Consent. Unless you consent to sample storage (“Biobanking”) and additional analyses, your saliva sample and DNA are destroyed after the laboratory completes its work, subject to laboratory legal and regulatory requirements. You can update your Biobanking preference to discard a stored sample within your Genebank Account Settings once your sample has completed processing.
- 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 saliva sample, or when you otherwise contribute or access your Genetic Information through our Services. Genetic Information includes the Genebank results reported to you as part of our Services, and may be used for other purposes, as outlined in Section 3 below.
III. Web-Behavior Information collected through tracking technology (e.g. from cookies and similar technologies)
- help us recognize you when you use our Services;
- customize and improve your experience;
- provide security;
- analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service);
- gather demographic information about our user base;
- offer our Services to you;
- monitor the success of marketing programs; and
- serve targeted advertising on our site and on other sites around the Internet.
If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
Google Analytics. Google Analytics is used to perform many of the tasks listed above. We use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions). We have enabled the following Google Analytics Advertising features: Remarketing, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and DoubleClick Campaign Manager integration. We do not merge information collected through any Google advertising product with individual-level information collected elsewhere by our Service. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.
IV. Other Types of Information
Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
We do not sell, trade, or otherwise transfer customers’ personally identifiable information to outside parties without customers’ permission. Customers’ information is only accessible by relevant persons who have special access rights, and are required to keep the information confidential. All sensitive information you supply is encrypted via Secure Socket Layer (SSL) technology.
HOW DO WE USE YOUR PERSONAL INFORMATION?
I. To provide you with Services and to analyze and improve our Services
- open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);
- 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;
- contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.);
- enforce our Terms of Service and other agreements;
- monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks; and
- perform research & development activities, which may include, for example, conducting data analysis in order to develop new or improve existing products and services, and performing quality control activities.
II. To process, analyze and deliver your genetic testing results
As described above, to receive results through the Personal Genetic Service, you must create a Genebank account, register your kit, and submit your saliva sample to be sequenced by us or our contracted laboratory. Once sequenced, we further analyze your Genetic Information to provide you with our health and/or ancestry reports, depending on the Service purchased. Genebank 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.
III. To allow you to share your Personal Information with others
Genebank gives you the ability to share information, including Personal Information, through the Services. You have the option to share directly with individuals with Genebank accounts through (i) our Forums, and (ii) other sharing features and tools. You may also have the ability to share information directly with individuals who have not participated in our Service via a unique, shareable URL or through a social media platform (such information is "User Content"). Some sharing features, including receiving sharing invitations, may require that you opt-out, however you will always be required to take a positive action, such as opting in, to share Sensitive Information.
You should be thoughtful about your sharing choices. Once you have chosen to share any Personal Information, the individuals with whom you share this information, may also use or share your Personal Information, including any Sensitive Information you choose to share.
IV. To allow you to share your Personal Information for Genebank Research purposes
You have the choice to participate in Genebank Research by providing your consent.
Genebank Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or pharmaceutical companies. Genebank Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. Genebank Research uses Aggregate and/or Individual-level Genetic Information and Self-Reported Information as specified in the appropriate Consent Document(s), as explained in greater detail below.
Your De-identified Genetic and Self-Reported Information may be used for Genebank Research only if you have consented to this use by completing a Consent Document. If you have completed the main Research Consent Document:
- Your Genetic Information and/or Self-Reported Information will be used for research purposes, but it will be de-identified and will not be linked to your Registration Information.
- Genebank may use individual-level Genetic Information and Self-Reported Information internally at Genebank for research purposes.
- Genebank may share summary statistics, which do not identify any particular individual or contain individual-level information, with our qualified research collaborators.
Withdrawing your Consent. You may withdraw your consent to participate in Genebank Research at any time by changing your consent status within your Genebank Account Settings. If you experience difficulties changing your consent status, contact us via email. Genebank will not include your Genetic Information or Self-Reported Information in studies that start more than 30 days after you withdraw (it may take up to 30 days to withdraw your information after you withdraw your consent). Any research involving your data that has already been performed or published prior to your withdrawal from Genebank Research will not be reversed, undone, or withdrawn. You may also discontinue your participation in Genebank Research by deleting your Genebank account.
V. To recruit you for external research
Research is an important aspect of our Services and we want to ensure interested participants are aware of additional opportunities to contribute to interesting, novel scientific research conducted by academic institutions, healthcare organizations, pharmaceutical companies, and other groups. If you have chosen to participate in Genebank Research, from time to time we may inform you of third party research opportunities for which you may be eligible. For example, if a university tells us about a new cancer research project, we may send an email to Genebank research participants who potentially fit the relevant eligibility criteria to make them aware of the research project and provide a link to participate with the research organization conducting the study. We will not share Individual-level Genetic Information or Self-Reported Information with any third party without your explicit consent. If you do not wish to receive these notifications, you can manage them by editing your preferences in your Genebank Account Settings.
VI. 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.
VII. To conduct surveys or polls, and obtain testimonials
We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us. If you do not wish to receive these requests, you can manage them in your Genebank Account Settings.
VIII. To provide you with marketing communications
By creating a Genebank 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. You may also opt-in to receiving similar notifications on the website or mobile application(s). You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link or go to the “Preferences” section of your Genebank Account Settings to edit your email notification preferences. To opt-out of receiving website and mobile notifications, you may do so within your browser or device settings. Please note, the opt-out process differs between web browsers and mobile devices. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
SHARING YOUR PERSONAL INFORMATION
You have the ability to make decisions about how your data is shared and used. You can choose:
- To store or discard your saliva sample after it has been analyzed.
- Which health report(s) you view and/or opt-in to view.
- When and with whom you share your information, including friends, family members, health care professionals, or others outside our Services, including through third party services that accept Genebank data and social networks.
- To give or decline consent for Genebank Research. By agreeing to the Research Consent Document, or participating in a Genebank Research Community you consent to the use of your de-identified data for scientific research purposes.
- To delete your Genebank account and data, at any time.
Your Personal Information may be shared in the following ways:
I. General service providers
We share the information 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 Genebank 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:
II. 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 Genebank kit from the Genebank.com online store. Our distribution centers ship your kit(s) to you, and in some cases help return your kit safely to us or to our third party laboratory so your sample can be processed.
III. Our sequencing lab
To use our genetic testing services, you must purchase, or receive as a gift, a Genebank Personal Saliva Collection Kit, and ship your saliva sample to us or our third party laboratory. Once delivered, receiving personnel at the laboratory remove and discard kit packaging, which in some cases may contain "sender information" (e.g., name, address), before testing personnel receive the samples for processing. Receiving personnel do not perform testing, and testing personnel handle saliva samples that are only identified by a unique barcode and identifier. For samples processed by our third party sequencing laboratory, when the laboratory has completed their analysis, they securely send the resulting Genetic Information to us identified by your unique identifier.
During kit registration, you are asked to review our Consent Document for Sample Storage and Additional Genetic Analyses. Unless you consent to Biobanking and additional analyses, your saliva sample and DNA are destroyed after the laboratory completes its work, subject to the legal and regulatory requirements. Should you wish to update your sample storage preference to discard a stored sample, you can do so within your Genebank Account Settings once your sample has completed processing. Our sequencing laboratory or contracted sequencing laboratory will retain certain information as necessary to comply with applicable regulatory and legal obligations.
IV. 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.
V. Cloud storage, IT, and Security
Our cloud storage providers provide secure storage for information in Genebank databases, ensure that our infrastructure can support continued use of our Services by Genebank customers, and protect data in the event of a natural disaster or other disruption to our Service. Our IT and security service 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 Genebank’s security controls.
VI. 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.
NOTE: Our service providers act on Genebank'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.
VII. "Targeted advertising" service providers
VIII. 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 policy 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. Genebank 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.
IX. Information we share with commonly owned entities
X. 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. Genebank 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 Genebank may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Genebank 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 Genebank, its employees, its users, its clients, and the public. View our Transparency Report for more information.
NOTE: If you are participating in Genebank Research, Genebank will withhold disclosure of your Personal Information involved in such Research in response to judicial or other government subpoenas, warrants or orders in accordance with any applicable Certificate of Confidentiality that Genebank has obtained from the National Institutes of Health (NIH). There are limits to what the Certificate of Confidentiality covers so please visit the Certificates of Confidentiality Kiosk.
XI. Business transactions
Genebank will not sell, lease, or rent your individual-level information to a third party for research purposes without your explicit consent. In addition,
- We will not share your 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 YOUR INFORMATION
Genebank implements measures and systems to ensure confidentiality, integrity, and availability of Genebank data. Our team regularly reviews and improves our security practices to help ensure the integrity of our systems and your information. These practices include, but are not limited to, the following areas:
- Genebank uses industry standard security measures to encrypt Sensitive Information both when it is stored and when it is being transmitted.
- Limited access to essential personnel. We limit access of information to authorized personnel, based on job function and role. Genebank access controls include multi-factor authentication, single sign-on, and a strict least-privileged authorization policy.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, 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 Genebank of any unauthorized use of your password. Genebank 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 Singapore or any other country in which Genebank 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.
RISK AND CONSIDERATIONS
There may be some consequences of using our 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.
- You may discover relatives who were previously unknown to you, or may learn that someone you thought you were related to is not your biological relative.
- 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.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising.
COMMON LINKS INCLUDE:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
Unless you delete your account or delete certain Personal Information (i.e., User Content, etc.), we will store your Personal Information as long as your account is open. If you delete your account, we will take the steps and delete all your Personal Information, unless a longer retention period is required or permitted by law.
The Site is not intended for individuals under the age of 18.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at firstname.lastname@example.org.