- We collect and handle information, including Personal Information, (i) to provide, analyze and improve our Services, (ii) as we reasonably believe is permitted by laws and regulations, such as for marketing and advertising purposes, and (iii) as reasonably necessary to comply with laws and regulations, and to protect the security and safety of our company, employees, customers and others.
- We will not sell, lease, or rent your individual-level information (i.e., information about a single individual’s genotypes or other traits/characteristics) to any third party or to a third party for research purposes without your consent.
- We understand and respect the sensitive nature of the information you may provide to us, including information about your genetic characteristics, health survey, etc. To that end, we strive to be transparent in our collection, use and disclosure of this information and to ask for your consent to share such sensitive information with third parties. Please see below to learn more about our sharing and consent practices.
- We are committed to providing a secure and safe environment for our Services.
Please review this Privacy Statement and our Terms of Service. By using our Services, you agree to all of the policies and procedures described in the foregoing documents. Genetic Direction LLC is headquartered at 211 N. Ervay, Suite 5020, Dallas Texas 75201 and is referred to herein as Genetic Direction (or “we,” “us,” “our”) and includes all of our commonly owned companies.
What information we collect
- Information you provide directly to us
- Registration Information. When you register an account with us or purchase our Services, we collect personal information, such as your name, billing and shipping address, payment information (e.g., credit card) and contact information such as your email and phone number.
- Self-Reported Information. You have the option to provide us with additional information about yourself through our health survey.
- Testimonials. We may post customer testimonials either on our website or in other online or offline formats. Customer testimonials may contain personal information and it is our policy to request consent from customers in advance of using testimonials. If you wish to update or delete your testimonial, you can contact us at [email protected].
- Third-party services (e.g., social media). If you use a third-party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person’s name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third-party site. We do not control third-party site’s information practices, so please review their privacy policies and your settings on those sites carefully.
- Customer service. When you contact our Customer Service or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Service, Privacy Statement or applicable laws or regulations; and analyze and improve our Services.
- Information related to our genetic testing services
- Swab sample. To use our genetic testing services, you must purchase a Genetic Direction swab kit, register an online account, and ship your swab sample to our third-party laboratory. Once received, your saliva sample will be identified by its unique barcode, along with your gender and your date of birth. The barcode label identifies you to us but not to our third-party laboratory. Your saliva samples and DNA are destroyed within 45 days after the laboratory completes its work, unless the laboratory’s legal and regulatory requirements require it to maintain physical samples.
- Genetic Information. Genetic Information refers to features of your DNA that distinguish you from other people (e.g. the As, Ts, Cs, and Gs at particular locations in your genome) and is generated when we analyze and process your saliva sample. Genetic information includes the results information reported to you as part of our solution offerings.
- Information collected through tracking technology (e.g. from cookies and similar technologies)
How we use and share information
- Using information to provide, analyze and improve our Services
- open your account, enable purchases and process payments, communicate with you, and implement your requests;
- host our website, authenticate your visits, provide custom, personalized content and information, and track your usage of our Services;
- conduct analytics to improve and enhance our Services;
- offer new products or services to you, including through emails, promotions or contests;
- implement online marketing campaigns and targeted advertising, including by utilizing third party ads (subject to your cookie settings and preferences), and to measure the effectiveness of our marketing and targeted advertising;
- conduct surveys or polls, and obtain testimonials;
- process and deliver your genetic testing results and solution recommendations;
- 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.
- Information we share with third parties
- General service providers. We share the information described above in Section 1.b.i. with our third-party laboratory to process and analyze your saliva sample for purposes of generating your Genetic Information. NOTE: Our service providers act on Genetic Direction’s behalf. While we implement procedures and contractual terms to protect the confidentiality and security of your information, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.
- Aggregate information. We may share aggregate information with third parties, which is any information that has been stripped of your Registration Information (e.g., your name and contact information) and aggregated with information of others so that you cannot reasonably be identified as an individual (“Aggregate Information”). This Aggregate Information is different from “individual-level” information. Individual-level Genetic Information or health survey information consists of data about a single individual’s genotypes or other traits/characteristics information. We do not share such individual-level information with any third parties without your consent.
- Genetic Direction will ask for your consent/authorization to share individual-level Genetic Information with any third party, other than our lab provider, as necessary for us to provide the Services to you.
- Genetic Direction does not share Genetic Information with employers or health insurance providers. You are protected under the Genetic Information Nondiscrimination Act (GINA) of 2008.
- Disclosures required by law
Under certain circumstances your information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. Genetic Direction 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 Genetic Direction may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Genetic Direction Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; (d) protect the rights, property, or personal safety of Genetic Direction, its employees, its users, its clients, and the public or (e) respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
- Marketing communications
By registering for an account with us, you are agreeing that we may send you promotional emails about our Services. You can opt-out of receiving certain messages or notifications from us by contacting our Privacy Administrator at [email protected] You can also click the “unsubscribe” button at the bottom of promotional email communications. Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
- Account closure
If you no longer wish to participate in our Services or no longer wish to have your personal information be used, you may close your account by sending a request to our customer care [need email address]. When closing an account, we remove all information (Genetic Information, health recommendations, etc.) within sixty (60) days of our receipt of your request. However; your non-identified information (information that has been stripped of your Registration Information) that has previously been aggregated and shared with a 3rd party cannot be removed. Our contracted genotyping laboratory may also retain your Genetic Information as required by local law and we may retain backup copies for a limited period of time pursuant to our data protection policies. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) as long as your account is active or as needed to provide you Services, as well as for accounting, audit and compliance purposes.
- Security measures
To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, Genetic Direction uses a range of physical, technical, and administrative measures to safeguard your Personal Information. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.
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 Genetic Direction of any unauthorized use of your password. Genetic Direction cannot secure Personal Information that you release on your own or that you request us to release.
- Business transactions
In the event that Genetic Direction goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in this Privacy Statement or our Terms of Service.
- Linked websites
Genetic Direction provides links to third-party websites operated by organizations not affiliated with Genetic Direction. Genetic Direction does not disclose your information to organizations operating such linked third-party websites. Genetic Direction 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 Genetic Direction.
- Age Limit
None of Genetic Direction’s services are designed for, intended to attract, or directed toward anyone under the age of 18.
If you have questions about this Privacy Statement, please email Genetic Direction’s Privacy Administrator at [email protected] or send a letter to:
Genetic Direction, LLC
211 N. Ervay Street, Suite 5020
Dallas, TX 75201
*This Privacy Statement was last updated on July 1, 2017.