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Definitions

  • “DrGene” means DrGene Hong Kong Limited., whose principal place of business is at Unit 1707 Unicorn Trade Centre, 131 Des Voeux Road, Central, Hong Kong. , and all affiliates and entities under common ownership with DrGene.
  • “R&D” means research and development activities performed by DrGene on user data. These activities may include, among other things, improving our Services and/or offering new products or services to you; performing quality control activities; conducting data analysis that may lead to and/or include commercialization with a third party.
  • “Service” or “Services”means DrGene's products, software, services, mobile application, and website as accessed from time to time by the user, regardless if the use is in connection with an account or not.

DrGene Respects Your Privacy

DrGene recognizes the importance of privacy and respects your desire to store and access your information in a private and secure manner.

This Privacy Statement for www.drgene.com is intended to make you aware of how we handle your Personal Information. We are committed to providing you a secure, user-controlled environment for the use of our Services. At the same time, you share responsibility for maintaining privacy and security - for example, by keeping your password secure.

We encourage you to familiarize yourself with this Privacy Statement. Our Terms of Service explain that, by using our website and signing up for our service, you are allowing us to process your personal information according to the provisions set forth in those documents and this Privacy Statement.

Your Personal Information

In the course of your relationship with DrGene, we collect several types of Personal Information. “Personal Information” is information that could be used to identify you, either alone or in combination with other information. We collect such information from you when you purchase our Services, create a personal account, complete surveys and forms, and/or when you communicate with us or request information from us. Personal Information collected online can be combined with Personal Information collected offline. We collect six primary types of Personal Information through our Service and website.

  1. “Registration Information” is information that we collect from you when you purchase or sign up for our Services. Examples of such information include your name, credit card information, billing and shipping addresses, and contact information, such as email address and telephone number.
  2. “Genetic Information” consists of your genotype, e.g. the As, Ts, Cs, and Gs at particular locations in your genome. Genetic Information is generated when you purchase DrGene's Service and your saliva sample is analyzed and processed or you otherwise contribute or access your Genetic Information through our Services. Our instructions for sample collection and shipment clearly require you to send only your saliva sample to our third-party laboratory labeled with the unique barcode and no other identifier. The unique barcode identifies you to us but not to the laboratory. Testing personnel only handle samples labeled with the unique barcode. The laboratory securely sends the resulting Genetic Information to us along with your unique barcode. Genetic Information is stored securely on our servers. The laboratory conducting DNA extraction and analysis does not have access to your name, other Registration Information, or any other Personal Information.
  3. “Self-Reported Information” includes information you provide to us, including but not limited to information about your disease conditions, other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), personal traits (e.g., eye color, height), ethnicity, and/or family history (e.g. similar information about family members). We collect this information from you if and when you enter the information into surveys, forms, or features while signed in to your account.
  4. “User Content” is all information other than Genetic Information or Self-Reported Information generated by users of DrGene Services and transmitted, whether publicly or privately, to DrGene. User Content may include data, text, software, music, audio, photographs, graphics, video, messages, or other materials. For example, User Content includes posts made to the DrGene community forums or emails to Customer Support. User Content does not include Genetic Information or Self-Reported Information.
  5. “Web Behavior Information” is information on how you use the DrGene website (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology.
  6. “Referral Information” is information that you provide when referring DrGene Services to your friends and contacts. This information can include your name, your email address, and the name and email address of the person you are referring our Services to. When you make referrals using a social network it may also include information from your profile that is made available to DrGene when we connect to your social network to post the referral on your behalf. The information that DrGene is provided during this process varies depending on the social network and your privacy settings, but can include information such as your name, profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers and any other information you have permitted the social network to share with third parties.

How We Use Personal Information

DrGene collects Personal Information from you for all purposes necessary to ensure the regular operation of your account and/or availability of our Services. These include, among other things, providing you with our Services; improving our Services and/or offering new products or services to you; informing you about events; inviting you to participate in specific research projects, contacting you to obtain testimonials or for other promotional purposes; performing quality control activities; conducting other R&D ;

DrGene may provide your Personal Information to our third-party service providers, which are companies and people that help us provide, understand and improve our Services. For example, we may use service providers to help host our website, send emails, implement our marketing campaigns, measure the effectiveness of our advertising, conduct surveys or polls, obtain testimonials, or otherwise help us run or improve our business.

How We Use Registration Information

We use your Registration Information to authenticate your website and mobile application visits and usage; to enable your purchase; to communicate with you about information, services, and products that you have requested; and to manage and improve our website, software, and Services.

How We Use Genetic and Self-Reported Information

We use your Genetic and Self-Reported Information to provide you with DrGene Services, customize the user experience, and enhance our features. Self-Reported Information is used to customize your user experience - for example, by adjusting reports of genetic risk to account for your reported behaviors or environmental exposures.

DrGene may use your Genetic and Self-Reported Information for purposes such as quality control or other R&D activities. Genetic and Self-Reported Information used for such purposes may be included in Aggregated Genetic and Self-Reported Information disclosed to third-party research partners who will not publish the information in a peer-reviewed scientific journal.

Research partners may include commercial or non-profit organizations that conduct or support scientific/medical research or conduct or support the development of drugs or devices to diagnose, predict, or treat health conditions.

How We Use User Content and Web Behavior Information

DrGene uses User Content to provide our Services and improve the overall user experience. For example, posts made to the DrGene community forums are publicly displayed to other users. By submitting, posting, or displaying User Content, you give DrGene a non-exclusive license to use any User Content that you submit, post, or display on or through the Services, as further described in the Terms of Service. DrGene may make such User Content available to other companies, organizations, or individuals with whom DrGene has relationships, and to use such User Content in connection with the provision of those services. DrGene, in performing the required technical steps to provide the Services to our users, may also (a) transmit or distribute your User Content over various public networks and in various media; and (b) make such changes to your content as are necessary to conform and adapt that content to the technical requirements of connecting networks, devices, services, or media.

Information Sharing

DrGene gives you the ability to connect with other individuals through our community forums, relative finding features, and other sharing features. In addition, you may choose to disclose, through other means not associated with DrGene, any part of your Personal Information to friends and/or family members, groups of individuals, third-party service providers, doctors or other health care professionals, and/or other individuals. We recommend that you make such choices carefully.

Personal Information, once released or shared, can be difficult to contain. DrGene will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with a third party. It is incumbent upon customers to share Personal Information only with people they know and trust.

Ordering DrGene Services as a Gift

If you provide us personal information about others, or if others give us your information for purposes of ordering our service as a gift, we will only use that information for the specific reason for which it was provided to us, provided that once a gift recipient registers for his or her Services and agrees to our TOS, Privacy Statement and if applicable, Consent Form, his or her information will be used consistent with this Privacy Statement and those agreements.

Making Referrals

If you take part in a DrGene referral program to promote DrGene Services to your friends we will use the Referral Information you provide for the sole purpose of sending these referral emails. If as part of the referral program you provide us with a friend’s email address, you confirm that your friend has provided you with his or her consent to be sent the referral email. We will let your friend know that you asked us to contact them. Additionally, we may collect information from you and your friends through the use of cookies and other technology, so we can monitor the success of our referral program and keep track of friends you refer who may sign up for our services and to credit you with any benefit that is available under our referral program .

Information Disclosure

We do not sell, lease, or rent your individual-level Personal Information without your explicit consent. As a general rule, DrGene will not disclose your individual-level Personal Information to any third party, except under the following circumstances:

  • Partners or service providers (e.g. credit card processors or our contracted genotyping laboratory) process and/or store the information in order to help us provide, understand or improve DrGene's Services.
  • You have provided explicit consent for us to do so.

DrGene may disclose Personal Information for the following reasons:

  • DrGene may disclose Aggregated Genetic and Self-Reported Information intended to be published in a peer-reviewed scientific journal to research collaborators or as a result of publication.
  • Contact information. DrGene will ask for and require your explicit consent to allow partner organizations (not including service providers) direct access to your Registration Information

Information Disclosure Required By Law

Under certain circumstances Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. You acknowledge and agree that DrGene is free to preserve and disclose any and all Personal 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 DrGene may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the DrGene TOS; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of DrGene, its employees, its users, its clients, and the public.

Linked Websites

DrGene provides links to third-party websites operated by organizations not affiliated with DrGene. DrGene does not disclose your Personal Information to organizations operating linked third-party websites. DrGene 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 DrGene.

Customer Testimonials

We post testimonials from consenting customers on our web site, and may use testimonials in other formats consistent with consent received. Customer testimonials may contain personally identifiable information. We may use your Personal Information to contact you to obtain a testimonial and obtain your consent via email or agreement sent via fax, pdf or mail prior to using such testimonial and/or using your name along with your testimonial.

Account Closure and Correction of Personal Information

If you no longer wish to participate in our Services, you may close your account by sending a request to Customer Care. When closing an account, we remove all Genetic Information within your account (or profile) within thirty (30) days of our receipt of your request. As stated in the applicable Consent Document, however, Genetic Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in DrGene will not be removed from ongoing or completed studies that use the information. Our contracted genotyping laboratory may also retain your Genetic Information 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) for accounting and compliance purposes.

If your Personal Information changes, you may correct or update your Registration Information via your Account Settings page.

Security

DrGene takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, DrGene uses a range of reasonable physical, technical, and administrative measures to safeguard your Personal Information, in accordance with current technological and industry standards.

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 DrGene of any unauthorized use of your password. DrGene cannot secure Personal Information that you release on your own or that you request us to release.

Business Transitions

In the event that DrGene goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

Changes to This Privacy Statement

This Privacy Statement was last updated March 1, 2014. Whenever this Privacy Statement is changed in a material way, a notice will be posted on our website as part of this Privacy Statement. After 30 days the changes will become effective.

Contact Information

If you have questions about this statement, please email DrGene Privacy Administrator at:privacy@DrGene.com