Privacy Policy - Genece Health

Genece Health Privacy Policy

Last revised: July 5, 2023

Genece Health, Inc. (“Genece,” “our,” “us,” or “we”) respects the privacy of all visitors and users of its online services and is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully in line with all relevant privacy legislation. This Privacy Policy (“Policy”) applies to all visitors and users of the Genece website www.genecehealth.com and all other Genece-owned websites, domains, website services, applications, and products (“Services”) in connection with our business (the “Business”).

Please take the time to read this Policy carefully to understand what personal information we collect when you use our Services, why we collect it, how we use it, and your choices related to your information. We may change our Policy from time to time. We therefore ask you to check it occasionally to ensure that you are aware of the most recent version that will apply each time you access our Services. In the event of material changes to this Policy, we will notify you. Any modifications to this Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on our Services (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy.

Personal Information and What We Collect

We may collect, process, use, store, and transfer the following information to provide, improve and protect our Services and in connection with our Business.

We may collect Personal Information (as defined below) when you visit or interact with our websites, and/or access our Services, interact with our Business, correspond with us by phone, e-mail, or otherwise, or when you inquire about or apply for employment opportunities at Genece. “Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. We may collect Personal Information about you when you provide it to us, when you interact with the Services, and when other sources provide it to us.

Information You Provide to Us

In order to take advantage of certain Services or features offered or provided by Genece, you may be asked to provide certain Personal Information. For example, we may collect:

Contact Information such as your name, title, company, mailing address, email address, phone number, password, and any other information you choose to provide to us.
Other Personal Information, such as employment-related information, information about education and professional credentials, institutional affiliations, financial information, and demographic information like age, race, or gender.
Other Personal Information you choose to provide, such as when you participate in a survey, register for an event, or when you request technical or consumer support.
Financial and Payment Information, such as information we need to complete a transaction.
Marketing and communication data which tells us your preference in receiving marketing from us and our third parties and your communication preferences.
Commercial Information, such as products and services purchased from us.

Information that we collect automatically when accessing or using our Services

When accessing or using the Services, we automatically collect the following information from your computer or other electronic device:

Internet activity, and Service usage information, such as operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Services.
Cookies and Other Tracking Technologies. In some instances, we automatically collect certain types of information when you visit our websites and through e-mails that we may exchange. Automated technologies may include the use of “cookies” and web beacons.
Location information, such as information used to locate the device you use to access the Services. Location information may include: (a) the location of the device derived from GPS or WiFi use; (b) the location derived from the IP address of the device or internet service used to access the Services, and/or (c) other information made available by a user or others that indicates the current or prior location of the user.
Profile and Inference Information, such as information about your preferences and characteristics.

Information we collect from Third Parties

We may collect data from public or commercially available sources, as permitted by law. Personal Information may also be available from government agencies, public or third-party information sources, third-party service providers, or business partners. We also may collect information from industry and patient groups and associations, or combine information we have collected from multiple sources.

How We Use Your Personal Information

Personal Information that you provide to us will be used as described in this Policy, or in our Terms of Use.

To Provide and Manage the Services. This includes, for example, enabling you to participate in features provided by the Services, performing our contracts with you or your employer or business. We also may use information we gather to better understand and serve users and to improve our Services.
To Communicate with You. We may use your personal information to respond to questions you submit via the Services or to communicate with you regarding news, updates, educational and marketing materials, and/or to send you information about changes to our policies. You may opt-out of receiving commercial email messages from us by following the instructions in those messages.
As Required or Permitted by Law. We may use your Personal Information to comply with any applicable legal or regulatory obligations or for any other purpose permitted by law or with your lawful consent. We may deidentify, pseudonymize, or anonymize your Personal Information, which means that information that can be reasonably used to identify you will be removed. We may aggregate the deidentified data and use such de-identified information as permitted by law or with your consent.

How We Share Your Personal Information

We may share Personal Information as discussed below:

With affiliates. We may share your Personal Information internally among our business units and our affiliates to provide you our Services and generally to improve our product and service offerings consistent with this Policy.
With vendors and other service providers. We may share your Personal Information with service providers who perform services for us and act at our direction. These services may include activities such as cloud storage and services, fulfillment services, and other IT services. Our policy is to prohibit these service providers from using your Personal Information for purposes other than providing services to us.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Legal Purposes. We will disclose your Personal Information if we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant, or similar legal process; or if necessary to assert or protect our rights or assets.
With Third Parties. To another party or parties for any other purpose disclosed by us when you provided your Personal Information, with your consent or authorization, or as otherwise permitted or required by applicable law.
Compliance and Safety. We may share Personal Information for compliance above and to comply with legal requirements and processes.

Cookies & Other Data Collection Technologies

A cookie is a small file placed on the hard drive of your computer. We use cookies if you have a Genece account, use our Services, including our website. Cookies enable Genece to offer the Services to you and to understand the information we receive about you, including information about your use of other websites and apps, whether or not you are registered or logged in.

You can review your Internet browser settings to exercise choices you have for certain cookies. Please note that by blocking or deleting cookies used in our Services you may be unable to access certain parts of Genece Services.

We may use the following categories of cookies:

Essential Cookies: Essential cookies, also often called "strictly necessary cookies," are a type of cookie that is required for a website to function properly. They provide critical functionalities and features. Essential cookies are used to identify users, manage user sessions, and maintain security. For example, they enable users to stay logged into their accounts as they navigate between different pages on a website. Essential cookies also help enhance the security of a website. For example, they can help detect repeated failed login attempts, protect against cross-site request forgery attacks, or manage other security features. Because these cookies are strictly necessary to deliver the Services and the user's experience, you cannot opt out of them without impacting how our Services function.

Performance and Functionality Cookies: These cookies are used to enhance the performance and functionality of our Services but are non-essential to their use. Performance Cookies collect information about how you use a website to improve how a website works. These cookies don’t collect information that identifies you; all the information these cookies collect is aggregated and therefore anonymous. Performance cookies are only used to improve how a website works. Functionality Cookies allow the website to remember choices you make (such as your username, language, or the region you're in) and provide enhanced, more personal features. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites. Without these cookies, certain functionality may become unavailable.

Analytics and Customization Cookies: These cookies collect information that is used to help us understand how our Services are being used or how effective our marketing activities are, or to help us customize our Services for you to enhance your experience.

Persistent Cookies: These record your visit to our website and apps, recognize you as a previous visitor and track your activity on the website or apps.

Web Beacons and Pixel Tags: We might incorporate a type of software code known as web beacons and pixel tags into web pages or email messages. These are embedded within our web pages or emails, and they notify us when you engage with the content, such as accessing the pages or interacting with an email. By utilizing these tools, we're able to gauge the response to our communication efforts and subsequently enhance our Services.

You can learn more about how to manage all cookies across different types of browsers by visiting www.allaboutcookies.org.The site includes additional useful information on cookies. Cookie management tools are device and browser specific and may not work on all devices.

In addition, we may use third-party software, such as Google Analytics, to collect and process data. Google Analytics uses cookies to track your interactions with our Services, then collects that information and reports it to us, without identifying individual users. This information helps us improve our Services so that we can better serve users like you. More information about how Google uses data is located at www.google.com/analytics.

Protecting Your Data

We have implemented reasonable measures and procedures designed to protect your Personal Information. These measures include pseudonymization, anonymization, information security controls, and data retention protocol. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Information you transmit to us via the Services, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our technical, physical, or administrative safeguards.

Children’s Privacy Policy

Consistent with the United States Children’s Online Privacy Protection Act of 1998 (“COPPA”), we do not knowingly request personally identifiable information from anyone under the age of 13 without requiring parental consent. Any person who provides their personal information to Genece through our Services represents that they are 13 years of age or older. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us at info@genecehealth.com.

Genece complies with all applicable state and federal laws in addressing requests for access to Personal Information in our possession related to minors under the age of 18.

Additional Information for Consumers in the US

Depending on your state of residence, you may be entitled to additional privacy rights regarding your Personal Information. For example, if you are a resident of California, you may be entitled to the privacy rights described below under the California Consumer Privacy Act (“CCPA”) and other applicable laws. The California Privacy Rights Act (“CPRA”), also known as Proposition 24, further expands the CCPA. Please note that certain categories of Personal Information, such as Protected Health Information (“PHI”), are not covered by state law privacy rights, but may be protected by HIPAA and other laws that provide similar protections.

You have the right to request:

the specific pieces of Personal Information we have about you;
the categories of Personal Information we have collected about you in the last 12 months;
the categories of sources from which that Personal Information was collected;
if we sold or disclosed your Personal Information in the last 12 months and the categories of your Personal Information that we sold or disclosed;
the categories of third parties with whom we share your Personal Information; and
the purpose for collecting and selling Personal Information.

In general, you have the right to request and obtain from Genece, information about our collection and use of your Personal Information. We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose. You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Once we receive and confirm your verifiable consumer request, you have the right to request that Genece delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why. Genece will not discriminate against you in any way if you choose to exercise your rights under the law. However, if we delete your Personal Information based on a request you make, understand that you may be unable to use or access certain features of our Services.

You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, contact us at info@genecehealth.com.

Other California Privacy Rights, such as California’s “Shine the Light” law also gives California residents the right to request certain information regarding our disclosure of their Personal Information to third parties for those third parties’ direct marketing purposes. You may request information regarding the disclosure of your Personal Information to third parties for those third parties’ direct marketing purposes by emailing info@genecehealth.com or by writing us at the address in the Contact Information section below.

Your European Union and United Kingdom Privacy Rights

If you are a resident of the European Union or the United Kingdom, you have certain data protection rights under the General Data Protection Regulation (“GDPR”).

Your Rights Under GDPR

Genece is committed to providing individuals greater control over the processing of their personal data. You are entitled to certain rights under GDPR:

Right to Be Informed. You have the right to ask us questions about our processing of your Personal Data, including if you feel information is missing from this Privacy Notice.
Right to Access. You have the right to request access to your Personal Data and information about how this Personal Data is being processed.
Right to Rectification. You have the right to ask us to correct errors, or to complete omissions, in your Personal Data.
Right to Erasure (also known as the 'Right to be Forgotten'). In certain circumstances, you may have the right to ask us to delete your Personal Data where there's no compelling reason for its continued processing.
Right to Object. You may have the right to object to processing of Personal Data based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing, and processing for purposes of scientific/historical research and statistics.
Right to Restriction of Processing. In certain circumstances, you may have the right to limit our processing of your Personal Data.

Retention of Your Personal Information

We will retain your Personal Information for as long as is reasonably necessary to fulfill the relevant purposes set out in this Policy and during the period required or permitted by law. The retention period will primarily be determined by relevant legal and regulatory obligations and/or duration of our business relationship with you. We will securely delete or erase your personal information if there is no valid business reason for retaining your data.

Our Legal Basis for Processing Personal Data Under GDPR

In most cases, our use of Personal Data is necessary:

for us to carry out a contract with you, such as a contract to purchase a product or a Service;
so that we can comply with our legal or regulatory obligations, and/or cooperate with regulators and other authorities; or
for the purposes of pursuing our legitimate interests and where these are not overridden by your interests or fundamental rights or freedoms which require protection of personal data, such as to manage and improve our business and customer engagements and relationships to support the Services, and evaluate the use of our Services.

We will process your personal data only for purposes permitted by law. This includes processing where necessary for the following purposes:

to comply with a request or order from a competent court, law enforcement authority or other government agency; and/or
to enforce, exercise or defend legal claims.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data. If you have any questions or need more information regarding the legal basis and purpose for processing your personal data, please contact us at info@genecehealth.com.

Other International Visitors (non-EU or UK)

Our website and Services are based in the United States and cater to visitors within this region. Your interaction with the Services and your data provision is governed by the legal provisions of the United States and the State of California. If you decide to use our Services from other parts of the globe that have different laws related to data gathering, usage, and sharing, then it's important to acknowledge and agree that (a) your personal data is being transferred out of those regions to the United States, and (b) the rules and regulations of the United States regarding data privacy and protection, as well as the use and disclosure of Personal Information and PHI, may not be the same as those in your home country.

Changes to This Policy

It is our policy to post any changes that we make to our Policy on our website. If we make material changes to how we treat our users’ Personal Information, we will update this Policy. The date our Policy was last revised is identified at the top of the page. For any questions or comments regarding this Policy, please contact us at info@genecehealth.com.

Contact Information

Please contact us with any questions or comments about this Policy, your Personal Information or our Notice of Privacy Practices, or your consent choices by email at info@genecehealth.com or by mail to 12250 El Camino Real, Suite 160 Del Mar, CA 92130, Attn: Privacy Officer.