Last Updated: Jun 4, 2024
Last Updated: April 15th, 2024, effective May 1st, 2024
This Privacy Policy describes how we process the information we collect about you when you use the Services. We define “Services” below, but it generally means the products and services that we offer to you.
Please carefully review this Privacy Policy and let us know if you have any questions or concerns. We encourage you to contact us, at any time, using the contact information at the end of this Privacy Policy.
Depending on how you use the Services, we may ask you to sign an informed consent form that describes certain aspects of the Services and asks for your consent to process your information as part of those Services. To the extent that there is a conflict between this Privacy Policy and an informed consent form that you have signed, the informed consent form will control.
“Aggregate Information” is information about multiple individuals that we have combined so that no specific individual may be identified. Aggregate Information is not Personal Information because it cannot be used to identify you. For example, Aggregate Information may include a statement that “30% of our female users share a particular genetic trait,” without providing any data or testing results specific to any individual user.
“GENOMELINK” means Genomelink, Inc. We will refer to GENOMELINK as “we”, “us” and “our” throughout this Privacy Policy.
“Cookie” is a text file that is placed on your hard disk by a web server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. To learn more about Cookies, visit www.allaboutcookies.org.
“Data Collection Technologies” refer to Cookies, pixel tags, web beacons, and other technologies that we or third parties use on our websites and other digital services to collect information about your use of these services.
“De-Identified Data” is data that cannot be used to infer information about, or be linked to, an individual.
“Designated European Countries” means countries the European Economic Area, the United Kingdom, and Switzerland.
“DNA” stands for deoxyribonucleic acid, which is the molecule that contains your genetic information. Your DNA is what makes you uniquely you.
“Genetic Information” is any data concerning genetic material obtained from the analysis of your biological sample by us or by Third Party DNA services. Genetic Information includes, but is not limited to, DNA, Raw Data and Traits.
“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.
“Raw Data” means information about your genotypes that is generated by Third Party DNA Services. Your Raw Data contains the “letters” (nucleotides A, C, G, T) that comprise DNA.
“Sensitive Information” is a subcategory of Personal Information under applicable data protection laws that may include, for example, your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, and information concerning your health, sex life, or sexual orientation. Additional information on the types of Sensitive Information we may collect can be found in Section 2 below.
“Service” means the GenomelinkTM service, associated websites (http://genomelink.io and http://www.genomelink.io/) and mobile applications, and other ancillary or related services we offer from time to time.
“Third Party DNA Services” means companies and organizations not related to or operated by us that you may use to obtain DNA testing and results.
“Traits” means the characteristics or attributes that may be influenced by your DNA. Your Traits may include your preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. The traits we analyze as part of the Service are personal - not medical - in nature.
Depending on how you interact with or use the Service, we may collect the following categories of Personal Information about you:
We may collect your Personal Information directly from you, such as when you register for a Genomelink account, provide us with certain electronic health record data, complete a family history questionnaire, survey or form, contribute to blogs and forums, or contact us with a question.
We may also collect your Personal Information from third party sources, such as Third Party DNA Services, social media platform providers, or your friends and family who refer our Service to you. The Personal Information we collect from these third parties sources typically depends on the privacy settings or permissions that you have communicated with these third parties or otherwise set on their platforms.
Finally, we may collect certain Personal Information automatically through the use of Data Collection Technologies. Please see Section 7 and our Cookie Policy for more details about our use of Cookies and other Data Collection Technologies.
Non-Personal Information. We may also collect information that cannot be used to identify you. This non-Personal Information may include Aggregate Information about our users’ browser types, device types, and pages clicked. We collect this non-Personal Information through server logs and Data Collection Technologies. We may associate this information with the Personal Information that we collect about you -- if we do, we will treat the combined information as Personal Information.
We collect your Genetic Information in the following ways:
We use your Genetic Information for the following purposes:
You may revoke your consent for the use of your Genetic Information at any time by either deleting your data at https://genomelink.io/profile/ or contacting us at oi.knilemoneg@ofni.
We disclose your Genetic Information as follows:
Genomelink will not sell, lease, or rent your individual-level information to a third party for research purposes without your explicit consent. In addition, without your consent:
In addition to the purposes for which we collect your Personal Information listed in Section 2 above, we may use your Personal Information for the following purposes:
If we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide us with the information when requested, we may not be able to perform the contract we have, or are trying to enter into, with you. We will inform you of any Personal Information we require from you and the consequences if you fail to provide it.
Special Categories: We only process Special Categories of Personal Information if you give us your explicit consent (such as through our informed consent), the processing is necessary to meet a legal or regulatory obligation, the processing is in connection with the establishment, exercise or defense of legal claims, or is otherwise expressly permitted by law. Special Categories of Personal Information includes information about your racial or ethnic origin, genetic data (such as Raw Data), and data concerning health, sex life, and sexual orientation.
Other Uses: Any other purposes for which we wish to use your Personal Information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you by amending this Privacy Policy in accordance with the Section 17.
We may share your Personal Information in the following circumstances:
Note: When we share your Personal Information with research partners, we do not have control over how those research partners use or disclose your Personal Information. We recommend that you review the privacy policies of the research partners and any other third party with whom you share, or ask us to share, your Personal Information.
Sharing Aggregate Information. We may share Aggregate Information with third parties or the general public for our marketing or research purposes. For example, we may provide Aggregate Information in commercial arrangements with our business partners so that they may develop new research or products. We may also provide Aggregate Information to advertisers so they may tailor marketing messages or advertisements to our general user demographics. Disclosures for these purposes will never contain your Personal Information.
You can log into your Genomelink account and view or amend the Personal Information associated with your account at any time. Please note that if you amend the Personal Information in your account, our servers may retain the old information as part of our logs and backups.
We and our partners may collect, use, and disclose information about you and your device through Data Collection Technologies. For more information on our use of Data Collection Technologies, please see our Cookie Policy available here.
We maintain reasonable and appropriate safeguards designed to protect your Personally Information from unauthorized access, use, disclosure, alteration or destruction. For example, we limit our collection and use of your Personal Information to the extent necessary to provide you with the Service. However, we cannot guarantee the security of our systems or your Personal Information, and we encourage you to take reasonable precautions to safeguard your Personal Data.
We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements.
We are committed to complying with this Privacy Policy and the data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Information. We are located in the U.S. and may use facilities in the United States and other countries. When you provide us with your Personal Information or use the Service, we will process and store your Personal Information in the United States and such other countries where we have facilities. We recognize that the laws in the United States and such other countries may be different and, in some cases, not as protective as the laws where you are located. By providing us with your Personal Information or using the Service, you acknowledge that your Personal Information will be transferred to and processed where we operate.
If you are a resident of California, we are providing the following information to you in accordance with the California Consumer Privacy Act (“CCPA”).
This Privacy Policy describes our practices over the last 12 months with respect to categories of information we collect, the sources of that information, and how we have disclosed it. Specifically, in the last 12 months, we have disclosed each category of your Personal Information as follows:
It is not our practice to sell Personal Information for money. However, we understand that under the CCPA, the use of certain types of Data Collection Technologies may be considered a “sale” or “sharing” of Personal Information for targeted advertising. If you have not opted out from the use of certain Data Collection Technologies within the preceding 12 months, your Internet or other electronic network activity information may have been used to serve you targeted advertisements and “sold” or “shared” with providers of Cookies, advertisers, and advertising platforms and networks. We do not knowingly sell or share Personal Information about children under 16 years old.
As a California resident, you have the following privacy rights under the CCPA:
You may exercise your right to know, your right to correction, and your right to deletion twice a year free of charge. To exercise your right to know, your right to correction, or your right to deletion, call us at 8006011293 or email us at oi.knilemoneg@ofni and indicate “California Rights” in the subject line.
We will take steps to verify your identity before processing your request to know, request to correct, 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. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you to verify your identity, such as your name and email address. 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 rights requests. When we verify your agent’s request, we may verify your identity and request a signed document from your agent 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.
We only use and disclose Sensitive personal information to provide the Service and for other purposes specified under California law, including to improve the Service and for safety and security purposes.
Notice of financial incentive. We may offer programs or benefits in exchange for your Personal Information, such as a free trial for the Service or enhanced reporting about your traits or family members. The categories of Personal Information we collect will depend on the program or benefit but may include Identifiers, Demographic information and other protected classifications, Customer records, Internet and other electronic network activity information, Commercial information, Inferences, and Sensitive personal information. Our good faith estimate of the value of your Personal Information is the value of the benefit that we give you, which we have calculated by evaluating our expenses in offering the benefit. Your participation in these programs and benefits is optional and you will not be enrolled unless you choose to opt-in. You may withdraw from the program or benefit at any time by contacting us at oi.knilemoneg@ofni.
Shine the Light – Third Party Marketing. California law permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information at the end of this Privacy Policy. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.
If you are a resident of California, you may be entitled to the following rights regarding your Genetic Information:
To exercise these rights, you can visit https://genomelink.io/profile/ to delete your data or contact us at info@genomelink.io.
Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain Personal Information a business has collected or will collect about you. We do not sell your Personal Information pursuant to Nevada law. For more information about how we handle and share your Personal Information or your rights under Nevada law, contact us at oi.knilemoneg@ofni.
If you are located in the European Economic Area and we maintain your Personal Information, you have the following additional rights (under the European Union’s General Data Protection Regulation (the “GDPR”) with regard to your Personal Information:
Please note that if you decide to exercise some of your rights, we may be unable to provide you with certain services, or you may not be able to use or take full advantage of the services we offer. We may charge you a reasonable fee if you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why.
Our services are not directed to or intended for use by children. If we learn that we have received Personal Information directly from a child without his or her parent or legal guardian’s verified consent (where required by law), we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information.
When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies and terms of use. This Privacy Policy does not apply to any Personal Information that you provide to a third party website or service. We recommend that you read the privacy policy that applies to that third party website or service. A link or reference to a third party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.
The last updated and effective date of this Privacy Policy is posted at the top of this page. We may update this Privacy Policy from time to time to reflect changes in our practices, our industry, or applicable laws. When we make material changes to this Privacy Policy, we will give you advance notice by posting an alert through the Service or by sending you an email to the email address we have on file. The amended Privacy Policy will apply on a go-forward basis to the Personal Information we already collected about you, as well as any Personal Information we may collect in the future. If you disagree with any changes, please let us know by contacting us using the information at the end of this Privacy Policy.
We collect the personal information you provide to us when you purchase our products or visit our website. The categories of information we may collect include:
We may collect personal information about you from third-party sources, including Ad Networks and Other consumers (e.g., referrals).
The categories of information we may collect include:
Ad Networks
Other consumers (e.g., referrals)
We do not retain data for any longer than is necessary for the purposes described in this Policy.
We generally retain data according to the guidelines below.Type of Data | Retention Period |
---|---|
Cookies and online data we collect while you use our website, including Name, Email address, Postal address, Telephone number, Online Identifiers, Internet Activity, Purchases, Credit or debit card number, Genetic information, Sleep, health, or exercise data, General location data, Physical characteristics or descriptions, Age, Sex, gender, or gender identity, Sexual orientation, Race, color, or ethnic origin, National origin, Citizenship or immigration status, Religion or philosophical beliefs, Marital status, Disability, Data related to physical or mental health, Direct communications with your consumers, Inferences created from other personal information collected, Inferences based on sensitive information | We delete or anonymize data concerning your website use when users request data deletion or opt-out. |
Data we collect when you contact us for customer support and other inquiries, including Name, Email address, Telephone number, Purchases | We delete or anonymize data concerning your website use when users request data deletion or opt-out. |
Data we collect when you sign up for promotional and marketing communications, including Name, Email address, Postal address, Telephone number, Online Identifiers, Internet Activity, Purchases, Inferences created from other personal information collected | We delete or anonymize data concerning your website use when users request data deletion or opt-out. |
Data we collect when you review our products, answer surveys, or send feedback, including Name, Email address, Purchases | We delete or anonymize data concerning your website use when users request data deletion or opt-out. |
Data we collect in connection with privacy requests, including Name, Email address, Online Identifiers | We delete or anonymize data concerning your website use when users request data deletion or opt-out. |
Data we collect for security purposes, including Name, Email address, Online Identifiers | We retain security-related data as long as necessary to comply with our legal obligations and to maintain and improve our information security measures. |
Data we collect for research and product development, including Name, Email address, Postal address, Telephone number, Online Identifiers, Internet Activity, Purchases, Genetic information, Sleep, health, or exercise data, General location data, Physical characteristics or descriptions, Age, Sex, gender, or gender identity, Sexual orientation, Race, color, or ethnic origin, National origin, Marital status, Disability, Data related to physical or mental health, Direct communications with your consumers, Inferences created from other personal information collected, Inferences based on sensitive information | We delete or anonymize data concerning your website use when users request data deletion or opt-out. |
We process personal information for the following business and commercial purposes:
We may disclose personal information about you for business and commercial purposes when you purchase our products or visit our website:
Personal Information Category | Categories of Service Providers | Categories of Third Parties |
---|---|---|
Personal Identifiers | Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Customer Support Tools, Cybersecurity Providers, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, and Sales & Marketing Tools | Ad Networks, Data Analytics Providers, Data Buyers, and Payment Processors |
Internet Activity | Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Customer Support Tools, Cybersecurity Providers, Data Analytics Providers, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, and Sales & Marketing Tools | Ad Networks, Data Analytics Providers, and Payment Processors |
Commercial Information | Commerce Software Tools, Contractors, Customer Support Tools, Data Analytics Providers, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, and Sales & Marketing Tools | Ad Networks, Data Analytics Providers, and Payment Processors |
Financial Information | Contractors, IT Infrastructure Services, and Payment Processors | Ad Networks and Payment Processors |
Biometric Information | Contractors and IT Infrastructure Services | Data Buyers |
Location Information | Business Operations Tool, Collaboration & Productivity Tools, Commerce Software Tools, Contractors, Customer Support Tools, Data Analytics Providers, Governance, Risk & Compliance Software, IT Infrastructure Services, Payment Processors, and Sales & Marketing Tools | Ad Networks, Data Analytics Providers, Data Buyers, and Payment Processors |
Physical and Audio Data | Contractors, IT Infrastructure Services, and Sales & Marketing Tools | None |
Protected Classifications and Other Personal Characteristics | Business Operations Tool, Contractors, Customer Support Tools, IT Infrastructure Services, and Sales & Marketing Tools | Data Buyers |
Health Data | Contractors and IT Infrastructure Services | None |
Consumer Communications | Business Operations Tool, Collaboration & Productivity Tools, Contractors, Customer Support Tools, Governance, Risk & Compliance Software, IT Infrastructure Services, and Sales & Marketing Tools | None |
Inferences from Other Data | Contractors and IT Infrastructure Services | Data Buyers |
This section provides additional information for people in the European Economic Area (EEA) or United Kingdom (UK). The terms used in this section have the same meaning as in the General Data Protection Regulation and the UK Data Protection Act (GDPR). The term “personal information” as used in this notice has the same meaning as “personal data” in the GDPR.
The personal data we collect and how we share it is described above in our Privacy Policy.
We may disclose your personal information to the following third party controllers for business purposes:PayPal - Credit Card Processing, PayPal - Pay with PayPal, Venmo, Pay Later. To understand how these parties handle your data, please refer to their respectiveprivacy policies.
We use cookies to improve your experience on our site and to allow us and third parties to personalize the marketing content you see on other websites and social media. Website visitors from European Privacy Law regions can control cookie settings. Manage your region specific consent settings here.
We use these cookies for things like security, logins, site errors, and processing payments. We can't turn these necessary cookies off, but you can control them in your browser.
Cookie Name | Provider | Duration |
---|---|---|
__cf_bm | Cloudflare | 31 Mins |
_cfuvid | Cloudflare | Session |
_cfuvid | Cloudflare | Session |
_dc_gtm_UA-93746410-2 | First Party | 2 Mins |
_gat_gtag_UA_93746410_2 | First Party | 2 Mins |
notice_behavior | First Party | Session |
sessionid | First Party | 2 Months 29 Days |
TAsessionID | First Party | 31 Mins |
These cookies tell us how you use our sites and apps, and provide information to help us improve your experience.
Cookie Name | Provider | Duration |
---|---|---|
__hssc | Hubspot | 31 Mins |
__hssrc | Hubspot | Session |
__hstc | Hubspot | 5 Months 27 Days |
_ga | Google Analytics | 1 Year 1 Month 4 Days |
_ga_TQ4QDRX66K | Google Analytics | 1 Year 1 Month 4 Days |
_gid | Google Analytics | 1 Day |
We use these cookies to enhance functionality and personalize content for you. For example, they allow us to remember you when you return to our website or app. If you do not allow these cookies then some or all of these services may not function properly.
Cookie Name | Provider | Duration |
---|---|---|
hubspotutk | Hubspot | 5 Months 27 Days |
These cookies help us decide which products, services and offers may be relevant for you. We use this data to customize the marketing content you see on websites, apps and social media, and to measure your interactions with that content. We might use these cookies to advertise our products to you when you visit other websites.
Cookie Name | Provider | Duration |
---|---|---|
_fbp | Facebook Ads | 2 Months 29 Days |
_gcl_au | Google Ads | 2 Months 29 Days |
_tt_enable_cookie | Tiktok Ads | 1 Year 25 Days |
_ttp | Tiktok Ads | 1 Year 25 Days |
_ttp | Tiktok Ads | 1 Year 25 Days |
_uetsid | Microsoft Ads | 1 Day |
_uetvid | Microsoft Ads | 1 Year 25 Days |
MUID | Microsoft Ads | 1 Year 25 Days |
VISITOR_INFO1_LIVE | Google Ads | 5 Months 27 Days |
VISITOR_PRIVACY_METADATA | Google Ads | 5 Months 27 Days |
YSC | Google Ads | Session |
We process personal data on the following lawful bases:
Where we process personal data on the basis of our legitimate interests, we pursue the following interests: Research & Product Development, Analyzing Data, Conducting Surveys, Creating Customer Profiles, Delivering Targeted Ads, Improving our Products & Services, Internal Business Operations, Marketing Our Products & Services, Meeting Compliance & Legal Requirements, Operating Our Website or Mobile Apps, Processing Payments, Providing Customer Support, Sending Promotional Communications, Storing and Managing Data, and Tracking Purchases & Customer Data.
We may send the personal data of individuals in the EEA/UK to third countries, including the United States, where it may be stored or processed, for example on our service providers’ cloud servers. When we transfer personal data, we rely either on Adequacy Decisions as adopted by the European Commission (EC) or the UK Information Commissioner's Office (ICO) on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), the EU-US Data Privacy Framework and UK-US Data Bridge agreements, Standard Contractual Clauses (SCCs) issued by the EC or International Data Transfer Agreements (IDTAs) approved by the ICO. Data protection authorities have determined that the SCCs and IDTAs provide sufficient safeguards to protect personal data transferred outside the EEA/UK. You may read more about international data transfer mechanisms at the following links:
Individuals in the EEA/UK have the following rights regarding their personal data.Make a Privacy Request by clicking here. Once you submit a request, we will verify your identity and process your request in most cases within 30 days.
Right to access. You have the right to request a copy of the personal data we hold about you.
Right of portability. You have the right to ask us to transfer your data to another party.
Right to rectification. You have the right to request that we rectify any incorrect information we have about you.
Right of erasure. You have the right to request that we erase (delete) any personal information we hold about you.
Right to withdraw consent. You have the right to withdraw your consent at any time when we rely on your permission to process your personal data.
Right to object. You have the right to object to our use of data about you.
Right to lodge a complaint with a supervisory authority. You have a right to lodge a complaint with a supervisory authority. For more information, you can visit theInformation Commissioner’s Office website at https://ico.org.uk/, or see a list of EU Data Protection Authorities athttps://www.gdprregister.eu/gdpr/dpa-gdpr/.
Genomelink
Kensuke Numakura