Privacy Policy

Last updated: 2/19/2024

This Privacy Policy describes how Precision Epigenomics Inc (“we” or “us”) collects, uses, and shares your personal information when you use our website https://precision-epigenomics.com/ (the “Site”).

For more information on the use and disclosure of information collected about or from residents of California and Virginia, please see Our Privacy Notice. The Privacy Notice supplements this Privacy Policy. If there is any conflict between this Privacy Policy and the Privacy Notice, the Privacy Notice will control solely with respect to information relating to residents of California and Virginia. If you are a resident of California, Colorado, Virginia, Utah, and Connecticut, you acknowledge our Privacy Notice.

Topics:

•  Personal information we collect
•  How we use your personal information
•  How we share your personal information
•  How we store your data
•  Email marketing
•  Behavioral advertising
•  Your data protection rights
•  Third party websites
•  Changes
•  Contact Us

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. 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 use Device Information for:

• Functionality: To recognize you on our website and recognize your previously selected preferences, including your preferred language and your location.
• Advertising: To collect information about your visit, the content you viewed, the links you followed, and information about your web browser, device, and IP address. We sometimes share limited aspects of this data with third parties for advertising purposes.

You can set your browser not to accept cookies, and the website above tells you how to remove cookies from your browser. Some of our website features may not function if you disable cookies. 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.

We also collect data you provide to us directly. We refer to the data you provide as “Provided Information.” We collect and process data you provide when you:

• Register online or place an order for any of our products or services
• Voluntarily complete a customer survey or provide feedback on any of our message boards or via email
• Communicate by email, phone, or fax.

The Provided Information we collect may include:

• Personal identification information (name, email address, phone number, etc.)
• Billing information (billing address, shipping address, payment information, including credit card numbers, etc.)
• Personal medical information

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Provided Information.

How we use your Personal Information

We use the Provided Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, delivering products, and providing you with invoices and/or order confirmations). Additionally, we use Provided Information to:

• Communicate with you;
•  Screen our orders for potential risk or fraud; and
•  When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

 We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

How we share your Personal Information

 We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our visitors use the Site – you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.]

The types of third parties with whom we might share elements of your Personal Information include:

• Payment processors engaged by us to securely store and handle payments information, such as credit or debit card information
• Providers of email management and distribution tools
• Providers of security and fraud prevention tools and services
• Providers of data aggregation and analytics software services that allow us to effectively monitor and optimize our site

We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

How we store your data

We securely store your data at through Amazon Web Services.

We use commercially reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of information stored on our servers. Of course, no computer network or data transmission on the internet can be guaranteed to be 100% secure and so you submit your information at your own risk.

We will maintain your Personal Information for our records unless and until you ask us to delete this information.

Email Marketing

If you make a purchase on this Site and/or opt in to receive emails, you agree to receive email communications from this site, including but not limited to newsletters, site updates, promotions, and other announcements and correspondence. We are not responsible for the receipt of any such emails. You are responsible for ensuring that our email address(es) are not blocked or forwarded to your spam folder.

You have the right at any time to stop us from contacting you for marketing purposes. If you opt to unsubscribe from receiving emails, you understand that you may no longer receive information or updates from this Site, including promotions.

Behavioral advertising

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 by using the links below:

• Facebook: https://www.facebook.com/settings/?tab=ads
• Google: https://www.google.com/settings/ads/anonymous
• Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

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/.

Your data protection rights

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. Under certain conditions, you may also have the right to restrict or object to our processing of your data, and to request that we transfer your Personal Information to another organization. If you would like to exercise any of these rights, please contact us through the contact information below.

Additionally, if you are a European resident, we note that we are processing your information to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Please note that your information will be transferred outside of Europe, including to Canada and the United States.

Third Party Websites

Our privacy policy applies only to our website. We are not responsible for the data collection, privacy practices or policies of any third-party site to which we may provide a link or that may link to our site. We encourage you to read the privacy statement and terms of use of other sites.

Changes

We may update this privacy policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Complaints

Please contact us if you have any complaints about how we use your Personal Information so we can resolve the issue whenever possible. Residents of the European Union also have the right to lodge a complaint with your local data protection regulator, such as the Information Commissioner’s Office in the UK.

Contact

For more information about our privacy practices, if you have questions, or if you would like to exercise your data protection rights, please do not hesitate to contact us.

Email us: support@precision-epigenomics.com

Call us:

520-372-7522

Write to us:

630 N. Alvernon Way, Suite 280B

Tucson, AZ 85711

This Privacy Notice for U.S. State Residents applies to residents of California, Colorado, Virginia, Utah, and Connecticut and contains information required by the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act, the Colorado Privacy Act (“CPA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Utah Consumer Privacy Act (“UCPA”), and the Connecticut Data Privacy Act (“CTDPA”) (collectively, “U.S. State Data Protection Laws”), as amended or replaced from time to time, along with any implementing regulations, and tags along with the Privacy Policy 

The Company applies certain privacy controls to all U.S. customers. For example, all customers can request a copy of their data, request deletion, and control their privacy settings in their Account Settings. This notice makes sure we cover state-specific requirements. In the event of any conflict between the terms of this notice and the Privacy Statement, the terms of this notice prevail. 

Here is a summary before we dive into the details:

• You have the right to know whether we sell or share your Personal Information and opt-out of a sale or sharing of your Personal Information with a third party.
• You have the right to receive an overview of the Personal Information we collect, how we use it, and who we share it with.
• You have a right to limit use and sharing of your sensitive Personal Information.
• You have the right to access your Personal Information and get a copy of it.
• You have the right to correct inaccurate Personal Information.
• You have the right to delete your Personal Information.
• You or your authorized agent can always contact us if you have a question at [privacy email]

Your Rights

When we talk about “Personal Information” in this notice, we mean any information that identifies, relates to, describes, is capable of being associated with you, or could reasonably be linked, directly or indirectly, with you, and as otherwise defined in the U.S. State Data Protection Laws. The U.S. State Data Protection Laws do not consider publicly available information, deidentified, or aggregate consumer information as “Personal Information.”

We will not attempt to reidentify deidentified information (except as necessary to test our deidentification processes to ensure no individuals can be identified) and will use it only in deidentified form.

Let’s start with your privacy rights first. You have the right to:

• Know what Personal Information we collect, use, disclose, share, or sell.
• Receive a copy of your Personal Information.
• Correct inaccurate Personal Information.
• Delete your Personal Information.
• Receive your Personal Information in a portable and, if technically feasible, in a readily usable format.
• Opt out of targeted advertising; the sale or sharing of your Personal Information with third parties; and/or, profiling in the furtherance of decisions that produce legal or similarly significant effects. Please see our Cookie Choices page for more information.
• Limit the use and sharing of your sensitive Personal Information. Sensitive Personal Information includes, but is not limited to, Personal Information that reveals your racial or ethnic origin, religious beliefs, mental or health conditions or diagnosis, sex life or sexual orientation, citizenship or immigration status, genetic data, precise geolocation, or as otherwise defined in applicable U.S. State Data Protection Laws. Your Company Registration Information, Genetic Information, and Self-Reported information likely include sensitive Personal Information.
• Not receive discriminatory treatment if you exercise your privacy rights.

To make a privacy rights request, or to appeal an action we made related to your privacy request, you can email us at [email] with the subject line “Privacy Rights Request”. We will require some additional information to verify your identity in order to process your request. Alternatively, you may exercise your privacy rights through an authorized agent. If you use an authorized agent, we will require you to verify your identity and confirm that you have provided the authorized agent permission to submit the request on your behalf.

We will respond to your request within 45 days, and in more difficult cases we may extend our response time by another 45 days. Your rights under the U.S. State Data Protection Laws are not absolute and Company may exercise limitations or exemptions as permitted by the U.S. State Data Protection Laws.

Notice of Right to Opt-Out of Sale/Sharing

Like many websites, Company uses cookies (including other tracking technologies) for targeted or cross-context behavioral advertising. Cookies require your Web-Behavior Information to work.

Under the CCPA, this use of your data for cross-context behavioral advertising may constitute a “sale” or “sharing” of personal information. We let advertising providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our sites and apps when you use our online service. In the past 12 months, these categories of personal information may have been “sold” or “shared” as defined under CCPA. We do not have actual knowledge of selling or sharing personal information of users under the age of 16.

Company believes in providing you with a frictionless experience by responding to Global Privacy Control (“GPC”) signals sent by your browser or mobile device. A GPC is a signal from your browser that notifies us of your privacy preferences, such as whether or not you want us to drop cookies on your device. To check your GPC preferences, check out the settings or extensions in your browser or mobile device. Learn more about GPC. Otherwise, you can always opt-out of cross-context behavioral or targeted advertising any time via the Cookie Choices page.

File a complaint under the California Genetic Information Privacy Act or the Virginia Genetic Information Privacy Act

We encourage you to reach out to us with any complaints or concerns at [email]. If you choose to contact us directly by [website/email/phone/in writing], you will need to provide us with:

• Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf. 

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

Residents of the state of California or the state of Virginia may also file complaints if they believe certain rights were infringed under the California Genetic Information Privacy Act or the Virginia Genetic Information Privacy Act.

If you are a California resident, you may file a complaint with the California Attorney General, or your California county district attorney. Residents of cities with more than 750,000 residents may file a complaint with their city attorney, and residents of cities with full-time city prosecutors may file a complaint with their city prosecutor. If you wish to file a complaint with your district attorney, city attorney, or city prosecutor, contact their local office for more information.

If you are a Virginia resident, you may file a complaint with the Virginia Attorney General, or contact the Virginia Consumers Protection Hotline at 1-800-552-9963.

What We Collect

As detailed in our Privacy Statement, we collect Personal Information for various purposes with privacy principles in mind.

Below, we describe the categories of Personal Information as defined under the CCPA for California residents and may include reference to certain key definitions from our Privacy Statement. Some of the categories below require separate opt-in consent and these categories do not necessarily reflect all types of information that we may collect about you. We will provide you with separate notice if we collect any additional Personal Information about you. Some Personal Information included in the categories may overlap with other categories.3

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

In the last twelve (12) months, we have collected the following categories of Personal Information:

• Identifiers: Registration Information and information contained in Web-Behavior Information and/or User Content such as your name, display name, address, online identifier, IP address, email address, username, or other similar identifiers.
• Personal information categories listed in the California Customer Records provisions: Certain information from Registration Information (including payment information), certain User Content (such as your name, address, or phone number), and/or certain Self-Reported Information (such as details about your employment or education).
• Characteristics of protected classifications under California or federal law: Certain information from Registration Information, Self-Reported Information, and/or User Content, such as your age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, and genetic information (including familial genetic information). You can review protected classes under California law here.
• Commercial information: Certain information from Self-Reported Information and/or User Content such as products or Services purchased, obtained, or considered, survey responses regarding past purchasing history, information about products you purchased or considered, or other purchasing or consuming histories or tendencies.
• Audio, electronic, visual, thermal, olfactory, or similar information: Certain information from Self-Reported Information and/or User Content you provide to us through surveys or other engagement on our platform, such as when you upload a profile picture.
• Professional or employment-related information: Certain information from Self-Reported Information and/or User Content such as education, household income, occupation, and other professional information. This information can be collected when you apply for a job with Company, fill out a survey, or otherwise engage with us.
• Biometric information: Certain information from Self-Reported Information and/or User Content such as physiological, behavioral, and biological characteristics that can be used to establish an individual’s identity. To the extent we collect this information, we collect it directly from you when you choose to share it with us.
• Internet or other electronic network activity information: Web-Behavior Information such as data generated from your use of our Services and collected through log files, cookies, web beacons, and similar technologies. Such information may include your browser type, domains, page views, how long you spent on a page or feature of the website, or other data about your engagement with our Services.
• Geolocation data: Web-Behavior Information that includes the identification or estimation of physical location or movement.
• Inferences drawn from other personal information: Inferences and Derived Data includes any information, data, assumptions, or conclusions Company infers based on analyses of facts, evidence, or another source of information or data. Company may derive Genetic Information, such as imputed genotype data, genetic risk scores, and phenotypes (which are observable characteristics or traits). Generally this information is created by Company and not collected directly from you. Company may derive information from data that was collected in relation to our genetic testing services, directly from you, or through tracking technology.
• Sensitive personal information: Genetic Information, and certain Registration Information, Sample Information, and Self-Reported Information may be considered “sensitive.” This includes data that reveals your: social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; mail, email, and/or text messaging contents where Company is not an intended recipient; and genetic data.

Company may access publicly available information or public records from federal, state, or local government records (e.g., vital records, census data).

How We Use Your Personal Information

As defined under the CCPA for California residents, Company may use Personal Information listed above for the purposes described below or at your direction. Such purposes include:

• Providing Services: To provide our Services to you, including maintaining or servicing your account, providing customer service, processing or fulfilling orders and transactions, and more.
• Audit: Auditing related to a current interaction and concurrent transactions, or compliance with applicable laws or standards.
• Security and Integrity: Detecting security incidents, maintaining integrity, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging: Debugging to identify and repair errors that impair existing intended functionality.
• Transient Use: Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with our business, provided that your Personal Information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction.
• Advertising and Marketing: To provide advertising and marketing to you, including cross-context behavioral advertising. Check out our Cookie Choices for more information on how we use your Web-Behavior Information for cross-context behavioral advertising.
• Research and Development: Internal research that Company performs to improve and develop its products and services.
• Quality Assurance and Product Improvement: Activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Company, and otherwise to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Company.

If you have given your explicit consent, for example via a data transfer authorization or other consent document, we may use, disclose, or share your Personal Information for commercial or research purposes to third parties. The purpose, such as recruitment for external research or participation in Company Research, may vary and will be described in the consent at that time.

In the past 12 months, we have disclosed Personal Information to service providers and contractors for the business purposes described above, and to third-party advertising and marketing companies for cross-context behavioral or targeted advertising.

We do not use or disclose sensitive Personal Information for purposes other than the business purposes permitted by CCPA, which include, for example, to perform our services, to detect and prevent security incidents, to perform services on behalf of the business, and other purposes as allowed by CCPA.

Changes to this notice

Company will periodically review and update this notice. We recommend visiting this page to stay aware of any changes. If we modify this notice, we will make the revised notice available through our website.