Effective Date / Last Updated: April 1st, 2022
If you participate in beta-testing our products or services, or if you purchase or participate in certain of our add-on Services (e.g. private coaching sessions), additional terms, conditions and policies may apply which will be presented at the time of participation or data collection.
How We Collect Information
The information that we may collect from or about you broadly falls into the following categories:
- Information that you voluntarily provide to us, for example, your contact information, your payment information, and information submitted in the course of receiving or using our DNA testing services.
- Information that we (or our third-party service providers) automatically collect through your use of the Services, for example, data collected by the servers used to operate our website (e.g., IP addresses), data collected by cookies, data collected through your use of our mobile app, and data collected by analytics and advertising services.
We Collect Information You Provide
Personal Information. "Personal information" is information that, alone or in combination with other information, can identify a natural person. You can visit our website without providing us with your personal information, but you will be required to provide personal information in order to purchase DNA testing services and to use certain features of the Services. We will collect any personal information from or about you that you choose to provide to us, which may include your name, email address, telephone number, physical address, billing address, birth date, and payment information. For example, you must provide certain personal information to purchase DNA testing services, to register DNA test kits, when contacting GenoPalate customer support, when receiving and fulfilling information requests, when registering for an account to use the Services, and when responding to communications from us (e.g., questionnaires, surveys, promotional offers).
Accounts. When you set-up an account online or through our mobile app, you are required to provide certain personal information such as your name, email address and other contact information requested. To register your DNA test kit you will need to provide your name, email address, age, gender, birth date, and any other similar information as requested at such time, as well as the DNA test kit product key code and the barcode on the sample collection tube in the DNA test kit. In order to provide you certain Services, we need you to respond to certain questionnaires and/or surveys, whether online, written or verbal.
Questionnaires. We will collect all information you choose to provide in the course of completing any questionnaires or any other forms or surveys we may provide. Some information we request is required in order to use the Services or receive reports from us, such as your name, contact information, birth date, age, gender, zip code, personal attributes (e.g., weight, weight loss goals, height, other body measurements, physical activity levels), dietary information (e.g., special diets, food allergies and sensitivities, alcohol intake), health-related information (e.g., health goals, medication information, diseases, blood glucose levels, cholesterol levels, family medical history), sleep habits, dietary behaviors (e.g., eating habits, food and drink consumption), purchasing habits, mood and well being (e.g., stress levels, motivations), and other similar types of information.
Some information we request from you is optional, but it helps us provide Services more customized to you and our other users, and it helps us provide better Services, such as your food preferences.
As GenoPalate's Services and business plans evolve over time, GenoPalate may modify the types of information and questions that are mandatory versus optional, from time-to-time. We will indicate what information is mandatory when we ask you to fill out the applicable questionnaire or survey. You may opt-out of participating in GenoPalate questionnaires, forms or surveys, however, we may not be able to provide you certain Services or reports without the requested information.
Location. We may ask for your zip code or provide you the option to opt-in to location tracking to provide certain Services to you. For example, we need to know your approximate location in order to help find grocery stores near you. We also use location information to customize our Services to you, to improve the Services, to help us with product development, and to send targeted advertisements to you. You may opt-out of location tracking in the settings within your account or by declining to permit location tracking when prompted.
Genetic Data. One type of personal information is genetic data. When you provide your saliva, buccal swab, blood, urine, stool, or any other cells or fluids sample, it is collected by the designated third-party DNA testing company that we contract with, and they provide your raw genetic data to GenoPalate. When you provide us with your DNA data upload, that upload is provided directly to GenoPalate via uploading a .txt file of your raw genetic data through your GenoPalate online account.
Food Logging; Grocery List. We may collect all information you choose to communicate to us in the course of using the Services, including information that does not personally identify you, such as any food, drinks or alcohol that you log in the food logging or grocery list portion of the Services. We also collect any search queries you make in the Services. When we collect this type of information, we may provide various displays of this information for your convenience, including displays that may add additional information to your data, such as total foods eaten, foods by category, foods shopped for, nutrients and calories eaten and other similar displays.
Emails From Us. If you sign up or otherwise opt in to receive newsletters or promotions from us, you will need to provide your email address. We will use this information to provide you with promotional and other electronic communications. In addition, we will send you information about how to interpret your report when you purchase DNA testing services from us. You may opt out of receiving promotional emails from us at any time by following the unsubscribe instructions contained in the applicable email. We may use third-party email providers to deliver these communications to you.
Add-On Services. We will collect all information you choose to communicate to us in the course of receiving and using our add-on Services, such as our personalized recipes, personalized grocery lists, customized genetic and nutrition reports, and coaching services. For example, if you sign up for coaching services, we will collect the contents of all text messages you send to GenoPalate and all information communicated during telephone coaching sessions with GenoPalate.
Sweepstakes & Contests. We may offer sweepstakes, promotions or contests that you may participate in at your option.To participate you must submit certain information as set forth in the applicable terms and conditions, which may include personal information. Data collected via sweepstakes, promotions and contests will be (i) used to contact you with promotional and related communications, (ii) shared with third-party vendors, and (iii) subject to additional terms provided to you at such time.
Stories. If you submit your story to us on the "Stories" page of our website, you must submit your name, email address and a related message regarding your story. Any such story and related information may become public information, may be posted on our website, and will not be treated confidentially (although we will not post your last name on our website). We will use your stories and related information as described in the Terms of Service.
We Rely on You. We rely on you to provide us accurate and complete information. The Services and reports that we provide may not be relevant, helpful or applicable to you if you provide inaccurate or incomplete information. You should not use the Services unless you provide accurate and complete information.
Information We Automatically Collect When You Use the Services
IP Addresses and Related Data. The servers used to operate and provide the Services may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Services, including Internet protocol (IP) addresses assigned to the devices from where you access the Internet, your Internet service provider (ISP), your device name, year and class, your device ID number and manufacturer, your approximate geographic location, your web browser type, the pages you access on the Services, the websites you access before and after visiting the Services, the length of time you spend on the Services, date and time stamps, and clickstream data.
GenoPalate may use this information toad minister, monitor and analyze the Services, to monitor and help prevent fraud, to investigate complaints and violations of our policies, to track and identify potential marketing leads, to protect our rights and improve security, to improve the Services, to perform targeted advertising, and to help us with product development. The suppliers that we use to provide the Services may collect similar types of information about your visits to the Services and other websites.
Most web browsers automatically accept cookies. You can disable cookies but disabling cookies may impact your use and enjoyment of the Services. Changing your cookie preferences in one web browser will not necessarily carry over to other web browsers. You may not be able to disable operationally necessary cookies.
What information is collected and how is that information used? The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. By way of illustration, the types of information collected by our website’s cookies and the purposes for which that information is used are described below. We may also combine information collected by cookies with other information.
- Operationally necessary (also called essential cookies). These are cookies that are required for the operation of our websites. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of our website to make use of its functions, for example, shopping carts, saved searches, and similar functions. Without these cookies, services that you have requested cannot be provided.
- Functionality related. These cookies allow us to offer you enhanced functionality when accessing or using our website. This may include remembering choices you make, for example, remembering your username, preferences, or settings, remembering if you reacted to something on or through our website so that you are not asked to do it again, remembering if you have used any feature of our website before, restricting the number of times you are shown a particular advertisement, remembering your location, and enabling social media components. You may disable functional cookies, but then various functions of our website may be unavailable to you or may not work the way you want them to.
- Performance related (also called analytical cookies). These cookies assess the performance of our website, including as part of our analytic practices to help us understand how visitors use and interact with our website, for example, which pages on our websites users visit most often. These cookies also enable us to personalize content and remember your preferences (e.g., your choice of language, country, or region).These cookies help us improve the way our websites work and provide a better, personalized user experience. Some of our performance-related cookies are managed for us by third parties.
- Advertising or targeted related. These cookies record your visits to our website, the pages you visit on our websites, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. GenoPalate and its third-party advertising platforms or networks may use this information to make our websites, their content, and advertisements displayed on our websites more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising). These cookies are also used to limit the number of times you see an advertisement, provide aggregated auditing, provide research and reporting for advertisers, help improve our Services, and help measure the effectiveness of advertising campaigns. To find out more about interest-based ads and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.
How long do cookies last? A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the applicable website. Persistent cookies exist for a set period of time, for example, six months or one year. Each time you visit a website that has implemented a persistent cookie, that cookie will remain active until its predetermined expiration date. You can also manually delete persistent cookies.
What about other tracking technologies? The Services may also use the following types of tracking technologies: web beacons (also called clear GIFs), flash cookies, and pixels tags. A web beacon is a tiny graphic with a unique identifier that functions similar to how cookies function. However, in contrast to cookies, web beacons are embedded invisibly on websites. Flash cookies collect and store information about your use of our Services and are commonly used for advertisements and videos. Pixels can be placed on websites or within emails to track your interactions with those websites and when emails are opened.
How can I control, disable, or opt out of cookies? Most web browsers allow users to manage cookies in the browser’s settings. Please note that disabling or otherwise limiting cookies may impact your use and enjoyment of the Services and other websites. For your reference we have included the below links to various web browsers’ instructions on managing cookies.
More information. For more information about cookies, including about advertising cookies and your choices regarding cookies, we suggest you visit:
Mobile App Tracking.
Usage Details. If you are using the Services through our mobile app, GenoPalate and its third-party service providers may automatically collect certain information to help us enable the mobile app and create a better user experience, to provide targeted advertising, and to help us improve the Services. For example, we may collect the time spent on each page, the buttons clicked, the location where the mobile app was accessed and when the mobile app was accessed. We use Amazon Web Services, Inc. ("AWS") and Google Analytics to help us with such data collection.
Geolocation. GenoPalate and its third-party service providers may collect the location of your device for the purpose of improving the Services and other product development purposes, as well as improving your user experience. You may disable this feature by declining to permit us to track your location if prompted.
The App Store. The mobile app store from which you downloaded the mobile app (e.g. Google Play orApple's App Store) ("App Store") also tracks certain information, such as the number, location and time of mobile app downloads and installs.
More About Third-Party Analytics. The Services, including the mobile app, use third-party analytics tools (e.g., Google Analytics, Peaches, Active Campaign, AWS, Data Chat, Criteo) to collect and process data about your use of the Services and other activities online. Our analytics providers may set and read cookies to collect data about your use of the Services and other websites that you visit and your web browser will automatically send such data collected by those cookies to our analytics providers.
Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content, improve the user experience, for product development purposes or to provide and improve targeted advertising to you. We also use data gathered by these third-party analytics companies in public presentations and at conferences, but such data is in a de-identified and aggregated format.
We also use third-party providers such as Criteo, Peaches, and Hubspot on our web-based platform to enhance our marketing efforts, which includes tracking users via their IP address. For example, Criteo enables us to show you advertisements on third-party websites. Peaches enables us to provide you referral codes when you visit our website and refer others to our website, which may be subject to additional terms and conditions. We use Hubspot to help us with our email marketing.
The App Store and some mobile device manufacturers also collect analytics data about download rate and mobile app usage, which they may provide to GenoPalate.
Interest-Based Advertising. The Services may use advertising networks and services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including Google Ads and advertising services provided by Facebook (sometimes referred to as the Facebook “tracking pixel”) and Instagram.
These services collect information about your visits to and interactions with the Services and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your personal information. These targeted advertisements may appear on the Services or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.”
For example, through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Services and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet.
Additionally, we have enabled and implemented the following Google Analytics Advertising Features on our websites: Remarketing with Analytics, Demographics and Interest reporting, Campaign Manager integration, Display & Video360 integration, Google Display Network (GDN) Impression Reporting, and Segments. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the website. Demographics and Interest reporting uses a third-party cookie to collect information about our website traffic by tracking users across websites and across time, which generates a report for us to better understand website users. Campaign Manager integration allows us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video360. Google Display Network (“GDN”) Impression Reporting allows us to measure the impact of unclicked GDN Display ad impressions on website behavior and conversions. Segments allows us to isolate and analyze subsets of website users by sorting our Google Analytics data.
To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Services.
If you have a Facebook account, but do not wish Facebook to collect data relating to you via the Services, we suggest that you: (a) hide social media platform plug-ins using an ad blocker; (b) always log off completely from Facebook before visiting other websites and delete all related cookies; and, (c) where the option is available, disable the advertising services and networks operated by Facebook.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other web browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time.
Other Advertising. When you access your account, we may direct advertisements to you to purchase certain recipes based on recommendations, as well as to purchase subscriptions to use additional add-on Services.
How We Use and Share Personal Information
- Affiliates and employees
- Third-party laboratory for DNA testing services
- Third-party service providers and suppliers
- Third-party partners
- Government/law enforcement
- Professional advisors
- Subsequent owners, assigns and successors
For the Purpose Collected. We will use and share your personal information for the purposes stated or agreed-to (or as was obvious) at the point of collection. For example, we use and share personal information to communicate with you in connection with your orders, to process payments submitted through our website, to administer your GenoPalate account, to provide DNA testing services, to provide other GenoPalate products and services, to provide you with information and communications that you request, and for research and biobanking purposes as further described below.
We also may share certain results, recommendations, and other data or research resulting from your de-identified or aggregated genetic data, so long as it no longer identifies you.
Personalized Analyses Through the Services. As part of the Services, we analyze the information we collect from you, including personal information, and provide you with various reports, views and displays of your information. We sometimes add additional information to your information (e.g. displaying the calorie content of a food item, providing a customized genetic or nutrition report, etc.). IF YOU DO NOT AGREE TO HAVE THIS TYPE OF ANALYSES PERFORMED ON YOUR INFORMATION, YOU SHOULD NOT USE THE SERVICES.
Research and Biobanking. GenoPalate only biobanks your DNA sample if you have signed our "Consent to Biobanking" form found inside of your GenoPalate account. “Biobanking" means that GenoPalate and its third-party genotyping laboratory will store your DNA sample and related personal information for up to 10 years for the research and analyses purposes described in this Section.
If you consent to biobanking, GenoPalate may perform additional research and analyses using your genetic data and DNA sample. In connection with this research, your genetic data may be shared with third parties in de-identified form only and only where the applicable third party has agreed to protect the confidentiality of such information. The types of research and analysis that GenoPalate may perform are further described in our biobanking F.A.Q.s.
Furthermore, GenoPalate only shares your genetic data, DNA sample, and related personal information with third parties for research purposes if you have signed our "Consent to Research" form found inside of your GenoPalate account. GenoPalate may request your this additional consent to permit your genetic data, DNA sample and related personal information to be used in academic or other Institutional Review Board (IRB) approved research (a) by a third party with whom GenoPalate has partnered with to perform research and analyses, and/or (b) by a third party to perform their own independent research and analyses. GenoPalate will not share your biobanked genetic data or DNA sample with any third party (aside from our third-party genotyping laboratory) unless you further consent to such sharing.
Aside from signing our "Consent to Biobanking" form, no additional action is required by you to biobank your DNA sample. Biobanking is provided at no cost to you, and you can withdraw your consent at any time by emailing us at firstname.lastname@example.org. There is no penalty for withdrawing your consent.
To learn more about Research and Biobanking, please see our F.A.Q.s.
Product Development. You understand and agree that we use certain information, including personal information, in part, to help improve our products and services and develop new products and services. When we use your information for such purposes, we first de-identify and/or aggregate any personal information so that it no longer identifies you individually.
Advertising. We may use personal information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our website or mobile app, and for other similar communications.
Sharing Collected Information with Our Third-Party Service Providers and Suppliers. We may share personal information with our third-party service providers and suppliers. These third-party service providers and suppliers include the providers of our DNA test kits and the laboratories that analyze the genetic samples, as well as our website and mobile app management and hosting suppliers, cloud storage providers, IT security providers, payment processors, marketing, advertising and public relations service providers, email service suppliers, suppliers that help us with product development, and shipping label providers. Our third-party service providers and suppliers are authorized to and may use and disclose personal information as necessary for them to provide the applicable services to us and, if applicable, as provided by their own privacy policies.
Evaluation and Improvement of Our Services, User Demographics, and Aggregation. We may use and disclose personal information: to administer, analyze, develop, and improve the content, materials, products, and services that we make available (including the Services); tailor features, customer content and preferences; manage profiles and accounts; troubleshoot problems; recognize you in the Services; to inform marketing and communication plans and strategies; to understand customer demographics and preferences; and to evaluate customer needs and customize website content, promotional emails, and users’ browsing experience. In addition, we may aggregate your personal information and other collected information to create aggregate data on users that describes users as a group but does not reveal the identity of individual users. We may use and share aggregate data in order to understand users’ needs, to determine usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products and services.
Security and Protection of Rights. We may use and share personal information as required or permitted in accordance with subpoenas, court orders, law enforcement requests, and other legal processes. GenoPalate will use personal information and share it with third parties if we believe doing so is necessary to protect our rights or the rights of others, including disclosing information necessary to identify, contact, or bring legal action in the event of a violation of our contracts, terms, or policies.
Professional Advice. We may share personal information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to GenoPalate.
To Send You Push Notifications. The Services will automatically send you certain reminders or "push" notifications, such as reminders to log meals, unless you opt-out by turning off those reminders in your account on the "Settings" page.
How Long We Retain Your Personal Information
Research and Biobanking. If you consent to research and biobanking your genetic data and DNA sample (as described above under the Section titled "How We Use and Share Your Personal Information"), GenoPalate and its third-party genotyping laboratory will retain your genetic data and DNA sample for up to 10 years. You may withdraw your consent to research and/or biobanking at any time by emailing us at email@example.com, in which case your genetic data and DNA sample will be deleted within 90 days. There is no penalty for withdrawing your consent. It may take us up to 90 days to comply with your withdrawal request.
However, your withdrawal of consent will not be effective regarding any uses or disclosures of genetic data, DNA samples and personal information that GenoPalate already used or disclosed in reliance upon your prior consent. For example, if any of your genetic data or DNA sample was used, or is currently in use, in research or analyses that began before you withdrew your consent, GenoPalate and any third party with whom you consented that GenoPalate may share such information with will not delete your genetic data or DNA sample from resulting research or analyses or from any research and analyses in progress.
GenoPalate may create de-identified or aggregated data from personal information it collects, so that it no longer identifies an individual. GenoPalate may use and disclose to third parties de-identified or aggregated information without restriction, in compliance with applicable laws. GenoPalate is the sole and exclusive owner of any research or analyses resulting from or including your personal information, genetic data, or DNA samples.
Feedback Submitted By You
If you submit feedback to us about the Services or anything else relating to GenoPalate, we may use and disclose that feedback for any purposes without compensation to you and we may, in our sole discretion, not treat such feedback as confidential.
We have appropriate technical and organizational security measures in place to help protect against the loss, misuse, and alteration of personal information under our control, including Secure Sockets Layer (SSL) technology, which is used to encrypt information passed between your web browser and our systems. If your personal information is breached, we will notify you if required under applicable law.
You understand that no data transmission over the internet or a mobile device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.
Access by Minors
The Services are only intended for adults who are the age of majority in their state of residence (typically this is 18 or 19 years of age). GenoPalate does not knowingly collect information from children under 18 through the Services.
Third-Party Websites and Services
Access from Outside the United States
If you are accessing or using the Services from outside the United States, please be aware that personal information may be transferred to, stored in, and processed in the United States (where our and our suppliers’ servers and databases are located and operated). Certain governmental authorities may not consider the level of protection of personal information in the United States to be equivalent to that required by the in other jurisdictions.
Your California Rights
If you are a California resident, you are permitted, pursuant to California Civil Code Section 1798.83, to obtain: (a) a list of all third parties that we may have disclosed your personal information to, within the past year, for direct marketing purposes; and (b) a description of the categories of personal information disclosed. To obtain such information, please email your request to the contact information set forth in the "Contact Us" section below.
If you are a California resident under eighteen (18) years old, you can request that we remove content or information that you have posted to our Services (California Civil Code Section §22581) by contacting us a per the "Contact Us" Section below.
WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
How to Access, Correct or Delete Your Personal Information
Generally. To access or update your personal information as it exists in our records, please visit the account settings section of your GenoPalate account (if applicable) or contact us at firstname.lastname@example.org. To request that we delete any personal information we maintain about you, please contact us at email@example.com.
Biobanking. To withdraw your consent for biobanking and request that we delete the bio banked information, please email us at firstname.lastname@example.org.
We will make reasonable efforts to update or delete your personal information within a reasonable time period of your request. It may take up to 90 days to comply with your request to delete information that was previously part of our Biobank. However, we may decline to delete certain personal information if we have a business reason for doing so (e.g. as reasonably necessary to comply with our legal obligations, to enforce agreements, to resolve disputes, etc.), as permitted by applicable law. We may require you to prove your identity before providing you access to, updating, or deleting your personal information. Except as prohibited by applicable laws, we may decline to process requests that are unreasonably repetitive, required is proportionate technical effort, jeopardize the privacy of others, or would be extremely impractical.
However, the third-party genotyping laboratory will retain your personal information, including genetic data, as required for compliance with applicable legal obligations, including the federal Clinical Laboratory Improvement Amendments of 1988 (CLIA) and laboratory accreditation requirements. Once you submit a genetic sample to our third-party genotyping laboratory, we cannot return it to you.