Privacy Policy

 

Effective Date / Last Updated: September 13, 2019

 

This Privacy Policy describes the information collected by GenoPalate, Inc. (together with any and all affiliates, “GenoPalate,” “we,” “us,” or “our”) through our website, our online customer portal, including your account, our mobile application ("mobile app") and the related services we provide (collectively, the “Services”) and how that information is used and shared. “Services” includes our DNA testing services, add-on Services, and any software applications we may make available, as well as any emails, texts or other electronic communications sent in connection with the Services.

 

This Privacy Policy is incorporated into and made a part of our Terms of Service.

 

By accessing or using the Services, by clicking "I Agree", or by entering into any agreement with GenoPalate that references this Privacy Policy, you (“you”) agree that you have read and understand this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use the Services.   

 

We reserve the right to modify this Privacy Policy at any time. All changes will be effective immediately upon posting to the Services. Material changes will be conspicuously posted on the Services or otherwise communicated to you.

 

Contents

 

Additional Terms

How We Collect Information

We Collect Information You Provide

Information We Automatically Collect When You Use the Services

How We Use and Share Personal Information

How Long We Retain Your Personal Information

De-Identified Data

Feedback Submitted By You

Information Security

Access by Minors

Third-Party Websites and Services

Access from Outside the United States

Your California Rights

How to Access, Correct or Delete Your Personal Information

Contact Us

 

Additional Terms

 

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, birthdate, 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).

 

When you set-up an account online or through our mobile app, you are required to provide certain personal information such as your name and email address.  To register your DNA test kit you will need to provide your name, email address, age, gender, birthdate and DNA test kit product key code, in addition to the barcode on the saliva sample collection tube in DNA test kit. You also have the option to provide other information such as your height, and weight.

 

Genetic Data.  One type of personal information is genetic data.  When you provide your saliva, 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.

 

Order & Payment Information. Purchases of products or services must be made by credit or debit card. All credit and debit card information is provided directly to our PCI-compliant third-party payment processor. GenoPalate does not directly access, handle, or store your credit or debit card information. To make a purchase, you will need to provide your name and your credit or debit card type, number, expiration date, security code, and billing address. We will maintain a record of the purchases that you make using our website. Our payment processor, Stripe, may use your payment-related information in accordance with the Stripe Privacy Policy.

 

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 menu, 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.

 

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. This information may include your name, contact information, birthdate, age, gender, personal attributes (e.g., weight, height, other body measurements, physical activity levels), dietary information (e.g., food allergies and sensitivities, alcohol intake), health-related information (e.g., medication information, diseases, blood glucose levels, cholesterol levels), family medical histories, mood and wellbeing.

 

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.

 

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 to administer, 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 type of information about your visits to the Services and other websites.

 

Cookies. Our website and mobile app automatically use cookies to track your use of our website and mobile app. Cookies are small pieces of information that are stored on your device’s hard drive by your web browser that provide us information about your activities.

 

Cookies can be either “first-party” cookies or “third-party” cookies. A first-party cookie allows your web browser to talk to the actual website that you are visiting, whereas a third-party cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider.  We do not have access or control over third-party cookies and this Privacy Policy does not cover the use of third-party cookies.

 

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 or Apple'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, Critio) 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. 

 

One type of third-party analytics that we use is Google Analytics.  Google sets cookies and then your web browser will automatically send data to Google. Google uses this data to provide us with reports that we use to improve the website's structure and content. For more information on how Google uses this data that it receives directly from cookies that it places, visit Google’s Privacy Policy and Google’s page on How Google uses data when you use our partners' sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent GenoPalate from using other analytics tools and will not prevent data from being sent to the Services itself or to Google. For more information about how Google Analytics uses cookies to measure user interactions on websites, visit Google Analytics Cookie Usage on Websites. You may disable cookies as discussed above, but that may impact your use and enjoyment of the Services.

 

We also use third-party provides such as Critio, Peaches, and Active Campaign on our web-based platform to enhance our marketing efforts, which includes tracking users via their IP address.  For examples, Critio 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 Active Campaign 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 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 & Video 360 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 allow us to view, analyze, and create remarketing lists using our Campaign Manager data in Google Analytics. Display & Video 360 integration allows us to create remarketing lists in Google Analytics and have those lists available in Display & Video 360. 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 menus based on recommendations, as well as to purchase subscriptions to use additional add-on Services.  

 

Our Social Media Pages. GenoPalate is active on social media, including Facebook, Twitter, and Instagram. GenoPalate reserves the rights to post on its websites and social media pages any comments or content that you post on our social media pages.  Anything you post on Social Media is public information and will not be treated confidentially.  If you connect with Social Media through our Services, certain features may require those Social Media platforms to use cookies, plug-ins, and APIs to enable those features. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy. The Services may use advertising networks and services offered by Social Media platform to deliver advertising content.

 

Embedded Content. The Services incorporate content, including feeds scripts embedded in the Services’ code and visible content (for example, videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content. For example, Vimeo may collect or otherwise have access to usage data on videos embedded on the Services as described in the Vimeo.com Privacy Policy.

 

How We Use and Share Personal Information

 

GenoPalate may share your personal information with the following categories of third parties for the uses described in this Privacy Policy:

 

·        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

 

In addition to the uses and sharing described throughout this Privacy Policy, GenoPalate may use and disclose personal information as described below. We do not use, sell, rent, or otherwise disclose personal information except as stated in this Privacy Policy and as permitted by applicable law.

 

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, and to provide you with information and communications that you request.

 

Provision of DNA Testing Services and Add-On Services - Use and Disclosure of Genetic Data. If you have purchased DNA testing services from GenoPalate, we will use and share genetic data in order to provide you with those DNA testing services in accordance with our Terms of Service. Primarily, this means that the third-party laboratories we have engaged will analyze saliva samples to generate raw data (where you have provided a saliva sample) and GenoPalate will analyze and process that data (and, where applicable, any DNA data uploaded by you), along with your answers to our questionnaires, in order to generate and provide you with customized genetic and nutrition reports.  Other personal information collected when providing the DNA testing services (such as your contact information) is used as described throughout this Privacy Policy. 

 

We also use your genetic data, in a de-identified and / or aggregated format, in order to improve our products and services (i.e. for our own internal research and development purposes). 

 

Except as described in this Privacy Policy, we do not share your genetic data, outside of the GenoPalate company in a personally identifiable format, with any third parties unless you authorize us to do so. We may, however, share genetic data as described in more detail below relating to government/law enforcement requests, with our professional advisors, or with subsequent owners or successors (including as part of due diligence).       

 

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.

 

To Communicate with You.  We may use  personal information to respond to your questions, comments or complaints, to notify you of changes to our Terms of Service or this Privacy Policy, and to provide you with promotional materials and other communications as described above. If you provide us with your telephone number in connection with your account or your orders, we may call you at that telephone number regarding your account and your orders, as well as in response to any questions that may arise. If you contact us for support or assistance in using the Services, we may use personal information to determine whether or not your system meets the minimum requirements needed to access and use the Services and otherwise to contact you regarding your request.

 

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 saliva 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.

 

Business Transactions. In the event GenoPalate undergoes a change in control, acquisition, merger, reorganization, or asset sale, in whole or in part, we may transfer, sell, share, or otherwise disclose personal information to the subsequent owner(s) or successor(s) of the transaction. That owner(s) or successor(s) will be bound by this Privacy Policy as it applies to that information. Also, if GenoPalate (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change in control or reorganization, personal information could be one of the assets transferred to or acquired by a third party.

 

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.

 

With Your Consent. With your consent, we may use and share your personal information in ways not specifically described in this Privacy Policy.

 

How Long We Retain Your Personal Information

 

GenoPalate will retain personal information for as long as it is needed for or otherwise serves the purposes outlined in this Privacy Policy and in accordance with our Terms of Service or other applicable agreement with you, subject to retention periods as required or permitted by applicable law (e.g., tax, accounting, and other legal requirements). GenoPalate and our third party genotyping laboratory will retain certain personal information (e.g., genetic data, date of birth, and sex) as required for compliance with applicable legal obligations, including the federal Clinical Laboratory Improvement Amendments of 1988 (CLIA) and laboratory accreditation requirements.

 

De-Identified Data

 

GenoPalate collects certain data that is not personally identifiable to you.  In addition, GenoPalate may create de-identified or aggregated data from personal information, 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 or any de-identified or aggregated data that it collects or creates. 

 

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.

 

Information Security

 

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 not directed at children under 13 years of age. GenoPalate does not knowingly collect information from children under 13 through the Services.

 

Third-Party Websites and Services

 

The Services may link to, or be linked to, websites and services not maintained or controlled by GenoPalate. GenoPalate is not responsible for the privacy policies or practices of any third parties or any third-party websites or services. This Privacy Policy does not apply to any third-party websites or to any personal or other information that you may provide to third parties.

 

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

 

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 privacy@genopalate.com.  To request that we delete any personal information we maintain about you, please contact us at privacy@genopalate.com

 

We will make reasonable efforts to update or delete your personal information within a reasonable time period of your request.  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, require disproportionate 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 saliva sample to our third-party genotyping laboratory, we cannot return it to you. 

 

Contact Us

 

If you have any questions or concerns regarding this Privacy Policy, contact us by email at hello@genopalate.com or by mail at GenoPalate, Inc.; Attn: Legal Department; GenoPalate Inc, 10437 W Innovation Dr. # 123, Milwaukee, WI 53226.