Privacy Policy

 

Last Updated: September 12th, 2018

This Privacy Policy describes the information collected through this website, the online customer portal, and the online and related services we provide (together with this website, 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.

GenoPalate, Inc. (together with any and all affiliates, “GenoPalate,” “we,” “us,” or “our”) and its suppliers may collect or receive the types of information described below in connection with your access to and use of the Services (together, “Collected Information”). This Privacy Policy is incorporated into and made a part of our Terms of Service.

By accessing or using the Services or by entering into our Terms of Service or any other 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.

If you have any questions or concerns about our use of your personal information or other information collected through the Services, please contact us using the contact information provided at the end of this Privacy Policy.

Contents

  • Information We Collect and How We Collect It

  • Personal Information and Other Information You Provide

  • Other Information We Collect

  • How We Use and Share Collected Information

  • How Long We Retain Your Personal Information

  • Information Security

  • Access by Children

  • Third-Party Websites and Services

  • Access from Outside the United States

  • How to Access Your Personal Information

  • Contact Us

Information We Collect and How We Collect It

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 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, and data collected by analytics and advertising services.

Personal Information and Other Information You Provide

Personal Information. 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 your personal information to purchase DNA testing services; to register DNA test kits; when contacting GenoPalate customer support; when receiving and fulfilling information requests; and when responding to communications from us (e.g., questionnaires, surveys, promotional offers).

We will use personal information as described below in this Privacy Policy, including to process your orders for products and services, to communicate with you in connection with your orders, to administer your GenoPalate account, to provide DNA testing services, and to provide you with information and communications that you request or that we believe are relevant or may be of interest to you, subject in each case to applicable laws and the terms of this Privacy Policy. If you provide your mobile or other telephone number to us, you consent to receiving telephone calls from us at that telephone number as described below.

Mailing List Information. 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. 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.

DNA Testing Services. To register your DNA test kit you will need to provide your name, email address, and DNA test kit product key code, in addition to the barcode on the saliva sample collection tube in DNA test kit. You will need to mail a sample of your saliva to a designated third-party laboratory in order for us to perform the DNA testing services. If you instead purchase a DNA data upload, you will need to provide us with that data by this via uploading a .txt file of your raw genetic data through your GenoPalate online account.

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 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 our Product Questionnaires or any other forms or surveys we may provide. This information includes 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), and family medical histories.

Other Information We Collect

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 computers and other devices from where you access the Internet, your Internet service provider (ISP), your device ID number, 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 the Services and its servers, to generate statistical information, to monitor and analyze Services traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, to track and identify potential marketing leads, and to improve the Services’ content and the products, services, materials, and other content that we describe or make available through the Services (see also how we use analytics services as described below). We may combine this information with other Collected Information (including personal information) and information obtained from third parties for security reasons and to protect our rights or the rights of others as discussed below. The suppliers that we use to provide the Services may collect information about your visits to the Services and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained further below under “Cookies.”

Cookies. Our website automatically uses cookies to track your use of our website in order to facilitate and enhance the user experience on our website and for other purposes as described below. Cookies are small pieces of information that are stored on your device’s hard drive by your web browser. Our website may use both cookies that we implement and cookies implemented by our suppliers and other third parties. We use cookies to track how you access and use our website, to learn when and how users visit our website, to learn how popular website pages are and aren’t, to learn which search terms are used to find our website, and to learn which websites direct you to our website. We also use cookies to help display certain information on our website and to improve your enjoyment of our website, for example, by remembering your contact and other information when you access or use our website.

A cookie can either be a “session” cookie or a “persistent” cookie. Cookies can also 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.

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, so you may need to adjust your preferences each time you get a new computer, install a new web browser, upgrade an existing web browser, or alter or delete a browser’s cookie file. Our suppliers may use cookies and other tracking technologies, such as pixel tags, to track website visitors across the Internet to understand how you get to our website. We do not have access or control over these cookies and this Privacy Policy does not cover the use of third-party cookies.

Due to this automatic collection of data using cookies, we do not honor “do not track” requests.

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 are used are described below. We may also combine information collected by cookies with other Collected 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 search, 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 to remembering choices you make, for example and as applicable, 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. As described above, you may disable functional cookies, but if you do so 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 party 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. However, we don’t allow those third parties to use the cookies for any purpose other than those listed above.

  • 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 and to 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, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.

How long do cookies last? Session cookies exist only for so long as you are visiting the applicable website. Session cookies are typically deleted or removed when you exit or quit your web browser application. 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 as discussed below.

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 (also called pixel 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.

More about behavioral advertising. Advertising cookies and related tracking technologies help us serve relevant advertisements to you more effectively. They also help us provide aggregated auditing, research, and reporting for advertisers, understand and improve our service, and know when content has been shown to you. To learn more about advertising cookies and behavioral advertising and your choices, please visit the Digital Advertising Alliance, the Network Advertising Initiative, the Interactive Advertising Bureau (IAB) Europe, http://www.allaboutcookies.org, and http://www.youronlinechoices.com.

What are my choices? How can I control, disable, or opt out of cookies? Most web browsers allow users to manage cookies in the browser’s settings. For example, a web browser may allow you to reject cookies from certain websites, reject certain types of cookies (e.g., advertising cookies) regardless of the website, reject or disable all cookies from all websites, and/or delete cookies stored previously. Some web browsers also give you the option of being notified every time a cookie is sent to your web browser by a website.

Please note that disabling or otherwise limiting cookies may impact your use and enjoyment of the Services and other websites. For example, our website may not be able to be personalized for you, our website may no longer capture or remember your preferences or other choices you have made on our website in the past, our website may not remember your log-in information, contact information, or other information you have entered using our website, and our website may not recognize the device(s) you use to access our website. 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:

Analytics. The Services uses third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Services, including when you visit the Services, URLs of the websites that you visit prior to visiting the Services and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send 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. For more information on how Google uses this data, 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.

 Advertising Networks, Personalized Advertising, Remarketing, and Retargeting. From time to time the Services may use or participate in advertising networks and related advertising 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, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.

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 Site. Demographics and Interest reporting uses a third-party cookie to collect information about our Site traffic by tracking users across websites and across time, which generates a report for us to better understand Site 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 Site 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.

Our Social Media Pages. GenoPalate is active on social media, including Facebook, Twitter, and Instagram. You may have the opportunity to comment on those social media platforms regarding GenoPalate and the products and services we offer. 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.

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 Collected Information

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

Purpose Collected & Communication with You. We will use and share your personal information and other Collected Information for the purpose for which it was collected, for example, to process and 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 (as further discussed below), to provide other GenoPalate products and services, and to provide you with information and communications that you request. We may use Collected Information to notify you of changes made to the Services (for example, 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 Collected 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.

Provision of DNA Testing Services and Add-On Services. If you have purchased DNA testing services from GenoPalate, we will use and share Collected Information in order to provide you with those DNA testing services you have ordered 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.

If you have purchased coaching services from GenoPalate, you will be presented with a separate Terms of Service Agreement and Privacy Policy that only applies to those coaching services.

Sharing Collected Information with Our Suppliers. We may share Collected Information with our suppliers as necessary for us to provide the Services, to engage in the use and sharing of Collected Information as permitted by this Privacy Policy, and as may be otherwise permitted by applicable law. These suppliers include the providers of our DNA test kits and the laboratories that analyze saliva samples, as well as our website management and hosting suppliers, cloud storage providers, IT security providers, payment processors, marketing and public relations service providers, email service suppliers, and shipping label providers. Our suppliers are authorized to and may use and disclose Collected 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 Collected Information: to analyze, develop, and improve the content, materials, products, and services that we make available (including 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.

Relatedly, we may provide aggregate information about our customers, website users, website traffic patterns, and related information to our affiliates and other third parties. We may also combine Collected Information with other information in our possession for purposes of using information as described in this Privacy Policy.

Security and Protection of Rights. We may use and share Collected Information as required or permitted in accordance with subpoenas, court orders, law enforcement requests, and other legal processes. GenoPalate will use Collected Information and share it with third parties if we believe doing so is necessary to operate, and 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 Collected 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, Collected Information could be one of the assets transferred to or acquired by a third party.

With Your Consent. With your consent, we may use and share your personal information and other Collected 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’s 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 information, 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.

 Information Security

GenoPalate does not guarantee that loss, misuse, or alteration of Collected Information will not occur, but we have appropriate technical and organizational security measures in place to help protect against the loss, misuse, and alteration of information under our control, including Secure Sockets Layer (SSL) technology, which is used to encrypt information passed between your web browser and our systems. The storage and communication of information can never be completely secure, so we do not guarantee that communications or other information that you submit or that are otherwise provided to us will be completely secure. If you become aware of any breach of Services security or this Privacy Policy, please notify us at privacy@genopalate.com immediately. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.

 

Access by Minors

The Services are not directed at children under 13 years of age. GenoPalate does not knowingly collect or use 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. You should read the privacy policy for each website that you visit.

 

Access from Outside the United States

If you are accessing or using the Services from outside the United States, please be aware that Collected 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). The data protection and related laws and regulations of the United States might not be as comprehensive as those in the country from which you access the Services.

 

How to Access 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 hello@genopalate.com.

 

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., 2140 N Prospect Ave., Milwaukee, Wisconsin 53202.