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Effective Date of January 12, 2022
We at Genoox, along with our related, affiliated, parent, and/or subsidiary companies (“Genoox”, “GNX Data Systems Inc.”, “we”, “our” or “us”) welcome you to utilize our products and services which are available to you through our website and other platforms.
Your privacy is important to us and we are committed to making our practices regarding your personal data fair and transparent.
This Privacy Policy describes how we collect, store, use and disclose personal data regarding individuals (“you”) who: (i) visit or otherwise interact with our website available at genoox.com, or any other website, webpage, platforms or public forms generated through our Service, e-mail, text message or digital ad under our control (collectively – “Sites”); (ii) use or otherwise interact with the Franklin Platform (available at franklin.genoox.com) – our cloud-based analytic tools and applications that allow you to conduct end to end genetic data analysis (“Platform” and “Users” respectively; and together with the Sites – the “Service”).
Specifically, this Privacy Policy describes our practices regarding –
The types of data relating to identified or identifiable individual (“Personal Data”) we collect, store, use and disclose include the following:
Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your data, or to have it processed by us or any of our service providers, please simply do not enter or interact with our Sites, nor use our Service. You may also choose not to provide us with “optional” personal data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.
This Privacy Policy pertains to Genoox’s practices as a “data controller”. Where we process Submitted Data, we act as our Customers “data processor” and process the Submitted Data under the direction of our Customers pursuant to our agreements with them. We do not have a direct relationship with Service Recipients whose personal data we may process in connection with one of our Customer’s use of the Services. If you are a Service Recipient who interacts with a Customer and believe we are processing your personal data on such Customer’s behalf, and would no longer like your personal data to be processed by such Customer, please contact the Customer that you interact with directly with such request.
Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in our Terms of Service (“Terms”).
We collect and control various types of personal data regarding our Users and visitors to our Sites. Such data is collected and generated through your interaction with us or with our Service, through automatic means, or directly from you, from other Users, from our Customers, or from other third parties (including our Service Providers, as defined below). Specifically, this includes the following categories of data:
Submitted Data: The Platform provides our Customers with analysis and insights on Submitted Data submitted to the Platform by a Customer and which can be used as part of the genetic interpretation process. With respect to the Submitted Data, the Customer assumes the role of a ‘data controller’ and Genoox that of a ‘data processor’.
Certain privacy and data protection laws require that prior to processing Personal Data a legal basis for such processing is established. Accordingly, whilst Genoox supports these laws by providing our Customers with features and options for how they use our Services – our Customer is solely responsible for determining whether and how they wish to use our Services and such features, and to ensure that the appropriate legal basis for the processing of Submitted Data have been established, by the Customer, prior to using the Services including providing all necessary notices, and collecting all consent, as required under privacy and data protection laws.
This privacy policy does not apply to the Submitted Data (which is not De-identified Data) as Genoox processes Submitted Data strictly on our Customer’s behalf in its role of a ‘data processor’, in accordance with their reasonable instructions and as further stipulated in our agreements with such Customer.
De-identified Data: When a Customer submits Submitted Data to the Platform, Genoox (in accordance with the processing instructions provided by the Customer) may pseudonymize and render some elements of Submitted Data de-identifiable (such as genetic sequence data or data elements related to specific genetic variants). This de-identified data may then be used as part of our products and services such as providing relevant clinical insights to our Customers.
Data automatically collected or generated: When you visit, interact with, or use our Service, we collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers (as defined in Section 4 below), including through the use of “cookies” and other tracking technologies (as detailed in Section 5 below).
Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device and application data (like type, operating system, mobile device or app id, browser version, locale and language settings used), date and time stamps of usage, the relevant cookies and pixels installed on or interacted with via such device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of visitors and Users in connection with our Service.
User Data received from you: When you contact us or sign up to the Service and create your individual profile (“User Profile”), you provide us with personal data. This would typically include your name, workplace and position, contact details (such as e-mail, phone and address), account login details (e-mail address and passwords which are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. For example, you may provide us with your affiliations, professional background, general location, and activity logs and data; as well as your preferences for using the Service.
You may also send us a “Contact Us” or support requests, or provide us with feedback or reviews, or responses to our surveys or promotions, including by submitting information in an online form on our Service or social media channels, by posting on any of our online public forums or communities, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on an issue you are experiencing, contact information and any other documentation, screen recording, screenshots or other information.
Our Customers may provide us with additional data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), it will not be regarded as “personal data” in most countries.
User Data received from our Customers and Users: Customers and Users may provide us with the contact details of their employees, team members and colleagues, in order for us to contact, invite or subscribe them as Users to our Service. Such data typically includes these individuals’ names and work e-mails, however additional data may be provided at the discretion of those providing it. For the purposes of this Privacy Policy, this data is also regarded as User Data.
Data received from other third parties: We may receive personal data which relates to you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your personal data from its organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business and channel partners, from our service providers, and through the use of tools and channels commonly used for connecting between companies and individual professionals in order to explore potential business and employment opportunities, such as LinkedIn.
Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and visitors visit or use the Sites or Service, which pages they visit and when, which website, ad or e-mail message brought them there, and how they interact with and use our Service and its various features.
We use other types of Personal Data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in providing, maintaining and improving our Service, e.g. in understanding how our Service are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Service to you and others; providing customer service and technical support; and protecting and securing our Users, Customers, visitors, ourselves and our Service.
Where our legal basis for processing is that of ‘legitimate interest’, we rely on our interest in processing your personal data in a way that is necessary and justified while considering any possible risks to you. For example, this may include using certain data elements to improve our Services. We have conducted a Legitimate Interest Assessment to assure such legitimate interest is lawful and proportionate. Please contact us if you would like more information on a specific justification on which we rely.
If you reside or are using the Service (i) in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to share via the Service), your acceptance of our Terms and of this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, to the extent permitted under law in such territory. If you wish to revoke such consent, please contact us by email at [email protected]
Specifically, we use personal data for the following purposes:
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Data Location: We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States, Canada, the European Union, Israel and other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.
While privacy laws between jurisdictions may vary, Genoox is committed to protect personal data in accordance with this Privacy Policy, customary and reasonable industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. For data transfers from the EU or UK to countries which are not considered to be offering an adequate level of data protection, we have entered into Standard Contractual Clauses as approved by the European Commission.
Data Retention: We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
Share De-identified Data or anonymized information with third parties: We may share De-identified Data with third parties for research or commercial activities. Third parties may include academic researchers or commercial entities. Recipients of such De-identified Data are contractually prohibited from attempting to re-identify an individual relating to it. For the avoidance of doubt, Genoox does not share any identifiable personal data of Service Recipients with third parties for the purposes mentioned in this section.
Franklin Community: Some of the Genoox Services enable a User to connect and share information with other Users. Any information you may submit for this purpose – including your User Profile – may be visible to other Users of the Platform. Due to the public nature of such forums, your posts and certain profile information may remain available even after you terminate your User Profile. You represent that any information you share with the community is de-identified so as not to include any information that may identify a Service Recipient and that you are doing so in full compliance with the requirements of all applicable laws and regulations applicable to you and/or the Service Recipient including, but not limited to, those pertaining to privacy and (where applicable) informed consent.
Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.
Service Providers: We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers include providers of Third Party Services (as defined in the Terms), hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics, e-mail and communication distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors (collectively, “Service Providers”).
These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.
Customers and other Users: Your personal data may be shared with the Customer to which you are subscribed as a User (including data and communications concerning your User Profile).
Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Genoox, any of our Users or Customers, or any members of the general public.
Genoox Subsidiaries and Affiliated Companies: We share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should Genoox or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Service.
For the avoidance of doubt, if we are legally obligated to do so, Genoox may share your personal data in accordance with such legal obligations. Additionally, we may also share your personal data subject to your consent (where applicable). Notwithstanding the above, if we have successfully de-identified or anonymized such data so that is no longer identifiable, we may transfer, share or otherwise use such data at our sole discretion and without the need for further approval.
Our Sites and Service (including some of our Service Providers) utilize “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by a User. To learn more about our practices concerning cookies and tracking, please contact us at [email protected].
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, log-in attempts or password reset notices, etc. You can control your communications and notifications settings from your User Profile settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Genoox at any time by sending an e-mail to [email protected], changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
In order to protect your personal data held with us, we are using industry-standard physical, procedural and technical security measures, including data encryption, user authentication, monitoring and access permissions as appropriate. Our commitment to security is further supported by our ongoing, annually reviewed ISO 27001 certification and independent annual penetration testing. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 4 above.
If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR or the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)), such as the rights listed below (each to the extent available to you under the laws which apply to you and subject to any exemptions), please contact us by e-mail at [email protected].
Please note that once you contact us, we may instruct you on how to fulfill your request independently through your User Profile settings; may refer you to your account administrator, who may be the relevant Controller of such personal data referred to in your request (see Section 9 below); may refer you to the relevant Customer, who may be the relevant Controller of such personal data referred to in your request (see Section 9 below); or may require additional information and documents, including certain personal data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
Certain data protection laws and regulations, such as the GDPR or HIPAA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the HIPAA, “covered entity”), who determines the purposes and means of processing; and the “data processor” (or “business associate” where HIPAA applies), who processes the data on behalf of the data controller (or “covered entity” where HIPAA applies). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
Our role as a data controller: Genoox is the “data controller” of Sites, CRM & Prospect Data, User Data, and De-identified Data. With respect to this data, Genoox assumes the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
Our role as a data processor (or business associate where applicable): Genoox is the “data processor” of Submitted Data. Submitted Data will only be processed by Genoox on behalf of our Customer. Accordingly, our Customer shall be deemed the “Data Controller” of such data, and Genoox will process such data on the Customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to our Terms, our Data Processing Agreement or Business Associate Agreement (each, to the extent applicable) and other commercial agreements with such Customer. Genoox’s Service Providers shall act as designated Sub-Processors in these instances. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing, providing data subjects with sufficient information about their personal data, and responding to Data Subject Rights requests concerning the personal data they control).
If you would like to make any requests or queries regarding personal data we process as a Data Processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact the Customer directly.
Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Service. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy, we’ll provide Users with notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending an email. Your continued use of the Service after the changes have been implemented will constitute your acceptance of the changes.
Third Party Websites and Services: Our Service includes links to third party websites, and integrations with Third Party Services (as defined in the Terms). Such websites and Third Party Services, and any information you process, submit, transmit or otherwise use with or to such websites and Third Party Services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and Third Party Services.
Our Service is not directed to children under the age of 18: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected].
Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact Genoox’s support at [email protected]. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU or UK supervisory authority, as appropriate.
