Privacy Policy

Last Updated: November 13th, 2024

SUMMARY

This Privacy Policy describes how Probably Genetic Inc. (collectively, “Probably Genetic,” “we,” or “us”) collects, uses, and discloses information about you when you access or use our websites and other online products and services that link to this Privacy Policy (collectively, our “Services”). This Privacy Policy also describes the choices you have to protect your personal information.

Residents of Washington state may visit our Consumer Health Data Policy for more information.

Personal information we collect
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‍Information you provide to us:

• Contact information, such as your name, email, telephone number, and address.
• Demographic information, such as your gender, nationality, date of birth, and language preferences.
• Intake responses, chat logs, or form-fills,  including any information you submit to our online health & symptom assessment which could include information about your or your family’s medical history, health conditions, symptoms, treatments, healthcare provider information as well as any photos, videos, or files you submit.
• Feedback or correspondence, such as information you provide when contacting us with questions, or provide feedback, product reviews, or otherwise correspond with us.

Information we obtain from third parties:

We use the information you provide to:

• Genetic profile information, lab tests, and electronic health records. If you are eligible and choose to be tested by Probably Genetic, you may authorize the release of your lab results and other health information to us, which may include lab test results, genetic profile and sequencing information, information about potential genetic conditions, and other diagnostic information. We will also receive your electronic health records from your healthcare provider where authorized by you.
• Social media information. We maintain pages on social media platforms, such as Facebook, X, Instagram, YouTube, and others. When visiting or interacting with our pages on those platforms, the platform provider’s privacy policy will apply to such interactions and their collection, use and processing of personal information. We may also receive information that you or the platform provide us and we will treat such information in accordance with this Privacy Policy.

Automatic data collection. We automatically log information when you use the Services, such as the type of computer or mobile device accessing our Services, and interactions over time with our Services. This information includes:

• Your actions on the Services, such as pages or screens viewed, how long was spent on a page or screen, browsing history, navigation paths between pages or screens, account and profile settings, information about activity on a page or screen, access times, and duration of access, and whether marketing emails were opened or links within them clicked.
• Device data, such as the computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, and general location information (derived from IP address) such as city, state or geographic area.

We and our third-party partners use cookies, pixels, and other similar technologies to collect information automatically. For more information, please see our Cookie Policy.

How we use personal information

To operate and deliver the Services in accordance with our Terms of Service, including for:

• Account creation, including registering and identifying you as a user setting up your profile, and logging and saving your account and settings.
• Providing, operating, maintaining, and securing your account and the Services, and allowing you to engage with features of the Services as well as to communicate with other users of the Services.
• Communicating with you about the Services, including by responding to questions, providing customer support, and sending announcements, updates, security alerts, and support and administrative messages.
• Resolving disputes and troubleshooting problems.

For business and product development. We may use personal information for legitimate interests such as to analyze and improve the Services, develop new products and services, identify usage trends, and operate and expand our business activities. This includes using information we receive to fine-tune, train and improve the performance of our AI models. We may also deidentify or aggregate personal information and use it for our lawful business purposes, including to analyze and improve the Services and for benchmarking purposes.

Marketing and advertising. We may use your personal information for our legitimate interests to promote and market our Services (where required by applicable laws, we will ask your consent before engaging in these activities). Our marketing and advertising includes:

• Direct marketing, including sending you newsletters and email marketing in accordance with your preferences, providing you offers, guides, events, webinars, and relevant promotions, and tailoring communications with you to accommodate your areas of interest and focus.
• Interest-based advertising. We may engage third-party advertising companies to display ads promoting our services across the web. These companies may use cookies and similar technologies to collect information about interactions over time across the Internet and use that information to serve online ads that they think will be of interest.

For compliance, fraud prevention, and safety. We may use personal information for our legitimate interests and in accordance with our legal obligations to: (a) comply with applicable laws, including where necessary or appropriate to respond to legal process, such as to respond to subpoenas or requests from government authorities; (b) protect our or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the terms and conditions that govern the Services; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

How we use and protect health information

• Intake responses, chat logs, or form-fills, including any information you submit to our online health & symptom assessment. The information you provide on our Services is used to evaluate your eligibility for genetic testing, to inform you of clinical trials and treatments that may be relevant to you, and in accordance with any consent or authorizations you provide to us.
• Genetic profile information, lab tests, and electronic health records. We use this information to provide access to genetic counseling in connection with our partner providers and counselors. Where authorized by you, we may also disclose this information to your healthcare provider and to other parties, such as biopharma partners, to enable you to explore relevant clinical trials, therapies, and treatment options.

We may also use this information, where permitted by applicable laws, for compliance, fraud prevention and safety purposes, and for our internal business and product development purposes.

Job applicants

When you submit an application for a position with us, we collect the personal information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities such as for candidate selection and monitoring recruitment statistics. We may also use this information to provide improved administration of the Services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Policy or our terms.

How we share personal information

Lab testing, counseling, and other health partners. We share personal information with health partners in connection with the Services, and where authorized by you. This may include your healthcare provider, our partnering physician network, genetic counselors who provide counseling, the laboratory we contract with for sequencing, bioinformatics partners we contract with for sequencing data analysis, and biopharma partners that offer relevant clinical trials, treatments, and therapies. 
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‍Service providers. We share personal information with service providers that help us operate the Services, such as hosting services, cloud services, information technology services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. We also rely on third-party AI service providers to power our AI features. 
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‍Advertising partners. We share information with third-party advertising companies to help us promote our Services to you and other potential users, including for interest-based advertising. We do not share health information with these partners.
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‍Professional advisors. We may disclose personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
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‍For compliance, fraud prevention and safety. We may share personal information for the compliance, fraud prevention, and safety purposes described above.
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‍Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Privacy choices

Access or update account information. Users who have registered for an account with us, may review and update certain personal information in their account profile by logging into the account.

‍Opt out of marketing communications. Recipients of marketing emails may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email or by contacting us as provided below.  Even if you opt out, you will continue to receive service-related and other non-marketing emails.

‍Your privacy rights. The laws of your country of residence (including if you live in the European Economic Area or United Kingdom) may give you certain rights regarding your personal information, including the right to:

• Access. Obtain information about our processing of your personal information and receive access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to certain processing activities involving your personal information.

You may submit these requests by contacting us as provided in the Contact Us section below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. 

‍Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Security practices

We use organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect personal information, we cannot guarantee its security. 

Children

The Services are not directed to children, and we do not knowingly collect information from children without parental involvement. You must be 18 years old or older to create an account to use our Services. If you are a parent guardian and you are at least 18 years old, you may create an account on your child’s behalf, in which case you authorize us to collect information about your child in accordance with this Privacy Policy and any consents or authorizations you provide in the course of using the Services.

Data storage and retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

If we transfer your personal information from the European Economic Area or United Kingdom to another country such that we are required to apply appropriate safeguards to your personal information under data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website. If you are a registered user, we will notify you using the email address you gave us when you signed up if we make material changes made to the Privacy Policy.

How to contact us

Please direct any questions or comments about this Privacy Policy to contact@probablygenetic.com. 

Users in the European Economic Area or United Kingdom can contact our representative at:

Consumer health data policy

This Consumer Health Data Policy explains how Probably Genetic collects, uses, shares, and protects “consumer health data” as defined under applicable laws, and the privacy rights and choices you have, in connection with our Services. 

This Consumer Health Data Policy supplements our Privacy Policy and applies only to consumer health data relating to Washington state residents.

Categories of consumer health data we collect

The consumer health data we collect will depend on your interaction with us and the Services, and may include information about your medical history (when provided), your family medical history, genetic profile, laboratory results, and other health information provided by you or a genetic testing lab, where authorized by you.

Purpose for which we collect, use and disclose consumer health data

We collect, use, and share consumer health data with your consent or as reasonably necessary to provide you with Services you request. We may use and share consumer health data to operate, manage, and maintain our business, to provide and improve our Services, and to accomplish our business purposes and objectives, including, for example, detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Probably Genetic and others, and to comply with applicable laws.  

The categories of third parties to which we may disclose consumer health data include: service providers, professional advisors, and government authorities. This may also include your healthcare provider, our partnering physician network, genetic counselors who provide counseling, the laboratory we contract with for sequencing, bioinformatics partners we contract with for sequencing data analysis, and biopharma partners that offer relevant clinical trials, treatments, and therapies. We may also disclose consumer health data in connection with or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

Your rights

Washington state residents may request the following in relation to their consumer health data:

Confirm whether we are collecting, sharing, or selling consumer health data, and to access a copy of the consumer health data

‍Delete consumer health data; and

‍Withdraw consent for our collection or sharing of consumer health data.

To submit a request, please contact us at contact@probablygenetic.com.