2020.05.19

PRIVACY POLICY

1. Introduction

Welcome to iSearchme, a personal genetic testing and analysis service provided by ichrogene USA Inc. (“Company”, “ichrogene” “us”, “we”, or “our”)
ichrogene USA Inc. operates iSearchme which is accessible to eligible users through our website (https://www.ichrogene.com) and iSearchme mobile application (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to https://www.ichrogene.com and iSearchme mobile application, and explains how we collect, safeguard and disclose information that results from your use of our Service.

We use your data to provide and improve the Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as they do in our Terms of Service.

Our Terms of Service (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“Agreement”).


2. Definitions

SERVICE means iSearchme which is available at the https://www.ichrogene.com website and iSearchme mobile application operated by ichrogene USA Inc.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA means data collected automatically, generated either by the use of Service or from the Service infrastructure itself (for example, the duration of a page visit).

RAW DATA means information about your genotype that is generated through the processing of your saliva or blood by Third Party Genomic Testing Services.

COOKIES are small files stored on your device (computer or mobile device). Cookies are uniquely assigned to you, and can be read only by a web server in the domain that issued that cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer.

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

GENOME means a person’s genetic material, made of DNA.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.


3. Information Collection and Use

We collect several different types of information to provide and improve our Service to you.


4. Types of Data Collected

Personal Data
While creating your account, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
(a) Email address and

(b) First name and last name

We also collect cookies and Web-usage Data pertinent to your use of the Services.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by clicking on the unsubscribe link.

Raw Data
To use the Service, you will need to upload your Raw Data. We collect Raw Data to provide you the Service by preparing an analysis based on your Raw Data.

Health-related information
We may ask you to fill out questionnaires relating to your health and lifestyle as we want to learn more about the genetic basis of different traits. We also use this information to tailor the Service to you.

Usage Data
We may also collect information that your browser sends whenever you visit our Service or when you access our Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a mobile device, these Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and to understand how users use it.

Cookies are files with a small amount of data that may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. We also use other tracking technologies such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. If you do not accept cookies, however, you may not be able to use some portions of our Service.

Examples of Cookies we use:

(a) Session Cookies: We use Session Cookies to operate our Service.

(b) Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

(c) Security Cookies: We use Security Cookies for security purposes.

(d) Advertising Cookies: We use Advertising Cookies to serve you with advertisements that may be relevant to you and your interests.


5. Use of Data

By default, other users of the Service will not have the option to observe or download the Personal Data, Raw Data, genetic analysis, or any individual-level survey (Questionnaire) without your consent.

ichrogene USA Inc. uses the collected data for various purposes:

(a) to provide and maintain our Service;

(b) to notify you about changes to our Service;

(c) to allow you to participate in interactive features of our Service when you choose to do so;

(d) to provide customer support;

(e) to gather analysis or valuable information so that we can improve our Service;

(f) to monitor the usage of our Service;

(g) to detect, prevent and address technical issues;

(h) to fulfill any other purpose for which you provide it;

(i) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

(j) to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

(k) to provide you with news, special offers and general information about other goods, services and events that we offer that are similar to those which you have already purchased or enquired about unless you have opted not to receive such information;

(l) in any other way we may describe when you provide the information;

(m) for any other purpose with your consent.


6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data are generally retained for a shorter period, except when these data are used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain these data for longer time periods.


7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

ichrogene USA Inc. will take all the steps reasonably necessary to ensure that your data are treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or a country unless that organization country provides security controls at least as stringent as those offered here.


8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

(a) Research.
We may share aggregated data with other researchers, entities, or companies. Aggregated data will not include your email address or other personal information. Your genomic information will be mixed with a large number of others’ genomes and only the average allele frequencies will be shared with other researchers. An “allele” is one of two or more variant forms of a given gene.

(b) Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

(c) Business Transaction.
In the event that ichrogene USA Inc. or a substantial part of its assets or stock are acquired, transferred, or sold, you understand and agree that your Personal Data can be transferred, licensed, assigned, and/or transmitted to another party under the condition that for at least 180 days following the date of the transaction the acquiring party will maintain your option to delete your Personal Data.

(d) Other cases. We may disclose your information also:

(i) to our subsidiaries and affiliates;

(ii) with your consent in any other cases.

9. Security of Data

The security of your data is important to us. Remember, however, that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Data, we cannot guarantee its absolute security.


10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at info@ichrogene.com

In certain circumstances, you have the following data protection rights:

(a) the right to access, update or to delete the information we have on you;

(b) the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

(c) the right to object. You have the right to object to our processing of your Personal Data;

(d) the right of restriction. You have the right to request that we restrict the processing of your personal information;

(e) the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;

(f) the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).


11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

In compliance with CalOPPA we agree to the following:

(a) users can visit our website anonymously;

(b) our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;

(c) signed-up users and visitors will be notified of any privacy policy changes on our Privacy Policy page;

(d) users are able to change their personal information by editing their Personal Profile on the web/mobile application

Our Policy on “Do Not Track” Signals:

Some web browsers have a “Do Not Track” features that signals to websites that the owner does not want to have his online activities tracked. Although we honor your privacy preferences we do not currently respond to “Do Not Track” signals from browsers because industry standards have yet to be developed for this feature.

12. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data, but only to perform these tasks on our behalf and they are obligated not to disclose or use it for any other purpose.


13. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is Google’s web analytics service; it tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. These data are shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.


14. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

AWS CodePipeline

We use AWS CodePipeline, provided by Amazon.com, Inc., a service that automatically updates software to quickly give you the benefit of new features.
.

For more information on what data AWS CodePipeline collects for what purpose and how the protection of the data is ensured, please visit AWS Privacy Policy page: https://aws.amazon.com/privacy/?nc1=f_pr.

15. Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click a third party link, you will be directed to that third party's website. We strongly advise you to review the Privacy Policy of every website you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites or services, any or all of which are subject to change at any time without notice to us. We do not warrant the offerings of any of these entities/individuals or their websites.


16. Children's Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”). If you are under 18, please leave our website.

We do not knowingly collect personally identifiable information from Children under 18. If we learn that we have received Personal Data or Raw Data from a child without his or her parent or legal guardian’s verified consent (where required by law), we will use that Personal Information (e-mail address) to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our Service without verification of parental consent. Subsequently, we will take steps to remove that information from our servers.


17. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy at every visit for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


18. Contact Us

If you have any questions about this Privacy Policy, please contact us:

By email: info@ichrogene.com.