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Effective date: June 11, 2019
It is important that you review and agree to the Terms of Service and Informed Consent before using this Service. Usage of this Service and the Site and any information you provide are bound by the laws and regulations of the state of Georgia, USA which is the location of our laboratory. For more details, please check our Notice of Privacy Practices and Informed Consent. Write us at privacy@Pro-GeneX.com if you need additional information or clarifications.
Collecting information related to your health history allows us to have a more accurate and personalized prevention and screening data. But we can still produce reliable results even if you can’t provide this information. The following are the specific categories of information we collect:
Personally identifiable information (“PII”)
We collect “personally identifiable information” or “PII” when you create a Pro-GeneX account or order a MyBestMed Test. The “PII” is information that identifies you as an individual. The information includes your name, mailing address, email address, phone number, credit card, and relevant billing data. Also, we may collect information such as date of birth or sex which can be considered PII when combined with other information which can identify a specific individual.
To deliver meaningful and clinically actionable results, Pro-GeneX collects certain information relating to you and your biological family including ancestry, age and sex. We may request additional information including weight, height and fitness level. PFHI also includes your medical history and the history of those medical conditions in your family and information of any known genetic mutations in you or your family members. Provide the most accurate information possible in this section.
Users of the Service provide information about their healthcare providers. Healthcare providers who use the Service may share information about their medical practice and patients for whom they order a Test. Such information includes NPI numbers, fax numbers, and the name, job title, and contact details of additional providers who care for the patient. If you require our services but do not have a physician Pro-GeneX can refer you to a provider to review your information for you where applicable.
You can only provide information about other individuals with Pro-GeneX if the person consents. We will only use the information for the specific reason for which we need it under this Policy, our Terms of Service and where applicable, Informed Consent.
To use the Service, you need to provide a cheek swab sample. For more information on what we do with your sample, please review our Terms of Service and Informed Consent.
Cookies and Online Tracking Information
Please review the section entitled “Cookies and third-party services” for more information.
Pro-GeneX creates clinically usable results from your genetic information to guide you and your physician on the potential impacts your genes may have on prescription medication, their efficacy and your safety. Pro-GeneX uses the information you provide to deliver the Services you ordered, improve our services, enhance client experience and increase the accuracy of genetic research and science. We may use your information in the following ways:
For example, to create your Pro-GeneX account, we ship a sample collection kit to you, collect payment for the Service ordered, and analyze the sample to produce the Results. The Service may include a dynamic review of your information to determine if your Results need any updates or changes such as reclassification of Variants of Uncertain Significance.
Your contact information allows us to communicate with you about the Service. For example, we may need to inform you that your physician has ordered a Test for you, notify you to return your kit, reply emails, connect you with a medical professional, request for more information and request feedback on your Results.
We may also get in touch to request your participation in customer feedback surveys that help improve our services. We will only include your name with your feedback if you consent.
We may use your sequenced data, which is de-identified to safeguard your privacy and safety, to improve the quality of existing products. These improvements can be in the form of updating variant classification for under-represented populations, enhancing the accuracy of results of analysis of complicated regions of the human genome or supporting our lab operations, such as internal quality controls, validation studies, research and development, data analysis, and research database creation.
We may send you monthly health newsletters; product updates, special offers and opportunities we believe are a good fit. If you want to opt out of marketing emails, find out more in “Your Choices” below. You will only receive marketing emails from Pro-GeneX if you opted in.
Please review the section entitled “How Information Is Shared” below to learn more about our R&D efforts with third parties.
We may also use your information for:
The following information may be collected, stored or used when you use online services connected to Pro-GeneX’s Service and/or Site.
Cookies are small files used as an anonymous unique identifier. When you visit a website, the site sends cookies to your browser where it is stored on your hard drive.
However, refusing our cookies may restrict the use of all the features on our website.
Some browsers have a “Do Not Track” feature that signals digital devices that a user does not approve tracking of their online activity. We and our service providers do not respond to DNT signals because industry regulators have not agreed on the standard response to DNTs.
Our Site may automatically record certain device information through technologies such as “clear gifs” or “web beacons.” Automatically collected information allows us to deliver a customized and improved user experience. This information includes your IP address or other device address or ID, device type, browser type, the web pages or sites you used just before and just after visiting our Site, your interaction with the Site, and the dates and times you visit, access or use the Site.
These technologies may also help us improve our services by collecting data related to your interactions with email messages from Pro-GeneX. We use automatically collected information to:
Analytics software such as Google or Adobe Analytics helps Pro-GeneX improve our services, deepen our knowledge and understanding of clients, and improve our engagement.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Pro-GeneX may work with a third-party advertising partner for outbound advertising but we do not collect nor sell information to advertisers.
This section describes the situations in which we may allow third parties access your information. Please review the Informed Consent for more information.
We may share your protected health information (“PHI”) with professionals who care for you. These include healthcare providers (including your physician and/or an independent provider who may assess your information to determine whether to order a Test on your behalf), genetic counselors, confirmatory laboratories, clinics, and other healthcare providers.
To bill and collect payment, we may share your PII and PHI with you, your employer, your health insurance, or other relevant third parties. Our billing and collection efforts may also involve other third parties.
Third-party service providers may work with us to provide our website, hosting, maintenance, application development, analytics, variant analysis, payment processing, support ticketing, distribution and collection of Test kits, transmission of test results, and more. We limit the amount of personal, health, and non-personal details us share with these service providers to only what they need to provide their services to us, and they are under obligation to protect the privacy and safety of such information.
As a policy, Pro-GeneX DOES NOT SHARE or publish clients’ de-identified genetic data on public databases or with any organizations.
We may share aggregated, anonymized information such as aggregated trends about the general use of our Service (excluding clients’ PHI) with our partners and the general public.
We may publish findings of our research using de-identified information either by ourselves or in collaboration with academic or commercial entities.
We may share your information if we consider it an appropriate action or as part of enforcing our Terms of Service.
We may disclose client information and otherwise transfer to an acquirer, successor, or assignee as a condition for a merger, acquisition, debt financing, asset sales, or other transactions or in the event of a bankruptcy, insolvency, or receivership in which we transfer information to a single or multiple third parties as one of our business assets.
As said earlier, we collaborate with third-party analytics companies that collect your information when you visit our Site.
We may share your information under the following situations:
If we consider disclosing the information as appropriate or required to handle cases of fraud, security breach, technical challenges, or protect ourselves and others from harm under legal provisions.
To comply with relevant federal and state laws, rules, and regulations and law enforcement requests and legal processes like a court order or subpoena.
Pro-GeneX separates your private information from your genetic information to ensure full anonymity. When used for third party research, we will only share de-identified details of your information with our research partners, except you waive your anonymity by consent.
Pro-GeneX protects your information using physical, managerial, and technological safeguard measures. We encrypt all the information on our servers at rest or in transit. A 256-bit RSA encrypts all personal information including genetic and otherwise when it is stored on our servers and we only transmit information over SSL. We have strict internal guidelines and access controls that help safeguard your PII and PHI.
You are fully responsible for the security of any information you transmit or store regarding our Service. Also, we cannot offer assurances that such information may not be accessed, disclosed, altered, or destroyed by a breach on our security safeguards. You agree that Pro-GeneX is not responsible for the unauthorized release of your PII or PHI except such disclosure was because of gross negligence or willful misconduct from Pro-GeneX.
To safeguard the privacy of your PHI, we comply with the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”). If a breach leads to an unauthorized disclosure of your PHI, we will inform you immediately. We are bound by the duties and privacy practices outlined in this Policy, the Terms of Service and Informed Consent.
If you wish to stop receiving marketing emails from us, you will find the instructions to unsubscribe from the email on the received email.
We offer multiple marketing emails including
Systems limitations do not permit subscribing from all these emails via one unsubscribe email. This means you have to click unsubscribe in each of the emails to stop receiving the marketing communications from us. It is possible to stop receiving all types of marketing emails by updating your account setting or sending us a request by email at support@Pro-GeneX.com.
Note that requesting to stop receiving marketing emails from us or adjusting the frequency of the emails may take ten business days to reflect and you will continue to receive marketing communication from us even though you already opted out. Further, while you can opt out of receiving marketing communication from us, we will continue to send you administrative emails connected to the Service.
You can withhold some information from us, but this might limit your ability to use the full features and functionality of our Service and Site. To access or change the information we have about you, go to your account settings or send us an email at support@Pro-GeneX.com. You can also request to deactivate your account by contacting us at support@Pro-GeneX.com.
Choosing to deactivate your account will unsubscribe you from all marketing communications, remove your PII from our active database, and we will cease to provide you with any Service (including, without limitation, any updates or changes to your Results). We will implement any changes you make in active user databases within the shortest time possible.
While we can remove personal information from our active databases, our inactive databases will still contain some or all your personal information from the deactivated account for compliance with regulatory, legal, and other considerations. It may be impossible to retrieve or trace back for destruction, deletion or amendment any information that has already been anonymized, de-identified, aggregated, and/or disclosed to third parties under the terms of this Policy before a removal request.
No part of this Site or Service may be accessed or used by individuals under the age of 16. Parents or guardians who find out their child under 16 has set up an account on the site should promptly notify us at support@Pro-GeneX.com so we can block his/her access.
We advise users to visit this page periodically to learn of any changes to this policy as we may update it periodically. Updates to the Policy with the date of the latest revision will be available on the Site. If the revisions alter your rights or obligations, we will make reasonable efforts to inform you of the change. If you continue using the Site and/or Service after the changed Policy comes into effect, it is believed that you have read, understood and agreed to the new version of the Policy.
If you have questions about this Policy, your personal information, our use and disclosure practices, or your consent choices, contact us by email at support@Pro-GeneX.com