Full Genomes Privacy Policy

Updated: July 24, 2018

1. Our Commitment to Privacy

   Full Genomes Corporation, a Delaware corporation with its principal place of business at 2275 Research Blvd, Suite 500, Rockville, MD 20850 (“FGC,” “we,” “us,” or “our”) is dedicated to bringing users (“Users,” “you,” or “your”) the best DNA sequencing services (“Services”) possible, by combining next generation sequencing technology with an easy to use, feature-rich web experience—to allow Users to explore themselves—their history, their ancestry, and their genealogy. During the course of Services, Users provide DNA samples, which FGC uses to perform certain DNA testing and provide an online service where Users can explore themselves according to the DNA testing results. This involves the collecting, processing, storing and/or sharing of personal information.

   FGC is committed to providing Users a secure, friendly, and user-controlled environment for the use of Services. This Privacy Policy elaborates how Users’ privacy is protected during the course of Services. We encourage Users to familiarize themselves with this Privacy Policy.

   This Privacy Policy governs the information collection, use and disclosure practices of FGC in connection with Services through its web site at https://www.fullgenomes.com (“Website”), its mobile applications, and other online or offline interactions with Users. By using the Website and/or Services offered by FGC, Users agree to the terms of this Privacy Policy. We reserve the right to change this Privacy Policy from time to time, and such changes will be effective immediately upon posting to this Website. Under certain circumstances (for example, in connection with certain material changes), we may also elect to notify you of changes or updates to our Privacy Policy, or to request your consent for such changes, by additional means, such as posting a notice on the front page of our Website or sending you an e-mail. This Privacy Policy is incorporated into, and part of, FGC’s Terms of Use, which govern your use of Services in general.

2. Information We Collect

   Personal Information

   “Personal Information” is information that could be used to identify you, either alone or in combination with other information. We may collect such information from you when you use or purchase our Services (including when you send us a DNA sample), create a personal account, complete surveys and forms, and/or when you communicate with us or request information from us, either online or offline. The Personal Information we collect includes your name, mailing addresses, e-mail addresses, phone numbers, billing information, username and password, DNA sample, Genetic Information (defined below), and any other information you choose to share with us, which may include information about your hobbies, career, interests, education, and health conditions. If you choose to refer others to our Services, we may collect the names, e-mail addresses, and/or other contact information about the individuals that you refer, if you choose to provide that information to us. Please note that the amount of Personal Information you decide to submit to us is up to you, but you should understand that you may not be able to access or use certain features of the Website or the Services if you do not provide sufficient Personal Information.

   By sending a DNA sample to us and indicating your consent through our online purchase forms, you authorize us and/or a third party authorized to act on our behalf, to analyze that sample and generate genetic information from it (“Genetic Information”). To protect your privacy, samples are de-identified (i.e., personal information such as name, age, address etc. are completely removed) and the sample is labeled with a unique code before being transferred to a laboratory. The laboratory does not have access to your account information, or any other Personal Information unless required by federal or local laws. Unless you requested or the law otherwise requires, your DNA samples will be destroyed after the laboratory completes its work. The laboratory securely sends the resulting Genetic Information to us along with the unique code. We store de-identified Genetic Information securely on our server or on a third party’s server under our direction.

   If someone has referred you to us, that person may have provided us with your name and e-mail address. That information will be treated in accordance with this Privacy Policy and applicable laws. This information may also include your personal contact information when you chose to allow FGC to access your address book on your computer or mobile device. We will collect the contact information of the friends you refer our Services to.

   We may also collect your social media profile information if you make referrals or link to us using a social network such as LinkedIn, Facebook, WeChat, Google+ or Twitter. The information that we may obtain during this process varies depending on the social network and your privacy settings, but can include information such as your name, profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers and any other information you have permitted the social network to share with third parties.

   Non-Identifying Information

   When you visit or use the Website, we may also collect certain non-identifying information including, but not limited to, browser type, domains, web log information, page views, IP addresses, geographic location that we may collect through log files, cookies, and other web technologies.

   “Cookies” are small data files that are sent to your browser or related software from a web server and stored on your computer’s hard drive. Cookies track where you travel on our web site and what you look at and purchase. They may store the information in your shopping cart, and/or your username and/or password. A cookie may enable us to relate your use of our web site to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Services. You can use the browser that you are viewing this website with to enable, disable or delete cookies. Please note that if you set your browser to disable cookies, you may not be able to access secure areas of the Website and other parts of the Website may also not work properly. To find out more about cookies and how to manage them, please click http://www.allaboutcookies.org/.

3. Use of Your Information

   When you provide us with any Personal Information, which includes your DNA samples and Genetic Information, you consent to the transfer, storage and processing of your Personal Information to and in the United States as well as outside the United States. You acknowledge and recognize that different countries may provide different levels of protection for personal data than in your country of residence. Notwithstanding the foregoing, FGC does not transmit, store, or accept any information or purchases from residents of the European Union.

   You may have the right to “opt in” and “opt out” of certain of our uses of your Personal Information by contacting our privacy administrator at support@fullgenomes.com. For example, at the time you are requested to provide Personal Information on our web site, you may have the opportunity to elect to, or not to: (1) receive correspondence from us, or (2) have your Personal Information shared with a third party. You also have the right to have all of your Personal Information removed from the FGC database upon your request. Please allow us a reasonable time to respond to your requests.

   Generally, we use your Personal Information:

   • authenticate your Website and mobile application visits and usage;

   • to enable your purchase and verify your payment details;

   • to communicate with you and your referrals about information, services, and products that you have requested or you or they may be interested in;

   • to maintain our internal record keeping;

   • to manage and improve our website, mobile application, and software;

   • to provide you and your referrals with our Services and to improve our Services;

   • to customize your user experience;

   • to enforce or exercise any rights in our Terms and Conditions;

   • to distribute our own advertisements; and

   • with your consent, we may use your Genetic Information and User Provided Information in an aggregated and anonymous form, for the purposes of genetic research and paper publication.

   We use Non-Identifying Information:

   • to improve our Services to you;

   • to improve the functionality of the Website and the Services; and

   • to analyze user behavior as a measure of interest in, and use of, our web site and e-mails, both on an individual basis and in the aggregate.

4. Your Options Regarding Genetic Information

   You may control how you share your Genetic Information with us or other users of our Services.

   A. DNA sample. When you order our Services for yourself, we may send you a DNA collection kit so that you may obtain and send us a DNA sample. We can analyze the DNA sample and obtain your Genetic Information (including Raw DNA Data and DNA Testing Results, see below). You have the option to discontinue the process by not sending us a DNA sample after you receive the DNA collection kit. When you order our Services as a gift to another person, we may send you or the person the DNA collection kit at your choice. The person has the option to discontinue the process by not sending us a DNA sample after you or the person receives the DNA collection kit. Unless you have legal authority to represent the owner, only an owner of the DNA sample has access to the Genetic Information. For example, if you order our services for another person as a gift, only the person, but not you (without legal authority), has access to the Genetic Information obtained from the DNA sample, unless that person has agreed to share the results with you.

   B. DNA Testing Results. When your DNA testing results (“DNA Testing Results”) are ready, we will notify you and you will be able to access them through our Website. In ancestry testing services, your DNA Testing Results will be loaded into our database so that we can identify your relatives on our family tree. You may choose which related information, e.g., ethnicity, nationality etc., may be entered into our database. If you do not want us to enter your DNA Testing Results into our database at all or you may delete your DNA Testing Results, then you may then not be able to benefit from all aspects of our Services.You may request all of your genetic data to be deleted from our database at any time.

   C. Raw DNA Data. “Raw DNA Data” is the DNA sequence data that's generated in the laboratory from your DNA sample before it is processed or interpreted to obtain DNA Testing Results. You may download these raw data from our Website. Please note that once you download Raw DNA Data, that downloaded copy will not be protected by our security measures.

5. Your Options Regarding Other Personal Information

   You may review, update or modify the Personal Information that is stored in your user account on this Website. Before we are able to provide you with any information, correct any inaccuracies, or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

   If you no longer wish to participate in our Services, you may close your account by sending a request to us. When closing an account, we remove all Genetic Information within your account (or profile) within thirty (30) days of our receipt of your request. Any information that you have previously provided and for which you have given consent to use by us in research or database construction will be removed from ongoing studies that use the information, to the extent that it is practical, i.e. the studies have not been completed and the results published or the database(s) have not been finished and implemented. Our contracted laboratory may also retain your Genetic Information as required by local law and we may retain backup copies for a limited period of time pursuant to our data protection policies. In addition, we retain limited account information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes.

6. How We Share Personal Information with Third Parties

   FGC discloses your Personal Information to third parties in very limited circumstances, as set out below.

   A. We may disclose your Personal Information to our partners or service providers. Under the protection of appropriate agreements, third parties may perform various tasks for us. For example, we may use third parties to process payments from you and to help manage the Website and relationships with you. For analyzing or storing DNA samples we may use specialized laboratories or storage facilities. These third parties are only given access to that information needed to perform their services, and are prohibited from using it for other purposes. Our service providers may include affiliated and unaffiliated service providers in in the United States and in other jurisdictions.

   B. We may disclose your Personal Information to our subsidiaries, parent company, other subsidiaries of our parent company, or successors. As our business continues to grow and change, we may get involved in business transactions, e.g., merger and acquisition, spinoff, or asset sales, and your Personal Information may be transferred as part of that transaction.

   C. We may also disclose your Personal Information (i) with your permissions; (ii) as described in this statement; (iii) as may be required by law, regulatory authorities, legal process or to protect the rights or property of FGC or other Users (including outside your country of residence); (iv) to enforce our terms and conditions; (v) to protect our rights, privacy, safety, confidentiality, reputation or property; (vi) to prevent fraud or cybercrime; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain.

7. Protection of Children's Privacy

   FGC is committed to protecting the privacy of children as well as adults. Neither the FGC’s Website or mobile apps, nor any of its Services are designed or intended to attract children under the age of thirteen (13). FGC does not intentionally collect information by any means from those we actually know are under 13 without verifiable parental consent. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the contact information listed below. Notwithstanding the foregoing, a parent or guardian may collect a DNA sample from, create an account for, and provide other information on behalf of his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to FGC about his or her child is accurate.

8. Security

   While we endeavor to protect the security and integrity of Personal Information collected via this Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

   If you contact us by e-mail or a “contact us” or similar feature on our Website, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit.

   You may be able to create an account on our Website with a username and password. If so, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any access to or use of the Website by you or any person or entity using your password, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee or agent. Please notify us of any unauthorized use of your password or account or any other breach of security.

   We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

   In the unlikely event that we believe that the security of your Personal Information in our possession or control may have been compromised, we will notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the United States Postal Service to notify you in this situation, please e-mail us at support@fullgenomes.com.

9. Links to Other Websites

   When you are on our Website you may have the opportunity to visit, or link to, other websites, including other websites operated by unaffiliated third parties. These websites may collect Personal Information about you. FGC does not control sites that are operated by these entities and is not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of other websites. We recommend that you review the privacy practices of all linked sites before using those sites or providing any Personal Information.

10. Do Not Track Signals

    Some browsers have a Do Not Track (“DNT”) feature that lets you tell websites that you do not want your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies. Our Website does not respond to DNT signals at this time.

11. Additional Provisions Applicable to California Residents

    If you are a California resident under 18 years of age and have an account with us or have linked to us through social media, you can request that we remove content or information that you have posted to our website or other online services under our control. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another member). To request removal of content or information, please e-mail or call us using the contact information below.

12. Contact Us

    If you have any questions or comments regarding our privacy practices, you may contact us at support@fullgenomes.com.