- "Exogen Biotechnology" means Exogen Biotechnology, Inc., whose principal place of business is at 628 Stannage Av., Albany, CA 94706, and all affiliates and entities under common ownership with Exogen Biotechnology.
- " My-DNA-Health Research" means scientific research that Exogen Biotechnology performs with the intent to publish in a peer-reviewed scientific journal. My-DNA-Health Research only uses Phenotypic and Self-Reported Information from users who have given consent according to the applicable Consent Document. My-DNA-Health Research activities do not include R&D.
- "R&D" means research and development activities performed by Exogen Biotechnology on user data. These activities may include, among other things, improving our Services and/or offering new products or services to you; performing quality control activities; conducting data analysis that may lead to and/or include commercialization with a third party.
- "Service" or "Services" means Exogen Biotechnology’s products, software, services, mobile application, and website as accessed from time to time by the user, regardless if the use is in connection with an account or not.
Exogen Biotechnology Respects Your Privacy
Exogen Biotechnology recognizes the importance of privacy and respects your desire to store and access your information in a private and secure manner.
This Privacy Statement for www.exogenbio.com and our mobile application is intended to make you aware of how we handle your Personal Information. We are committed to providing you a secure, user-controlled environment for the use of our Services. At the same time, you share responsibility for maintaining privacy and security – for example, by keeping your password secure.
We encourage you to familiarize yourself with this Privacy Statement. Our Consent Form and Terms of Service explain that, by using our website and signing up for our service, you are allowing us to process your personal information according to the provisions set forth in those documents and this Privacy Statement.
If you have questions or complaints regarding our privacy statement or practices, please contact us at email@example.com or Privacy Administrator, Exogen Biotechnology, Inc. 628 Stannage Av., Albany, CA 94706.
Your Personal Information
In the course of your relationship with Exogen Biotechnology, we collect several types of Personal Information. "Personal Information" is information that could be used to identify you, either alone or in combination with other information. We collect such information from you when you purchase our Services, create a personal account, complete surveys and forms, and/or when you communicate with us or request information from us. Personal Information collected online or through our mobile application can be combined with Personal Information collected offline. We collect five primary types of Personal Information through our Service and website.
- "Registration Information" is information that we collect from you when you purchase or sign up for our Services. Examples of such information include your name, credit card information, billing and shipping addresses, and contact information, such as email address and telephone number.
- " Phenotypic Information" is information regarding the health of your DNA (e.g. the number of breaks in you DNA) or your DNA repair machinery (e.g. DNA repair kinetics) tested in your blood by Exogen Biotechnology or by its contractors, successors, and assignees; or otherwise processed by and/or contributed to Exogen Biotechnology. Phenotypic Information is generated when you purchase Exogen Biotechnology’s Service and your blood sample is analyzed and processed or you otherwise contribute or access your Phenotypic Information through our Services. Our instructions for sample collection and shipment clearly require you to send only your blood sample to us labeled with the unique number you were provided and no other identifier. No other Personal Information than sex and date of birth or age is required for the analysis. To protect your privacy, receiving personnel at the laboratory will remove any identifying information (e.g. name, address) included with blood samples before testing personnel receive the samples for break-level analysis. Receiving personnel do not perform testing, and testing personnel only handle samples labeled with the unique number. Unless you choose to store your sample, DNA, cells and blood samples are destroyed after the testing personnel completes its work, provided that laboratory legal and regulatory requirements no longer require the actual samples to be maintained. The testing personnel securely send the resulting phenotypic Information to receiving personnel along with your unique number. Phenotypic Information is stored securely on our servers; the testing personnel also stores your Phenotypic Information, but labeled only with a sample number.
- "Self-Reported Information" includes information you provide to us, including but not limited to information about your disease conditions (e.g. Cancer), other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), personal traits (e.g., eye color, height), ethnicity, family history (e.g. similar information about family members) and/or lifestyle (e.g. diets, physical activity). We collect this information from you if and when you enter the information into surveys, forms, or features while signed in to your account. Self-Reported Information is included in My-DNA-Health Research only you have given consent as described in the applicable Consent Document.
- "User Content" is all information other than Phenotypic Information or Self-Reported Information generated by users of Exogen Biotechnology Services and transmitted, whether publicly or privately, to Exogen Biotechnology. User Content may include data, text, software, music, audio, photographs, graphics, video, messages, or other materials. For example, User Content includes posts made to the Exogen Biotechnology community forums or emails to Customer Support. User Content does not include Phenotypic Information or Self-Reported Information.
- "Web Behavior Information" is information on how you use the Exogen Biotechnology website (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology.
How We Use Personal Information
Exogen Biotechnology collects Personal Information from you for all purposes necessary to ensure the regular operation of your account and/or availability of our Services. These include, among other things, providing you with our Services; improving our Services and/or offering new products or services to you; informing you about events; inviting you to participate in specific research projects, contacting you to obtain testimonials or for other promotional purposes; performing quality control activities; conducting other R&D; and, upon your authorization, conducting My-DNA-Health Research.
Exogen Biotechnology may provide your Personal Information to our third-party service providers, which are companies and people that help us provide, understand and improve our Services. For example, we may use service providers to help host our website, run our mobile application, send emails, implement our marketing campaigns, measure the effectiveness of our advertising, conduct surveys or polls, obtain testimonials, or otherwise help us run or improve our business. In all instances, our service providers act on Exogen Biotechnology’s behalf and we require by contract that they protect the confidentiality of any information they receive from us.
We do not ask you for, access, or track any location-based information from your mobile device at any time while downloading or using our mobile application or Services. Below we will describe the additional ways in which we use subsets of Personal Information.
How We Use Registration Information
We use your Registration Information to authenticate your website and mobile application visits and usage; to enable your purchase; to communicate with you about information, services, and products that you have requested; and to manage and improve our website, mobile application, software, and Services. We give you the opportunity to opt out of optional communications, either through our Service or by contacting our Privacy Administrator at firstname.lastname@example.org.
How We Use Phenotypic and Self-Reported Information
We use your Phenotypic and Self-Reported Information to provide you with Exogen Biotechnology Services, customize the user experience, and enhance our features. IF you allow sharing, Phenotypic and Self-Reported Information may be displayed in other users’ accounts. Self-Reported Information is used to customize your user experience – for example, by adjusting reports of risk to account for your reported behaviors or environmental exposures.
If, and only if, you have given consent to participate in My-DNA-Health Research as described in the applicable Consent Document, we may include your Phenotypic Information and Self-Reported Information in Aggregated Phenotypic and Self-Reported Information disclosed to third parties for the purpose of publication in a peer-reviewed scientific journal. My-DNA-Health Research is intended to advance knowledge and to create, commercialize, or undertake activities toward the practical applications of this learning to the improvement of health care. Towards the same goals, if you have given consent to participate in My-DNA-Health Research, we may allow research contractors to access your individual-level Phenotypic and/or Self-Reported Information onsite at Exogen Biotechnology’s offices for the purpose of conducting scientific research, provided that all such research contractors will be supervised by Exogen Biotechnology and subject to Exogen Biotechnology’s access rules and guidelines. If, and only if, you have given consent to use of your individual-level data in the Research Portal, we may provide your individual-level Phenotypic Information and/or Self-Reported Information to qualified researchers for the purpose of scientific research and publication in a peer-reviewed scientific journal, which could also lead to commercial uses of such information. When your Phenotypic Information and/or Self-Reported Information is being used for research purposes, pursuant to My-DNA-Health Research, research onsite at Exogen Biotechnology or via the Research Portal, it will never be combined with your Registration Information.
If you do not give your consent to participate in My-DNA-Health Research, Exogen Biotechnology may still use your Phenotypic and Self-Reported Information for purposes such as quality control or other R&D activities. Phenotypic and Self-Reported Information used for such purposes may be included in Aggregated Phenotypic and Self-Reported Information disclosed to third-party research partners who will not publish the information in a peer-reviewed scientific journal. Research partners may include commercial or non-profit organizations that conduct or support scientific/medical research or conduct or support the development of drugs or devices to diagnose, predict, or treat health conditions.
How We Use User Content and Web Behavior Information
Exogen Biotechnology uses User Content to provide our Services and improve the overall user experience. For example, posts made to the Exogen Biotechnology community forums are publicly displayed to other users. By submitting, posting, or displaying User Content, you give Exogen Biotechnology a non-exclusive license to use any User Content that you submit, post, or display on or through the Services, as further described in Section 13 of the Terms of Service. Exogen Biotechnology may make such User Content available to other companies, organizations, or individuals with whom Exogen Biotechnology has relationships, and to use such User Content in connection with the provision of those services. Exogen Biotechnology, in performing the required technical steps to provide the Services to our users, may also (a) transmit or distribute your User Content over various public networks and in various media; and (b) make such changes to your content as are necessary to conform and adapt that content to the technical requirements of connecting networks, devices, services, or media.
Web Behavior Information is collected through log files, cookies, and web beacon technology during a visit to the Exogen Biotechnology website. Web Behavior Information is used to improve our Services and the overall user experience, and if you have given consent to participate in My-DNA-Health Research as described in the applicable Consent Document, your Web Behavior Information may be used and disclosed to third parties in aggregate form for My-DNA-Health Research intended to be published in peer-reviewed scientific journals. If you do not give consent to participate in My-DNA-Health Research, we may still use your Web Behavior Information for R&D purposes as described above, which may include disclosure of aggregated Web Behavior Information to third-party non-profit and/or commercial research partners who will not publish that information in a peer-reviewed scientific journal.
Log Files. When users visit our website or use our mobile application, Exogen Biotechnology gathers certain information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider, referring/exit pages, operating system, date/time stamp, and clickstream data (i.e. a list of pages or URLs visited). This information may be linked to a particular user’s profile ID or order number. We use this information to analyze trends, administer the site, track users’ movements around the site, identify and resolve issues, and gather demographic information about our user base as a whole.
Web Beacons. A web beacon is a clear graphic image that is loaded by your web browser when it accesses a website and that records a user’s visit to a particular web page. We, or third parties that work for us, may place cookies and web beacons on our website, in our emails, and in our advertisements that appear on other websites or in emails sent by others that mention our products and services with our permission. The purpose of our web beacons is to support operation of our website and to offer additional products and services through targeted advertisements. For example, we may use beacons to determine when someone views a web page, count how many individuals visit our website after clicking advertisements placed on other websites, or count how many people have purchased products from our website after viewing an advertisement we placed. Web beacons may also help us determine the effectiveness of an email campaign because the beacons can count the number of individuals who open an email or forward it to others. We use this Web Behavior Information to better tailor our marketing to you and may also use this information to customize content on our website, enable a shopping cart, or conduct research. Third parties only collect anonymous Web Behavior Information through the use of web beacons, allowing statistical analysis relating to the performance of our advertising.
If you wish to disable web beacons, it is possible to prevent your browser from loading them, although there is not currently a standard method for doing so.
Exogen Biotechnology gives you the ability to connect with other individuals who have Exogen Biotechnology accounts through our community forums, relative finding features, and other sharing features. For some features, opt-out is required to avoid notifications. In addition, you may choose to disclose, through other means not associated with Exogen Biotechnology, any part of your Personal Information to friends and/or family members, groups of individuals, third-party service providers, doctors or other health care professionals, and/or other individuals. We recommend that you make such choices carefully.
Personal Information, once released or shared, can be difficult to contain. Exogen Biotechnology will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with a third party. Likewise, if you are reading this because you have access to the Personal Information of an Exogen Biotechnology customer through a multi-profile account, we urge you to recognize your responsibility to protect the privacy of that person. It is incumbent upon customers to share Personal Information only with people they know and trust. Users with multi-profile accounts should use caution in setting profile-level privacy settings.
Ordering Exogen Biotechnology Services as a Gift
If you provide us personal information about others, or if others give us your information for purposes of ordering the Personal Genome Service as a gift, we will only use that information for the specific reason for which it was provided to us, provided that once a gift recipient registers for his or her Services and agrees to our TOS, Privacy Statement and if applicable, Consent Form, his or her information will be used consistent with this Privacy Statement and those agreements.
If you provide us personal information about others within the mobile application for the purposes of sharing a Exogen Biotechnology discovery we will use the email address you provide, or access your contacts list if you choose to allow us to do so, to send a one-time email with the discovery and an invitation inviting him or her to visit the site. Exogen Biotechnology does not store this information.
If you provide us personal information about others on our website for the purposes of sharing a Exogen Biotechnology discovery we will use the email address you provide and any additional information you provide to send a one-time email with the discovery and an invitation inviting him or her to visit the site. Exogen Biotechnology stores this information for the sole purpose of sending this one-time email. Your friend may contact Customer Care at email@example.com to request that we remove this information from our database.
We do not sell, lease, or rent your individual-level Personal Information without your explicit consent. As a general rule, Exogen Biotechnology will not disclose your individual-level Personal Information to any third party, except under the following circumstances:
- Partners or service providers (e.g. credit card processors or contracted laboratory) process and/or store the information in order to help us provide, understand or improve Exogen Biotechnology’s Services.
- If you have consented for research, research contractors may access your individual-level Phenotypic and Self-Reported Information onsite at Exogen Biotechnology’s offices for the purpose of scientific research, provided that all such research contractors will be supervised by Exogen Biotechnology and subject to Exogen Biotechnology’s access rules and guidelines.
- If you have consented to use of your individual-level data in the Research Portal feature, qualified researchers (who must comply with certain requirements) may access your individual-level Phenotypic and/or Self-Reported Information for the purpose of scientific research, which could lead to commercial use.
- We are required to do so by law or we do so in coordination with regulatory authorities (see the section below titled "Information Disclosure Required By Law").
- You have provided explicit consent for us to do so.
Exogen Biotechnology may disclose Personal Information for the following reasons:
- My-DNA-Health Research. Exogen Biotechnology may disclose Aggregated Phenotypic and Self-Reported Information intended to be published in a peer-reviewed scientific journal to research collaborators or as a result of publication. You may give/withhold consent for your data to be used in My-DNA-Health Research when viewing the applicable Consent Document during the process of claiming your Phenotypic Information into your account. You may also give consent or change your global consent status through your Account Settings at any subsequent time which will be effective thirty (30) days thereafter; however, we cannot withdraw information that has previously been used for published research or shared with external collaborators prior to your request to withdraw consent. Exogen Biotechnology will not use your Phenotypic Information in new research that starts thirty (30) days or more after your withdrawal of consent.
- Contact information. Exogen Biotechnology will ask for and require your explicit consent to allow partner organizations (not including service providers) direct access to your Registration Information.
- Commercial partnerships. Exogen Biotechnology may enter into commercial arrangements to enable partners to provide our Service to their customers and/or to provide you access to their products and services. We will not provide any individual-level Personal Information to these commercial partners without your explicit consent. Exogen Biotechnology may include your Phenotypic and/or Self-Reported Information in Aggregated Phenotypic and Self-Reported Information disclosed to these commercial partners even if you have not given consent for your data to be used in My-DNA-Health Research.
Information Disclosure Required By Law
Under certain circumstances Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. You acknowledge and agree that Exogen Biotechnology is free to preserve and disclose any and all Personal Information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that Exogen Biotechnology may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Exogen Biotechnology TOS; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Exogen Biotechnology, its employees, its users, its clients, and the public. In the event we are required by law to make a disclosure, we will notify you through the contact information you have provided to us in advance, unless doing so would violate the law or a court order. As relates to Exogen Biotechnology’s IRB-approved research, Exogen Biotechnology has obtained a Certificate of Confidentiality from the National Institutes of Health. If you are participating in Exogen Biotechnology’s IRB-approved research, Exogen Biotechnology will withhold disclosure of your Personal Information involved in such research in response to judicial or other government subpoenas, warrants or orders in accordance with the Certificate of Confidentiality. There are limits to what the Certificate of Confidentiality covers (for more information, please visit the Certificates of Confidentiality Kiosk).
Exogen Biotechnology provides links to third-party websites operated by organizations not affiliated with Exogen Biotechnology. Exogen Biotechnology does not disclose your Personal Information to organizations operating linked third-party websites. Exogen Biotechnology does not review or endorse, and is not responsible for, the privacy practices of these organizations. We encourage you to read the privacy statements of each and every website that you visit. This Privacy Statement applies solely to information collected by Exogen Biotechnology.
We post testimonials from consenting customers on our web site, and may use testimonials in other formats consistent with consent received. Customer testimonials may contain personally identifiable information. We may use your Personal Information to contact you to obtain a testimonial and obtain your consent via email or agreement sent via fax, pdf or mail prior to using such testimonial and/or using your name along with your testimonial.
Your Choices Regarding Your Information
You can opt-out of receiving certain messages or notifications from us by logging into your Exogen Biotechnology account and changing Notifications Settings or by contacting our Privacy Administrator at firstname.lastname@example.org. You can also click the “unsubscribe” button at the bottom of promotional email communications. Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
At your written request we will close your account and will remove Phenotypic Information from your account. See the section below titled "Account Closure and Correction of Personal Information."
Account Closure and Correction of Personal Information
If you no longer wish to participate in our Services, you may close your account by sending a request to Customer Care. When closing an account, we remove all Phenotypic Information within your account (or profile) within thirty (30) days of our receipt of your request. As stated in the applicable Consent Document, however, Phenotypic Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in My-DNA-Health Research or the Research Portal will not be removed from ongoing or completed studies that use the information. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes.
If your Personal Information changes, you may correct or update your Registration Information via your Account Settings page. You may also correct or reset Self-Reported Information entered into a survey, form, or feature from within your account on the surveys page. Locate the name of the survey you wish to update and click on the review or update button.
Newsletter and Email Communications
You may choose to stop or start receiving our newsletter or marketing emails by changing your notifications settings in your account (go to Account, Settings, Notifications) or you can contact us at email@example.com.
Exogen Biotechnology is committed to protecting the privacy of children as well as adults. A parent or guardian may collect a blood sample from, create an account for, and provide Self-Reported 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 Exogen Biotechnology about his or her child is kept secure and that the information submitted is accurate.
Exogen Biotechnology takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, Exogen Biotechnology uses a range of reasonable physical, technical, and administrative measures to safeguard your Personal Information, in accordance with current technological and industry standards. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify Exogen Biotechnology of any unauthorized use of your password. Exogen Biotechnology cannot secure Personal Information that you release on your own or that you request us to release.
In the event that Exogen Biotechnology goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.
Changes to This Privacy Statement
This Privacy Statement was last updated August 1, 2013. Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our customers’ account login pages for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes.
If you have questions about this statement, please email Exogen Biotechnology’s Privacy Administrator at firstname.lastname@example.org. You can also contact us at this address if you have a question about Exogen Biotechnology’s handling of your information:
Exogen Biotechnology, Inc.
628 Stannage Av., Albany, CA 94706