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Privacy Policy
Overview
Precision Health Ally ("we", "us" or "our") is committed to protecting and respecting your privacy. This privacy statement ("Privacy Statement"), together with our Cookies Policy, describes the types of personal information collected and created in connection with your use of our Products and Services, how and why we use such information, who we share it with, and your legal rights. Please read the following carefully to ascertain how we process your personal information (or "Personal Information" or "information").
We may, from time to time, provide links on www.tryPGx.com (the "Site") to the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy statements and that we do not accept any responsibility or liability for their privacy or security practices. Please check the privacy statements of any other websites before you submit any Personal Information to them.
The service provider and the controller of your information is PGxAlly, Inc. trading as Precision Health Ally. Any defined terms in the Conditions of Sales & Services have the same meaning when used in this Privacy Statement.
What information we collect
When you access the Site or use our Products and Services, we collect, receive or otherwise process information in several different ways. In many cases, you choose what information to provide. Some information is required in order for us to provide our Products and Services. We use your information for the purposes described further below.
We may collect and process the following types of information about you:
1. Purchase and assistance information. We collect information when you purchase or use our Products and Services, when you phone our Support Team, or otherwise contact us for support. This information will include name, gender, contact information, billing address, delivery address and any further information you volunteer to provide to us.
2. Health-related data. When you purchase or use our Products and Services, we may collect and process data concerning your health. This could include information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments (including surgeries, procedures, medications, or other interventions),measurements of bodily functions, vital signs, or characteristics, including photographs, (which may also be considered biometric information under certain privacy laws), health insurance or claims information, and information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. Health-related data may also include Samples Samples, Test Information or any other information we might receive from you, a medical practitioner, any third party you are affiliated with such as your insurance company, or Accredited Laboratory.
3. Genetic and Genetic-Related Data. This is data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question (“Genetic Data”). Our collection of Genetic Data may include physical samples provided in connection with your use of our Products and Services (such as a saliva sample). We may also request or generate Genetic Data, medical history, family history, known familial genetic conditions or mutations where necessary to provide our Products and Services.
4. Identity Verification Data. In connection with certain Products and Services, we may collect documentation (such as a government issued ID).
5. Correspondence. We will collect and maintain your contact details when you communicate with us, sign up for promotional material, participate in special promotions, or connect with us through social media. If you contact us by email, we may keep a record of that correspondence. If you make a request with regard to the handling of your Personal Information, we may retain information regarding the request and any actions we take or correspondence we provide in response to such request.
6. Website and device information. We collect information about your browser or device, including, where available, your IP address or device ID, operating system and browser type. We also collect details of your visits to our Site and Apps including, but not limited to, traffic data, location data, the resources that you access, web logs and other communication data. Our Site and Apps also use cookies; for detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy. We may also ask you for information when you report a problem with our Site or Apps.
7. Survey information. If you respond to any surveys that we might request, which are completely voluntary, we will process your responses.
8. “Sensitive” Information. “Sensitive” personal information may be collected as defined by certain U.S. state laws and other applicable privacy laws. This could include information already mentioned above but can include: government identification for identity verification purposes such as your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin; the contents of your mail, email, and text messages unless Precision Health Ally is the intended recipient of the communication; your genetic data; the processing of biometric information for the purpose of uniquely identifying you; personal information collected and analyzed concerning your health; personal information collected.
How we use your information
We use the information we have to help us provide, operate, improve, understand, customize, support, and market our Products and Services, and for purposes described in this Privacy Statement. The broad uses of your information are described below. We may use your Personal Information for the following purposes:
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To provide you with our Products and Services.
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To receive, store and analyze your Samples at Accredited Laboratories.
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To receive, review, store and communicate your Test Information to you, including by presenting your Test Information and other reported history via the Precision Health Ally secure environment.
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To communicate with you via various channels including by phone, SMS text message, email, and physical mail, to support in the delivery of Products and Services or to send you important account-related communications. For example, communicating with you by phone to discuss your results, or sending you an email or text message to notify you that your results are ready.
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To provide you with your results and, in some instances, relevant treatment options.
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To de-identify your information for service improvement, product quality improvement, research, operations or to disclose to trusted partners for business or other purposes.
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We may use your Personal Information for research purposes where we have a legal basis to do so, or may contact you about research opportunities, clinical trials, or clinical treatments for you when appropriate. The legal basis for this activity is generally express prior consent (e.g. to participate in a research study), or if consent is not required as a legal basis for such activities, Precision Health Ally is acting in its legitimate business interests where not overridden by your interests or fundamental rights and freedoms.
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To fill and support your purchases of our Products and Services, including to process payments and to provide customer assistance. This may also include sharing your information with physicians, prescription service providers, or pharmacies where we have legal basis to do so.
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To ensure that content from our Site and Apps is presented in an effective manner for you and your device.
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To contact you with offers, updates, and news related to Services and Products you have purchased, unless you choose not to receive these. With your consent, we may also share Personal Information with third parties for advertising purposes. For more information on our use of advertising technologies and Cookies, please see our Cookies Policy. This excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
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To provide marketing, including targeted marketing on third party sites such as social media websites.
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To analyze information to help us administer, support and improve our business.
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To detect, investigate and prevent activities that may violate our policies or agreements or be illegal, including by sharing information with law enforcement.
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To retain certain records about the handling of any Samples you send us for regulatory purposes.
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To fulfill any legal obligations and legal requirements, for example regulatory reporting to health agencies, or retaining certain tax and accounting records for financial reporting.
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Children's privacy
We will not knowingly collect Personal Information from Site or Apps users that are under 18 years of age. We are relying on your representations in the Terms that you are 18 years of age or older. You should not use the Apps or our Site or its Services, including purchasing Products, if you are not 18 years of age or older.
How we secure your information
All Personal Information you provide to us in purchasing or availing of our Products or Services is protected by our privacy and security programs, which include a range of technical, organizational, and administrative privacy and security safeguards to protect your information from unauthorized use and disclosure. Any payment transactions effected by us will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site or Apps, you are responsible for keeping this password confidential. You must not share a password with anyone.
Once we have received your Personal Information, we will impose obligations of confidentiality and security on any of our service providers who process the Personal Information, sufficient to comply with applicable laws and regulations.
We maintain appropriate physical and electronic industry standard security practices, including encryption, passwords, access control, physical security measures, and managerial procedures to protect the security and confidentiality of your personal data.
Disclosure of your information
We share Personal Information with service providers, healthcare providers, affiliates, partners, and other third parties where it is necessary to provide the Products and Services, or for any other purposes described in this Privacy Statement.
Your Personal Information may be provided as necessary to the following categories of recipients:
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Accredited Laboratories
We may disclose and transfer your Personal Information to our Accredited Laboratory for the purpose of
(i) accepting and processing an accepted order by us;
(ii) in order to ensure the Product is delivered to you by it; and
(iii) to test any sample provided and make your test Information available to you on our secure account on our Site and Apps.
To process a request for a Product and for our Accredited Laboratory to test the sample and send you the test information, we need to disclose Personal Information within and outside our company including to healthcare providers, to our Accredited Laboratory and our IT services providers.
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Healthcare providers
We may disclose and transfer your Personal Information to healthcare providers, such as contracted or other medical practitioners for purposes of review, quality assurance, prescribing of tests, review of results and other purposes.
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Service providers (such as couriers, communications and marketing service providers, IT-related service providers, analytics providers, legal or financial advisors, contractors and vendors)
We may share your Personal Information with certain third party suppliers and service providers to help us operate, provide, improve, understand, customize, support, and market our Products and Services. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Statement by imposing obligations of security and confidentiality on such service providers. For research, development, publications, and analytics purposes, we may also share Personal Information where we have your consent or some other legal basis to do so.
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Other trusted third parties with whom we have an agreement for the protection of your information
We may engage in collaborative research with third parties (for example, health, educational, or government institutions, or private companies) related to the development of new tests, validation of existing testing processes or technologies, or to improve existing products and services. We may also disclose de-identified Genetic Data to public databases for the advancement of medical research; this enables improved understanding of how genetics may impact the risk of certain diseases or health conditions. We may include de-identified Genetic Data in our research databases, which may be accessible, searchable, and downloadable by third parties (including researchers and the public). More information about this will be available on any consent forms provided to you if you are using Products and Services that involve genetic testing, genetic sequencing, or processing of your Genetic Data. We and/or our workforce members may be involved in the creation of publications, and this may include collaborating with third parties. Where this is done, it will involve only de-identified Personal Information.
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Government/regulatory/law enforcement/local health agencies pursuant to legally binding order or where legally required, for example where we are required to report positive test results of certain communicable diseases to local health authorities.
If any third party has provided, subsidized or paid for the Products and Services you are using, your Personal Information may be shared with them as required by the contract between us and that third party.
In instances where our business is subject to a re-organization, such as a merger or acquisition of some or all of its assets, we may, in accordance with our legitimate interests, share information in the course of the transaction. In such circumstances, your Personal Information may be disclosed, where permitted by applicable law, in connection with a corporate restructuring, sale, or assignment of assets, merger, or other changes of control or financial status of Precision Health Ally.
If you send offensive or objectionable content or otherwise engage in any disruptive behavior on the Site, we can use your Personal Information to stop such behavior and pursue our legitimate interest to prevent such behavior on our Site. This may involve informing relevant third parties, such as law enforcement agencies, about the content and your behavior.
Equally, we may retain, preserve, or disclose your Personal Information if we have a good-faith belief that it is reasonably necessary to (i) respond, based on applicable law, to a legal request (such as a subpoena, a search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce the agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public. For example, your IP address may be supplied to regulatory authorities in connection with fraud or other formal investigations.
We may share information with advertising partners or service providers to contact you with offers, updates and news related to Services and Products you have purchased, unless you choose not to receive these. With your consent or another applicable legal basis, we may also share Personal Information with third parties for advertising purposes.This excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We may pass aggregate information on the usage of our Site and Apps to third parties.
How long do we keep your information?
We retain your information in our server logs, our databases, and our records for as long as necessary to provide the Products and Services. In some cases we may retain some of your information for a longer period, where we have a legitimate business interest to do so (such as to contact you to provide you with relevant information about our Products and Services or to maintain your account with us), in order to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims, or to enforce our Terms and Conditions. Samples are securely destroyed after they are processed, to the extent we do not have a legal basis to retain the sample, and your information is deleted using industry standard data deletion methods once no longer retained.
Cookies, “Do Not Track”, and “Global Privacy Control” Signals.
If you decide at any time that you no longer wish to accept cookies, pixels and related tracking technologies for any of the purposes described in this privacy policy, then you can instruct your browser, by changing its settings, to stop accepting these or to prompt you before accepting them from the websites you visit. If you do not accept all cookies, however, you may not be able to use all portions of the Site or all functionality of the Services. For more information on our use of Cookies, please see our Cookies Policy.
Some web browsers transmit "do not track" signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.
We respond to the Global Privacy Control (GPC) signal as required by CCPA and other laws. For more information see www.globalprivacycontrol.org.
Notice to US Residents – Your Privacy Rights
This section is applicable to residents of the USA. While certain states such as California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia and Washington may provide certain privacy rights detailed below, if you are a resident of any US state we will endeavor to honor and action reasonable requests you make in relation to your data privacy.
When you make a request, you can expect the following:
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We will take steps to verify your identity and authority to make the request.
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We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at pgxinfo@pgxally.com. We will respond to your request within 45 days of receipt of the request, if possible. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
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In certain cases, a request may be denied, for example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone's security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.
If you would like, you may designate an authorized individual or agent to make a request on your behalf. We will deny requests that do not evidence sufficient proof of authorization from you. To verify that an authorized individual or agent has authority to act for you, we may require a copy of a power of attorney or require that you provide the authorized agent with written permission and verify your own identity with us.
Depending on your state of residency you may have the following rights:
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Access and Right to Know. This is the right to request a copy of your information that we process, or to request information about how your information is collected and who from, how it is used, who it is disclosed to and their contact information, for what business purpose it is collected, used, and disclosed, what specific pieces of data were collected, used and disclosed, and how your data is secured. Please see the “Right to Know – Further Information” section below for more information.
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Correction. If you discover that we hold inaccurate information about you, you have a right to ask us to correct that information.
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Erasureor Deletion. You have the right to request that we delete your information or destroy your sample. We may refuse this request if the information is still necessary for the purposes that we collected or processed it or we still have a legal basis to process the information or retain the sample.
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Restriction. You have the right, in some cases, to restrict or limit the processing or sharing of your information, such as where you have exercised your right to object and we are reviewing your objection.
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Objection and Right to Opt Out of or Limit Sensitive Data Processing. You may have the right to object to us using your information for certain activities, and to opt out of or limit activities that involve processing of data defined as “Sensitive” under applicable U.S. state data privacy laws, such as health information. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Sensitive personal information includes information that reveals your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your precise geolocation; your racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless Precision Health Ally is the intended recipient of the communication; your genetic data; the processing of biometric information for the purpose of uniquely identifying you; personal information collected and analyzed concerning your health. Precision Health Ally will only use your Sensitive personal information to perform services or provide the goods reasonably expected by you.
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Portability. You have the right in some cases to obtain a copy of your information in a format able to be shared with another organization.
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Withdraw consent. If we are ever processing your information for an activity that you have consented to, you can withdraw your consent to processing at any time. Withdrawing your consent does not affect processing that has already occurred. Where you withdraw your consent, we will no longer process your information based on your consent. We may process your information if another legal basis applies, for example, if we are legally obligated to store certain records or if your withdrawal of consent was limited to certain processing activities.
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Right to Opt Out of “Sale” or “Sharing” for Cross-Context Behavioral Advertising and other Specified Purposes. Precision Health Ally does not engage in sale of your personal information for monetary consideration, but may share information for legitimate purposes described in this privacy notice. If an activity is ever considered a sale or sharing of Personal Information under a state privacy law’s definition, you may have the right to opt out of this to the extent Precision Health Ally engages in it. Residents of certain states such as California, Colorado, Connecticut, Nevada, Utah and Virginia have rights to opt out of sale of personal information or sharing of personal information for cross-context behavioral advertising and other specified purposes, and of the use and/or disclosure of personal information for certain types of targeted advertising and consumer or household profiling. You may have the right to direct us not to process your personal information for purposes of (i) targeted advertising, (ii) selling or otherwise transferring personal data in exchange for monetary or other valuable consideration, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Nevada law also gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration. This right applies even if their personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, please send us an email with the subject line “Nevada Resident Do Not Sell Request” to pgxinfo@pgxally.com. In general, we will only use your personal information to perform our services reasonably expected by you, internal reporting and analytics purposes, for other legitimate business purposes such as information security. When you visit our websites, we may share information about your use of our websites with certain advertising or analytics partners. You can opt into, or out of, such sharing at any time by interacting with our cookie banner and Cookie Preferences center that may appear at the bottom of our websites the first time you come to our website, or the Cookie Preferences link that may appear in the footer of our websites. You can learn more about our use of cookies, pixels, and related technologies, including about how to action your right to opt out of data sharing through the use of cookies, by referring to our cookies policy.
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Right to opt out of the processing of the personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. Virginia and other U.S. residents may have a right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects.
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Financial Incentives. The CCPA and other U.S. state data privacy laws allow businesses to offer consumers financial incentives for sharing personal information. For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their personal information. Where Precision Health Ally offers these programs, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms, and you may withdraw at any time.
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Non-Discrimination and No Retaliation. If you exercise any of your privacy rights we will not discriminate or retaliate against you, including, but not limited to:
Denying goods or services.
Charging different prices or rates for goods and services, including through the use of discounts or other benefits or imposing penalties.
Providing a different level or quality of goods or services.
Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.
We may, however, charge a different price or rate, or provide a different level or quality of goods or services, if that difference is related to the value provided to you by your data.
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Complaint and Appeal. If you have a complaint regarding privacy, this policy or its implementation, or want to appeal against a decision made about you, we would appreciate the opportunity to try and resolve your issue. Please contact pgxinfo@pgxally.com. If Precision Health Ally refuses to take action on any of the above rights, you can appeal this decision by emailing pgxinfo@pgxally.com. Within 60 days or less of receipt of an appeal, Precision Health Ally shall inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is unsuccessful and depending upon the state where you live, you may have the right to raise a concern or lodge a complaint with your state attorney general.
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Rights provided by California Civil Code Section 1798.83
A California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (a "California Customer") may request information about whether the business has disclosed Personal Information to any third parties for the third parties' direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed. Please note that we are only required to respond to one request per California Customer each year under Code Section 1798.83.
Right to Know – Further Information
Under California and other U.S. state privacy laws, you may have a right to know the categories of data we collect, where we collect them from, who they may be shared with, and for what business purposes we collect and share information. In the last 12 months, we have collected and shared the following categories of Personal Information from individuals from the following sources, for the following business purposes:
Purchase and assistance information including name, gender, contact information, billing address, delivery address, government issued ID if required for identity verification, payment information, and any further information you volunteer to provide through the Site and Apps. Categories of Sources:
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You
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Resellers and B2B Customers (e.g. if you are an employee or member of a health insurance plan, your employer or health insurer may provide us with certain necessary Personal Information for purposes of providing you with our services. If you purchase through a reseller channel, that reseller may provide your order and shipping details to allow us to fulfill your order)
Business or Commercial Purposes:
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To receive, store and analyze your Samples
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To receive, review, store and communicate Test Information
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To provide results
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To help facilitate your prescription order and delivery
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To de-identify information
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To fill and support purchases and delivery of Products and Services
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Processing payments
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Customer assistance
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Site and Apps development
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Marketing
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Administer, support and improve our business.
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To combat activities that may violate our policies or agreements or be illegal
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To retain certain tax and accounting records.
Third Parties with Whom Shared:
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Service Providers
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Payment processors
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Labs
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Pharmacies
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Healthcare Providers
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Your health insurer
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Public health agencies
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Marketing affiliates
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Other third parties (such as your employer or insurer if you are testing through a program sponsored or subsidized by them)
Health Related Data including Sensitive information such as in relation to your past, present and future health and healthcare, health insurance information, sex life or sexual orientation, sex at birth or gender, and ethnicity.
Categories of Sources:
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You
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Your healthcare providers or insurer
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Labs
Business or Commercial Purposes:
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To receive, store and analyze your Samples
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To receive, review, store and communicate Test Information
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To provide results
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To help facilitate your prescription order and delivery
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To de-identify information
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To fill and support purchases of Products and Services
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Customer assistance
Third Parties with Whom Shared:
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Labs
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Pharmacies
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Healthcare Providers
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Your health insurer
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Public health agencies
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Service Providers
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Other third parties that support the ordering, processing, fulfillment and delivery of Products and Services
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Other third parties (such as your employer or insurer if you are testing through a program sponsored or subsidized by them)
Genetic and Genetic Related Data.
Categories of Sources:
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You
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Your healthcare provider
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Labs
Business or Commercial Purposes:
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To receive, store and analyze your Samples
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To receive, review, store and communicate Test Information
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To provide results and genetic counselling
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To help facilitate your prescription order and delivery
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To de-identify information
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To fill and support purchases and delivery of Products and Services
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Customer assistance
Third Parties with Whom Shared:
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Labs
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Healthcare Providers and genetic counsellors
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Service Providers
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Other third parties that support the ordering, processing, fulfillment and delivery of Products and Services
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Other third parties with your consent
Biometric Data such as photos used to compare against government issued ID for identity verification purposes.
Categories of Sources:
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You
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Identity Verification Service Providers
Business or Commercial Purposes:
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To verify and identify
Third Parties with Whom Shared:
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Identity Verification Service Providers
Correspondence, sign-ups for materials and promotions or connections via social media.
Categories of Sources:
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You and other correspondents
Business or Commercial Purposes:
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To fill and support purchases of Products and Services
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Processing payments
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Customer assistance
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Site and Apps development
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Marketing
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Administer, support and improve our business.
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To combat activities that may violate our policies or agreements or be illegal
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To retain certain tax and accounting records.
Third Parties with Whom Shared:
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Social media
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Marketing affiliates and Service Providers
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Payment processors
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Tax agencies
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Other third parties with your consent (such as your employer or insurer if you are testing through a program sponsored or subsidized by them)
Website, Apps and device information.
Categories of Sources:
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You
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Your devices
Business or Commercial Purposes:
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Track use of Site and Services
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Increase navigation efficiency of the Site and Apps
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Personalization of the Site and Apps
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Marketing
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Site and Apps development.
Third Parties with Whom Shared:
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Marketing Service Providers
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Analytics Service Providers
Survey and Questionnaire Response Information.
Categories of Sources:
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You
Business or Commercial Purposes:
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Site and Apps development
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Marketing
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Administer, support and improve our business and products
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Research
Third Parties with Whom Shared:
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Service Providers
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Other third parties (such as your employer or insurer if you are testing through a program sponsored or subsidized by them)
Changes to our Privacy Statement
From time to time, we will make changes to this Privacy Statement. Any changes we may make in future will be posted on this page, so please check back regularly to see if there have been any changes to this Privacy Statement.
Contact us
Questions, comments and requests regarding this Privacy Statement are welcomed and should be addressed to pgxinfo@pgxally.com
Updated May 27, 2024
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