Privacy Policy

HumanCode Privacy Policy

Version 1.0

Last updated on September 26, 2017

Exploring your DNA through the HumanCode family of products, mobile applications, and website (humancode.com) should be an educational, fun, and curiosity-piquing experience that is worry-free.  Given this, we want you to feel confident that protecting your genetic and personal data is vital to our core operation. We also want to be transparent regarding information we track, collect and use.

If you have questions or concerns after reading the policy, please contact us at help@humancode.com.

We understand that reading a lengthy legal document can be cumbersome.  While we hope you take the time to read through our policy, there are a few points you should not overlook:

  1. We may collect information from you via the data you provide through account registration, DNA results via the HumanCode family of apps, surveys responses, support inquiries, information from social media, cookies and other tracking technologies. This information may be collected directly or received from third parties.
  2. If you opt in to included yourself in any product enhancement survey efforts, we do all that’s possible to de-identify your information.  Your personal data will never be shared without your explicit consent.  Wherever possible, your data will be viewed as a part of an aggregate group where it cannot be associated with you as an individual.
  3. We will not share your information with your employers, insurance companies, or any academic, government, corporate entity without your explicit consent.  The only exception would be in cases where we are subject to applicable laws requiring disclosure.  In the event of a subpoena, court order or other law enforcement or government mandate, we could be asked or required to share your data.  We will address these situations on a case-by-case basis.

 

We promise to be vigilant in protecting your privacy.  That said, it is also your responsibility to keep your information and the information of your friends and family secure. It’s important to get the consent of family members and friends before inputting their information into your account (for example: identifying traits, health status, pictures, and videos).

Please note that by using our website or apps and signing up for any services, you are allowing us to collect, use, and process data that could identify you, either alone or in combination with other information.

Outline:

    • Guiding principles
    • Reference information
    • Information collected by HumanCode
    • Information provided by Helix
    • Use of your personal and genetic information
    • Sharing and linking your information
    • Your choices
    • Aggregated data and pooled genetic information
    • Push notifications, email, and devices
    • Cookies and web analytics
    • Accessing, deleting or modifying your account
    • Links to other sites and 3rd party content
    • Data security and storage
    • Response to “do not track” signals
    • Children’s privacy
    • Gifting
    • Important notice to non-US Residents
    • Changes to this policy
    • Acceptance of this policy
    • How to file a complaint

Guiding principles

The guiding principles we consider core to our business are as follows:

  • Control: We give you control over if, how, and where your data is shared outside of HumanCode.  Except for the limited circumstances outlined in this policy, we never share any of your personally identifiable information without your consent.
  • Transparency: We strive to make it clear what data we are collecting and how we are using it.
  • Purpose: Information collected is intended to help deliver the best product experience for our customers.
  • Anonymity: Unless you consent otherwise, all information used for research purposes will be appropriately de-identified to the best of our ability.  

Reference information

  • Aggregate data: Combined results derived from separate sources of data or across a group of subjects
  • Cookie: A small amount of data that is sent to your browser from a web server and stored on your computer or device
  • Pooled genetic information: Genetic data pooled from multiple individuals which does not include any data that would reasonably permit someone to identify you individually

Information collected by HumanCode

The type of information we collect is in part dependent on how much you are comfortable with us collecting.  There is basic information (i.e., name, email, sex, ethnicity, etc.) that we must gather so that you may effectively use our products, communicate with us, or request information.  We also collect data from social media log-ins, surveys answers, and in-product behaviors. As mentioned above, some of this data may be collected directly by us from you, and some may be provided to us about you by third parties.  For the most part, this can be controlled by you through consent or opt-in/opt-out mechanisms, through our site or through the original site that collected your data.

Information we may request at registration:

  • Name, email address, a photo of you, date of birth, biological sex, location, and the password you create.
  • Credit card information to process payments for Services (collected by HumanCode, Helix, or a third party).  Please note that if you sign up for an account using a third party (like Facebook Connect or Google Plus) we may receive information that you have uploaded or entered about yourself.  This could include the ‘likes’ from your Facebook account.

On-going information we may request as you use our products:

  • Self-reported demographic information
    • Personal and family attributes (immediate and extended family)
      • We will collect information that you provide as it relates to the following:
        • Traits you or your family members have, such as ethnicity, sex, medical history, and physical features (like eye and hair color, and height)
        • Identifying information like name, age, or characteristics of you or your family members
    • Electronic data
        • This includes data, images, records, text, software, music, audio, photographs, graphics, video, messages, or other materials such as posts made by you to the HumanCode community forums or blogs, or emails to customer support.
        • Records and copies of any correspondence with you and details of any transactions you carry out through our Services (such as surveys, customer service, response to email campaigns).
      • Genetic and phenotypic (e.g. self-reported physical trait) data related to our products.
      • Questions that you voluntarily answer related to yourself and your family.  
      • Any data you may choose to connect or import, for example from other apps or services.
      • Mobile and web behavior collected through log files, cookies, and digital analytics tools.
        • IP address
        • Referring URLs
        • Page views
        • Browser and device characteristics
        • Product behavior (e.g., date and time of visit, length of visit, clicks on product information or other content)
      • Information allowed by you via your social media account opt-in

In summary, the types of information we collect may include, but not limited to:

  • Registration information when you create your personal account
  • Self-reported demographic information
  • Personal and family attributes that you provide
  • Genetic and phenotypic data related to our products
  • Questions that you voluntarily answer related to yourself and family  
  • Information allowed by you via your social media account opt-in
  • Device and browsing information related to how you interact with our online services

Information provided by Helix

HumanCode is designed to interact with the helix.com platform operated by Helix OpCo, LLC and/or its affiliates (“Helix”).  Upon your authorization, and when your sample is processed by Helix, we receive and store a small subset of your DNA results as it pertains to the information contained on the HumanCode app. We take your results and evaluate specific areas of your DNA to predict inherited traits.  We also combine the traits of you and your partner and predict the traits of your future children. This is done by plugging your raw DNA data into our secure trait prediction system which evaluates the DNA of you and your partner.  If you supplement your genetic information with any other information (for example, self-reported appearance characteristics or by answering survey questions), either directly to us, or by authorizing Helix or a third party, we will aggregate the data and use it to make a more comprehensive experience.

Use of your personal and genetic information

The reason for collecting your personal information is multifold.  Most importantly it allows us to tailor your experience to include, but not limited to:

  • Notifying you of changes to our services and policies
  • Improve products and create new products
  • Enable your purchases
  • Process transactions
  • Administer promotions
  • Perform quality control and quality improvement
  • Deploy user feedback initiatives
  • Conduct marketing campaigns and targeted advertising (subject to your browser cookie settings)
  • Authenticate website and app visits and usage
  • Invite you to participate in specific research projects.

This information comes from multiple sources such as account details, the types of products purchased, responses to surveys and the way you interact with the app and website.

If you prefer not to receive marketing communications from us, please opt out through the HumanCode Services or by contacting us at help@humancode.com.  Please note that even if you opt-out we may still send you administrative communications about the site, app, or your purchases thereunder.

Sharing and linking your information

How we share your information to third parties

HumanCode will not sell, rent, license, or trade your information with third parties for our own direct marketing use unless we receive your explicit consent.  

HumanCode may share your information under confidentiality agreements with other companies that work with, or on behalf of, HumanCode to provide products and services, such as a cloud hosting, order fulfillment, support services, or credit card processing.  These companies may use your information to assist HumanCode in its operations.  They will not have any independent right, however, to share this information.

We may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims.  We may share your information where we believe it is necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

We may share your information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of HumanCode’s business to such business entities.  We will make all assurances that the successor business entity will honor the terms of this Privacy Policy.

We may share grouped, de-identified information about users (including pooled genetic information) and usage of our Services publicly or with third parties for understanding genetic and phenotype variation and how it correlates within a population, for example. This could include public or private databases or our own product development efforts.

How we share your information with Helix

We may share your information with Helix for quality control and improvement, account management, support services, targeted marketing, research and product improvement and development.  

Sharing with and Linking to other people within and outside of the HumanCode community

You will have the ability to link with friends and family members through the HumanCode apps and website.  Please be cognizant of what you share.  HumanCode gives you the ability to connect with other individuals who have HumanCode accounts through our community forums and other sharing features. You may choose to disclose, through other means not associated with us, any part of your information to friends or family members, groups of individuals, third-party service providers, doctors or other health care professionals, or other individuals. We recommend that you make such choices carefully. Information, once released or shared, can be difficult to contain. We will have no responsibility or liability for any consequences that may result because you have released or shared Information with a third party.  Information contained in your account, if shared, could be used against your interests.

About GINA

The Genetic Information Nondiscrimination Act (“GINA”) protects your Genetic Information from use by group health insurance providers and employers. However, GINA does not apply to disability insurance, life insurance or long-term care insurance providers. Some states have protections for those types of insurance, so you should be aware of the laws in your state. If you choose to share your Genetic Information with these insurance providers, you do so at your own risk. Genetic Information that you choose to share with your health professional may become part of your medical record. That means it could be accessible to other health professionals and possibly health insurance providers in the future. If you share information on any forum or blog, or share it with a third party, that party may use it or disclose it in a way you didn’t intend.  

Third Party Referrals

HumanCode may provide referrals to service providers, including genetics counselors.  If you request that HumanCode shares information with such service providers, we may do so. We may also receive limited information about you from such providers if you so request.   HumanCode merely provides these referrals on a courtesy basis.  HumanCode does not make any representations or warranties about any service providers, and is not a party to any transaction or relationship between you and any service provider. You should vet all service providers carefully and make sure you understand the terms (including the payment terms) related to any services they may provide.  Service providers may collect, use and share your information differently than we do, and you should be careful to review their policies related to data privacy and security.  

Your choices

This chart illustrates your choices regarding most types of identifiable information we collect.  Aggregated de-identified data is handled differently, and in accordance with the next two sections. If you have questions, please contact us at help@humancode.com.

Information Type Options Shared with Friends/Family Shared with Helix Shared with 3rd Party (excluding Helix.com) for research or commercial purposes
Account information (ex: name, address, etc)
  • Required for product use
  • First/Last name shared only when you link accounts
  • First/Last name
  • Email
  • Only with your consent
Demographic data
  • Some data required for product use (i.e., sex, ethnicity)
  • Could be shared when you link accounts
  • Only with your consent
  • Only with your consent
Phenotype information
  • Moderate data collected at registration
  • May be extracted from photos
  • Self-reported data
  • Could be shared when you link accounts
  • With your consent, combined with aggregated data
  • Only with your consent
  • Only with your consent
Genetic Information
  • We collect info on a subset of your DNA
  • Your account can always be closed and deleted
  • Could be shared when you link accounts
  • Only with your consent
  • Helix is in possession of your sequence as they are the lab that processed the sample
  • Only with your consent
Customer care inquiries
  • Collected through our customer service systems and tracked.
  • Only with your consent
  • Shared when required to resolve a question related to both companies
  • Only with your consent
Survey answers
  • Collected through our surveys systems and tracked.
  • Only with your consent
  • Only with your consent
  • Only with your consent
Web browsing information
  • Collected through our web analytics systems and tracked.
  • Only with your consent
  • Only with your consent
  • Only with your consent

If you have any questions about how to opt-in or opt-out of any sharing, please contact us at help@humancode.com

Aggregated data and pooled genetic information

HumanCode counts, tracks, and combines general traffic-flow of our website and app.  We may merge information about you into anonymized data and/or aggregated group data. HumanCode will remove personal identifiers from information and maintain it in aggregate form that may later be combined with other information to generate anonymous, statistical outputs. HumanCode may use such anonymous group data for any purpose in its discretion.  Such anonymous group data may be shared with third parties for any purpose; if it does so, HumanCode will not disclose your individual identity.

Your Genetic Information may be combined with that of other users as pooled genetic information. Pooled genetic information does not include any data that would reasonably permit someone to identify you individually. HumanCode may use pooled genetic information for any business purpose in its discretion, including without limitation for research purposes and to improve product and data quality.  HumanCode may share pooled genetic information with third parties for any purpose; if it does so, HumanCode will not disclose your individual identity. Pooled genetic information may also be used for our promotional purposes. This could include informing users of our Services (e.g., “50% of our users are female” or “on average 30% of our user population is lactose intolerant”).

Push notifications, email and devices

If you opt-in to receive push notifications, we may send them to you on the mobile device you use with our product.  If you later decide you do not want to receive push notifications, you may be able to disable the settings on your mobile device. You also understand that you may opt out of receiving push notifications from us at any time using your device settings.   Please contact us at help@humancode.com with any questions.

It is your responsibility for obtaining the data network access and mobile device necessary to use the Services. Your mobile network’s data and messaging rates and fees may apply if you access or use the Services from your device. HumanCode does not guarantee that the Services, or any portion thereof, will function on any hardware or devices. In addition, the Services may be subject to malfunctions and delays inherent in the use of the Internet and electronic devices.

Cookies and web analytics

Cookies and other similar industry standard technologies may be used to capture your web browsing behavior. Cookies allow us to facilitate the administration and improve the effectiveness of the website and app as well as tailor your experience.  You may set your browser to decline cookies, but please note that you may not be able to fully experience certain interactive features of our services if you do so.

We may employ third party companies, such as Google Analytics (a web analytics service), to analyze the usage of our website and app for internal purposes. Google Analytics and similar companies use cookies to collect anonymous traffic data that help to understand how customers use the website. The information generated by a cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google and similar companies will use this information for evaluating your use of the site, compiling reports on site activity for us and providing other services relating to site activity and internet usage. Google and similar companies may also transfer this information to third parties where required to do so by law, or where such third parties process the information on their behalf.

By using the website or app, you consent to the processing of data about you by Google in the manner and for the purposes described in this policy. If you have concerns relating to the usage of Google Analytics, it is possible to block Google Analytics by installing a plug-in to your browser. A plug-in for the most common browsers can be found here: http://tools.google.com/dlpage/gaoptout.

Accessing, deleting or modifying your account

If you no longer wish to participate in our Services, you may close your account by sending a request to Customer Support at help@humancode.com.  When closing an account, we remove all personally identifiable genetic information from your account (or profile) within thirty (30) days of our receipt of your request. Information (including personally identifiable genetic information), however, that you have previously provided and for which you have given consent to use will not be removed from ongoing or completed studies or business activities that use the information (such as anonymized or aggregated statistical 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.

Please note that HumanCode will have access to genetic information only related to our family of products.  You must contact Helix (helix.com) if you wish to further delete all genetic data collected from your initial saliva sample.

If your information changes, you may correct or update your registration information via your profile page. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Information that has already been de-identified and/or aggregated (including pooled genetic information) may not be retrievable or traced back for correction or removal from any database.

If you wish to disassociate your account from your partner, friends or family, you can remove partners within the application under “More”.

Links to other sites and third party content

We may have included content from third parties within our products, which could include promotional material that links outside of our product.  The website and app may contain links to other sites, including to those of our affiliates or third party entities that have their own privacy policies. These sites may also refer you back to our website or app. We recommend that you read the privacy policies of each site you visit to understand the site’s privacy practices. We are not responsible for the privacy practices of sites and apps not operated by HumanCode, Inc.

Data security and storage

HumanCode understands that storing and securing your data is fundamental to good business practices within the genetic testing services business.  We store information and other data using industry standard physical, technical, and administrative safeguards designed to guard against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification.  Please note, however, that while HumanCode has endeavored to create a secure and reliable website and app for users, the confidentiality of any communication or material transmitted to/from the website or app cannot be guaranteed.

Response to “do not track” signals

Some Internet browsers include the ability to transmit “Do Not Track” signals. HumanCode does not process or respond to “Do Not Track” signals. Third party content included in our apps may or may not process or respond to “Do Not Track” signals.  

Children’s privacy  

We understand the importance of protecting children’s privacy in the interactive online world. Our website and app are not designed for, or intentionally targeted at, children under 18 years of age. No one under the age of 18 should submit any information to HumanCode or the Services.  If it is later found that information from a minor was submitted, the account will be deleted.

Parents, relatives, friends or guardians may post pictures or provide information pertaining to minors that is automatically collected via our website or app.  Please be aware that this information is difficult to retract once it’s shared publicly, so do so with caution, consideration and consent.

Gifting

Giving or receiving genetic testing kits as a gift is a common practice.  It does require, however, an exchange of information provided by you about others or vice versa. This information will be used for gifting purposes only.  The person who uses the kit will activate their account via Helix.com and Humancode.com.  At that time, information collected will be subject to the provisions within this privacy statement and that of Helix, as applicable

Important notice to non-United States residents

It is important to note that the website and app are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the website or the app, and/or providing us with your information, you consent to this transfer.

Changes to this policy

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve.  We display an effective date on the policy in the upper left corner of this Privacy Policy so that it will be easier for you to know when there has been a change.  If we make any change to this Privacy Policy regarding use or disclosure of information, we will provide advance notice on this website and in the app.  Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.

Acceptance of this policy

By registering for a HumanCode account, you signify that you agree with the terms and provisions it contains. If you do not agree to any parts of this Privacy Policy, please consider not using our products or services.

Please note that your continued use of the Services following the posting of changes to these terms will mean that you accept those changes.

How to file a complaint

You have the right to file a complaint with us if you do not agree with any of our practices or if we have not responded to you in a reasonable amount of time.  Your complaint can be sent via email to help@humancode.com.

Questions?

If you have any questions about this Privacy Policy or about HumanCode’s handling of your information, please contact us at help@humancode.com.