Phi Life Sciences Privacy statement
INTERNET PRIVACY STATEMENT Effective Date — January 1, 2017
THIS NOTICE DESCRIBES HOW YOUR PERSONAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW CAREFULLY.
This Privacy Statement applies to customers using Phi Life Sciences' website to order and/or receive genetic reports.
A Note to Non-U.S. Users
You expressly consent to the processing of your personal information in the United States in accordance with this Full Privacy Statement.
The Full Privacy Statement that follows tells you how Phi Life Sciences collects, protects, uses, and shares the information you provide us and the choices you have regarding our use of, and your ability to correct, that information. The Summary Privacy Statement is intended to introduce the Full Privacy Statement, not replace it. Later, it also serves as a quick reference guide to key information. By using our services, you acknowledge that you have reviewed and agree to the terms of the Consent, Full Privacy Statement and the Terms of Service.
INFORMATION WE COLLECT
By accessing or using this website or other services, purchasing a sample collection kit, or establishing a Phi Life account or submitting a sample, we will collect and store your personal information. This information identifies you or can be linked to your identity and Account Information. The following describes the types of personal information that we collect and store:
Account Information (contact and payment information, personal information for testing (e.g., date of birth, gender, ethnicity, weight, height, etc.) and information in Personal Settings)
Genetic Information Survey-Based Information (Health Survey and Other Surveys)
Sample and DNA Extract
Type of Genetic Report(s) (health or ancestry genetic report, etc.)
Genetic Testing-Based Health Information
Full Health (health conditions, carrier status, drug response)
Health Conditions (at risk diseases and complex health conditions)
Carrier Status (Pre-Pregnancy Planning) (recessive diseases)
Drug (Medicine) Response
FIT (diet and exercise)
Ancestry Information (genealogical and ethnic)
Genetic Counseling Information
Other Customer Provided Information Online Profile Information (computer IP address and non-personal information, such as browser types, web page views)
Friend's Name and Email
Customer Service Notes
Aggregate Information (summarized information unlinked to name or Account Information)
HOW WE USE YOUR INFORMATION AND YOUR CHOICES
Phi Life collects and uses your Account Information, Genetic Information, Survey-Based Information, Other Customer Provided Information, and Online Profile Information to provide you our services.
Phi Life's Comprehensive Genotype Testing process collects more Genetic (genotype) Information than is used to complete your genetic report that was ordered.
Third Party Service Providers may have access to and use Account Information, Survey-Based Information, and Other Customer Provided Information to deliver these services to you on our behalf. Phi Life-authorized physicians, genetic counselors and their agents may also have access to Genetic Information and other personal information to fulfill their responsibilities.
You cannot opt-out from transactional communications that are essential to delivering our services to you, unless a marketing message or advertisement is included.
We analyze and use Aggregate Information (unlinked from your name or Account Information, and Online Profile Information (your computer IP address and non-personal information) to track and monitor aggregate usage of our website and to improve the quality and features of our website and services. You can delete cookies as described in Cookies, under the Online Profile Information section of Information We Collect in the Full Privacy Statement.
We use your Account Information, Genetic Information, and Survey-Based Information to offer the right products and services from Phi Life and Trusted Partners to you. In this case, we maintain control of your personal information. You can opt-out from receiving each of these marketing communications (see the "How to Exercise Your Choices" section that follows). You can also delete cookies as described in Cookies, under the Online Profile Information section of Information We Collect in the Full Privacy Statement.
If you elect to use our Refer-A-Friend service, we will send a one-time email to your friend inviting them to visit our website. We will not share this information with any marketing partners. Your friend may request, using the email or physical address identified in the Contact Us section, the removal of his name and email address from our database.
HOW WE SHARE YOUR INFORMATION AND YOUR CHOICES
Phi Life will NOT share your Genetic Information or any other personal information with your employer or health insurance issuer.
Your genetic testing results will be disclosed to the ordering physician, who determines at his/her discretion whether to release the results to you, and Phi Life will not release your report to anyone else unless required by law.
Any reseller of our products or services should not collect personal information from you without your consent.
We may use your DNA marked only with a Phi Life-assigned unique identification number, along with other Genetic Information, Survey-Based Information, and other personal information which will either not include your name or contact information or will be encrypted for internal operations purposes to: validate genetic information; improve the quality and accuracy of Phi Life's genetic reports; develop new genetic reports and/or services, but not publish the results in scientific literature; promote the types of information that customers may learn from our reports; improve the quality and features of our website and services; and produce data for product approval or clearance by FDA or other regulatory authority or body.
We may contact and give you the opportunity to opt-in or refuse before any personal information is shared for any secondary purpose outside Phi Life's immediate control, including published scientific research. We also may pass on to you a research collaborator's request that you volunteer additional information or participate in a study. No name or Account Information is shared with a research collaborator without your express consent.
If you are a customer as a result of participating in your employee wellness program, Phi Life only provides your employer Aggregate Information unlinked to your name or Account Information.
We may disclose or report your personal information when we believe in good faith that the disclosure is required or permitted by law or regulation, a court order or other judicial or legal process or proceeding, or to cooperate with regulators or law enforcement authorities to resolve consumer disputes.
If Phi Life enters into a business transaction, such as a merger, acquisition by another company, selling some or all of its assets, or bankruptcy, your personal information will, in most instances, be part of the assets transferred. We will require the acquiring company to comply with the material provisions of the Full Privacy Statement upon entering into such business transaction.
HOW TO EXERCISE YOUR CHOICES
Opt-outs – To the extent you are permitted, you may exercise your right to opt-out by either a) clicking the unsubscribe link in the footer of any Phi Life's email or replying with unsubscribe in the subject line, or b) writing to us at the address in the Contact Us section at the end of this Privacy Statement.
Opt-ins – You may exercise your right to opt-in when expressly presented with this choice prior to the indicated personal information being shared.
ACCESSING, CORRECTING, UPDATING, OR DEACTIVATING YOUR INFORMATION
Phi Life will not be responsible for any liability caused by you sharing your personal information with others.
If your Account Information changes (such as email address, street address, or phone number), you can log into your account and change the appropriate information.
At your written request and according to your instructions, we can destroy your DNA extract at the next scheduled sample destruction date which occurs about every sixty (60) days and/or deactivate your Account from our systems within ten (10) days by contacting Phi Life as identified in the Contact Us section. However not all personal information can be removed from our systems. We are required by law and standards of medical practice to preserve medical records, some contact information, and disclosure records for specified time periods. Information archived on data backup media also cannot be deleted, however is protected by encryption. Aggregate Information and information in logs cannot be deleted.
We may deny access when denial of access is authorized by law, when granting you access would have an unreasonable impact on other people's privacy, or to protect Phi Life's rights and property.
HOW WE STORE AND PROTECT YOUR INFORMATION
Phi Life has adopted administrative, physical and technical security measures to protect your personal information. However no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we use commercially reasonable and appropriate means to protect your personal information, we cannot guarantee its absolute security.
POLICY ON MINORS
For orders authorized by your personal physician, we may collect personal information from minors. However parent or guardian consent should be obtained and maintained by your physician.
In any event, we will not knowingly market products or services to children under 18.
YOUR CALIFORNIA PRIVACY RIGHTS
California customers can request a list of personal information categories disclosed to third parties for their direct marketing purposes and the names and address of such third parties.
CHANGES OF THE PRIVACY STATEMENT
Material changes to this Privacy Statement that unfavorably affect your rights will be emailed to you and will be posted on our website at least thirty (30) days before the effective date of the Privacy Statement.
HOW TO CONTACT US FOR PRIVACY COMPLAINTS, QUESTIONS OR COMMENTS
If you have questions or comments regarding our privacy practices or have a complaint about our use or disclosure of your personal information or our privacy practices, you may contact us either by mail, email, or phone as follows:
Info@philifesciences.com or (888) 576-5445 Chief Executive Officer, Phi Life Sciences 645 Meeting St, Suite 3 Charleston, SC 29403
If we are unable to reasonably resolve any compliant to your satisfaction, you may also file a complaint with the Secretary of the U.S. Department of Health and Human Services and/or the South Carolina Department of Health Services. Phi Life will not take retaliatory action against you for filing a complaint about our privacy practices.