We want you to understand how and why we collect, use, maintain, and disclose your Personal Information, and this Privacy Policy governs the manner in which Toolbox Genomics. (“Toolbox”, “we” or “us”) collects, uses, maintains and discloses information collected from users of our Services. By creating and registering an Account with Toolbox Genomics, you consent to the practices described herein. We may update this Privacy Policy from time to time, so please check this Privacy Policy periodically for changes. If you have additional questions or would like further information on this topic, please feel free to contact us at info@toolboxgenomics.com.
SUMMARY
This Privacy Policy notifies you of:
You always have the right to access Personal Information about you and to obtain from Toolbox confirmation as to what, how, and why Personal Information is being processed by Toolbox. Upon your written request, Toolbox will remove any Genetic Information and Self-Reported Information provided by you to Toolbox and will cease using such Personal Information, subject to the terms of this Privacy Policy and the Toolbox Terms of Service. You may request access to and removal of such Personal Information and other Personal Information as collected by Toolbox by sending a written request to Toolbox at info@toolboxgenomics.com. If requested by you, Toolbox will endeavor to provide your Personal Information in a commonly used and machine readable format, which you have the right to use and transmit to another data controller.
By using or accessing any of the Services, you to the processing of Personal Information about you in accordance with the terms in this Privacy Policy, so please review it carefully in advance of using or accessing any of the Services or disclosing any information to Toolbox.
“Agreement” or “Privacy Policy” means this Privacy Policy and includes all terms and conditions contained herein.
“Account” means any and all records created pursuant to the relationship created between you and Toolbox, whether created online via the Toolbox website, by a consent letter or form, or otherwise, in which you provide Toolbox Personal Information in order to use and access the Services.
“Personal Information” means information that can be used to identify you, either alone or in combination with other information.
“Preference Information” is information derived from Registration Information, Genetic Information, Self-Reported Information and/or other information that indicates a preference for one or more products or category of products.
“Terms of Service” means the Toolbox Terms of Service, the most current version of which is available at www.toolboxgenomics.com/terms-and-conditions/.
“Toolbox Genomics,” “Toolbox,” “we,” “us,” or “our” means Toolbox Genomics, a Delaware Corporation, whose principal place of business is at Geneius Health LLC, DBA Toolbox Genomics Draper, UT 84020.
“Toolbox Research” means analysis by Toolbox of its Services, the Toolbox website, Aggregated Genetic and Self-Reported Information, its platform, and efficacy with its users. Toolbox Research only uses individual Genetic Information and/or Self-Reported Information from users who have given informed consent according to an applicable consent document.
“Service” or “Services” means Toolbox’s products, software, services, reports, and Toolbox website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by you regardless if the use is in connection with an Account or not.
“You,” “Your,” or “user” means you, the individual using or accessing the Services, whether acting on your own behalf or for anyone for whom you have legal authority to agree and act on behalf of or otherwise.
Toolbox collects and stores the following types of information in and through the Services that may, alone or in combination with other information, constitute Personal Information:
“Registration Information” is the information you provide, including information about yourself, when registering for and/or purchasing Toolbox Services (e.g., name, email, address, user ID and password, and payment information), whether provided in a consent letter or form, or online, and regardless of whether or not the information is provided via the Toolbox Website or in connection with an Account.
“Genetic Information” is information regarding a genotype (e.g., the As, Ts, Cs, and Gs at particular locations in a genome), generated through processing of or otherwise provided from (i) genetic data and/or genetic information provided by you to Toolbox (through the Toolbox website or otherwise), including raw genetic data and digital versions of the same (which may have been created or generated by third parties, including genetic testing services such as 23andMe, Inc.); (ii) your saliva by Toolbox or by its contractors, successors, or assigns; or (iii) information otherwise processed by and/or contributed to Toolbox.
“Self-Reported Information” is all information about yourself or otherwise reported by you, including information relating to nutrition, diet, disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you provide or enter into surveys, forms, or features while using or accessing Toolbox Services and/or signed in to your Toolbox Account.
“User Content” is all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials other than Genetic Information and Self-Reported Information generated by users of Toolbox Services and transmitted, whether publicly or privately, to or through Toolbox.
“Toolbox Website Behavior Information” is information on how you use the Toolbox website (e.g., browser type, page views, Internet Protocol (“IP”) address from which you access the Services, domains, uniform resource locator (“URL”) of the website from which you came and the website to which you proceed once you leave the Toolbox website) collected through log files, cookies, and web beacon technology.
“Aggregated Genetic and Self-Reported Information” is Genetic Information and Self-Reported Information that has been de-identified and combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.
If you communicate with Toolbox by email or otherwise, post User Content to the Toolbox website or via Toolbox Services, post messages to any forums, complete online forms, questionnaires, surveys, or entries, provide information outside of the account registration process, or otherwise interact with or use the features on the Toolbox website, a record of such communications may be kept.
Cookies
Like most web sites, the Toolbox website uses cookies and web log files to track site usage. A cookie is a tiny data file that resides on your computer that allows Toolbox to recognize you as a user when you return to the Toolbox website using the same computer and web browser. Like the Registration Information you provide during account registration, cookie and log file data is used to customize your experience on the Toolbox website. One type of cookie, known as a “persistent” cookie, is set once you have logged in to your Toolbox account. The next time you visit the Toolbox website, the persistent cookie will allow us to recognize you as an existing user so you will not need to log in before using the Toolbox website. In order to access or change any of your private information, you must log in with your password even if your computer contains your persistent cookie. Additionally, if you log out of the Toolbox website, you will need to re-enter your password the next time you visit in order to log in to your account. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the Toolbox website. Session cookies expire after a short time or when you close your web browser. You can choose to disable cookies on your browser or allow your browser to notify you when a cookie is being sent, however this may prevent you from utilizing certain features of the Toolbox website and Toolbox Services.
Google Analytics
We use a tool called “Google Analytics” to collect information about use of the Toolbox website, including Toolbox Website Behavior Information and for advertising purposes. We have implemented the following Google Analytics features: Display Ads, Google Remarketing Tool, Google AdWords, Google Ad Campaigns and Google Keyword Search. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to the Toolbox website. We use the information we get from Google Analytics only to improve the Toolbox website and our Services, and for advertising purposes. We do not combine the information collected through the use of Google Analytics with Personal Information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is governed and restricted by the Google Analytics Terms of Use (available at https://www.google.com/analytics/tos.html) and the Google Privacy Policy (available at https://www.google.com/privacypolicy.html). You can prevent Google Analytics from recognizing you on return visits to the Toolbox website by disabling cookies on your browser. You can also download a Google Analytics opt-out add on to your browser (available at https://tools.google.com/dlpage/gaoptout/).
(i) Genetic Information and Self-Reported Information
We use Genetic Information and Self-Reported Information for the following purposes:
(ii) Registration Information
We use Registration Information for the following purposes:
(iii) Toolbox Website Behavior Information
We use the Toolbox Website Behavior Information for the following purposes:
(iv) Aggregated Genetic and Self-Reported Information
We use Aggregated Genetic and Self-Reported Information for the following purposes:
(v) Preference Information
Preference Information is exclusively owned by Toolbox, and may be used by Toolbox and its strategic partners to provide you with information on products and services that may be of interest to you, and for other lawful purposes.
Except as otherwise stated herein, Toolbox will not share Personal Information about you with any third party, except under these circumstances:
Information Disclosure Required By Law
You acknowledge and agree that Toolbox 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 process (such as a judicial proceeding, court order, or government inquiry) or obligations that Toolbox may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Toolbox Terms of Service; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Toolbox, its employees, its users, its clients, and the public. In any such event, Toolbox will notify you through the Registration Information or contact information you have provided to Toolbox in advance, unless doing so would violate the law or a court order. You understand that the technical processing and transmission of the Services, including Personal Information, may involve (a) transmissions over various networks and (b) changes to conform and adapt to technical requirements of connecting networks, or devices. Finally, Toolbox may, in its sole discretion, restrict access to the Toolbox website for any reason.
Except as otherwise stated herein, Toolbox will never release Genetic Information or Self-Reported Information to a third party without asking and obtaining explicit consent from you to do so, unless Toolbox is required to by law to do so. Toolbox does not and will not disclose or share Genetic Information or Self-Reported Information to insurance companies or employers.
If a user includes such user’s Personal Information as part of the User Content that such user posts or transmits to the Toolbox website, such information may be made available to any parties using the Toolbox website, Toolbox Services, and/or such User Content. Toolbox does not edit or otherwise remove such information from User Content before it is posted on the Toolbox website. If a user does not wish to have such user’s Personal Information made available in this manner, such user must remove any such information from the User Content before posting. User contact information (which may include, without limitation, a user’s username and email address) may be included with any User Content that a user posts via the Toolbox website. Toolbox is not liable for any damages caused or incurred due to personally identifiable information made available in the foregoing manner.
Personal Information about users that is maintained on Toolbox’s systems and servers is protected using industry standard security measures. In order to secure your Personal Information, access to your data is password-protected, and sensitive data is protected by SSL encryption when it is exchanged between your web browser and the Toolbox website. However, no security measures are perfect or impenetrable, and Toolbox cannot guarantee that the information submitted to, maintained on, or transmitted from its systems will be completely secure. Toolbox is not responsible for the circumvention of any privacy settings or security measures contained on the Toolbox website by any users or third parties.
Toolbox Genomics complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. Toolbox has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Toolbox is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.
Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to info@toolboxgenomics.com. If requested to remove data, we will respond within a reasonable timeframe.
We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to info@toolboxgenomics.com.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Toolbox’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Toolbox remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless Toolbox proves that it is not responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Toolbox commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact us via email at: info@toolboxgenomics.com.
Toolbox has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
Generally, providing Personal Information other than Registration Information and Toolbox Website Behavior Information to Toolbox is voluntary and based only on your choice, your actions, and the permission you give Toolbox.
Giving consent to Toolbox to use the Genetic and Self-Reported Information provided by you for Toolbox’s Services, including its report generation services, Toolbox Research and other research for which you provide consent is completely voluntary.
Your sharing of Self-Reported Information through Toolbox Services, surveys, questionnaires, or other Toolbox website features, is voluntary.
8.1. Updating Registration Information; Opt-Out
If the Self-Reported Information or Registration Information you provided to Toolbox changes, Toolbox will endeavor to provide a way to correct, update, and/or remove your previously provided Self-Reported Information or Registration Information. This can be done by accessing your Account via the Toolbox website or by emailing a request to Toolbox at support@toolboxgenomics.com. When you sign up for updates or receive email messages from Toolbox, you will always be given the chance to opt-out of special offers and Services updates. You may change your preferences at any time and will only be contacted in a manner consistent with your stated preferences. All retained Personal Information will continue to be subject to the terms of the Privacy Policy to which you have previously agreed.
8.2. Accessing or Removing Personal Information About You
Upon your written request, Toolbox will remove any Genetic Information and Self-Reported Information provided by you to Toolbox and will cease using such Personal Information, subject to the terms of this Privacy Policy and the Toolbox Terms of Service. You may request access to and removal of such Personal Information and other Personal Information as collected by Toolbox by sending a written request to Toolbox at info@toolboxgenomics.com. If requested by you, Toolbox will endeavor to provide your Personal Information in a commonly used and machine readable format, which you have the right to use and transmit to another data controller. Please note that in certain circumstances, Toolbox may not be able to completely remove all of Personal Information about a particular user from its systems. For example, Toolbox may retain Personal Information about a user for legitimate business purposes, if it may be necessary to prevent fraud or future abuse, for Account recovery purposes, if required by law, or as retained in Toolbox’s data backup systems or cached or archived pages. All retained Personal Information will continue to be subject to the terms of the Privacy Policy to which the User has previously agreed. Notwithstanding the foregoing, you always have the right to access Personal Information about you and to obtain from Toolbox confirmation as to what, how, and why Personal Information is being processed by Toolbox.
8.3. Closing Your Account
If you no longer want to participate in Toolbox Services, you can close your Account by sending a request to support@toolboxgenomics.com. When you close an Account, Toolbox will remove all of Genetic Information and Self-Reported Information about you within thirty (30) days of your Account closure request. Any Genetic Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in Toolbox Research or other research cannot be and will not be removed from ongoing or completed studies that use this information. Toolbox’s laboratory contractors may retain Genetic Information about you as required by law. Registration Information may be retained as necessary for business purposes as related to your order history and for accounting, audit, and compliance purposes.
8.4 Other Rights relating to Personal Information
Depending on where you live, you may have additional rights provided by applicable law. For example, in addition to the rights to access and remove Personal Information, you may have a right to amend, restrict the processing of, or object to the processing of Personal Information. You may also have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you. We encourage you to first reach out to us at info@toolboxgenomics.com, so we have an opportunity to address your concerns directly before you do so.
California Civil Code Section 1798.83 permits users that are residents of California to request certain information regarding Toolbox’s disclosures of personally identifiable information to third parties for such third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email Toolbox at info@toolboxgenomics.com.
You can see when this Privacy Policy was last updated by referring to the Last Updated legend at the top of this page. Toolbox reserves the right, at its discretion, to change, modify, add or remove portions of this Privacy Policy at any time by posting such changes to this page. When any significant or material change is made to this Privacy Policy, a notice will be posted on the Toolbox website as part of this Privacy Policy for thirty (30) days. After such thirty (30) days, the changes will become effective. Additionally, all registered Toolbox users will receive an email or will receive a notice when logged into their Account notifying them of such changes.
You should periodically review this Privacy Policy for such changes. The most current version of the Privacy Policy is available at www.toolboxgenomics.com/full-privacy-policy and can also be provided upon request by emailing info@toolboxgenomics.com.
Questions regarding this Privacy Policy or how Toolbox handles your Personal Information can be emailed to info@toolboxgenomics.com or can be sent in writing to:
Toolbox Genomics
ATTN: Privacy
Geneius Health LLC,
DBA Toolbox Genomics
Draper, UT 84020