Privacy Policy
Effective Date / Last Updated: January 24th, 2021
This Privacy Statement describes the information collected by MyTraitRx, PLLC (together with any and all affiliates, “MyTraitRx,” “we,” “us,” or “our”) through our website (“Website”), including your MyTraitRx account, our mobile application ("App") and any related services we provide (collectively, the “Services”) and how that information is used and shared. “Services” include our pharmacogenomic DNA testing services and reporting, and any software applications we may make available, as well as any e-mails, texts or other electronic communications sent in connection with the Services.
This Privacy Statement is incorporated into and made a part of our <Terms of Use>. By accessing or using the Services, by clicking "I Agree", or by entering into any agreement with MyTraitRx that references this Privacy Statement, you (“you”, “your”, or “yours”) agree that you have read and understood this Privacy Statement. If you do not agree with this Privacy Statement, do not access or use the Services, leave the website, and permanently delete any App from your devices.
We reserve the right to modify this Privacy Statement at any time. All changes will be effective immediately upon posting to the Services. Material changes will be conspicuously posted on the Services or otherwise communicated to you.
Additional Terms
If you participate in beta-testing our products or services, or if you purchase or participate in certain of our add-on services which MyTraitRx may offer from time to time, additional terms, conditions, and policies may apply which will be presented at the time of participation or data collection.
How We Collect Information
The information that we may collect from or about you broadly falls into the following categories:
● Information that you voluntarily provide to us, for example, your contact information, your payment information, and information submitted in the course of receiving or using our DNA testing services.
● Information that we (or our third-party service providers) automatically collect through your use of the Services, for example, data collected by the servers used to operate our website (e.g., IP addresses), data collected by cookies, data collected through your use
of our Website, App, and data collected by analytics and advertising services.
Information Collected which You Provide
● Personal Information. For purposes of this Privacy Statement, "Personal Information" is information that alone or in combination with other information, can identify a natural person. You can visit our Website without providing us with your Personal Information, but you will be required to provide Personal Information in order to order or purchase our pharmacogenomic DNA testing services and to use certain features of the Services. We will collect any Personal Information from or about you that you choose to provide to us, which may include your name, email address, telephone number, physical address, billing address, birth date, and payment information. For example, you must provide certain Personal Information to purchase pharmacogenomic DNA test kits, when contacting MyTraitRx customer support, when receiving and fulfilling information requests, when registering for an account to order or use the Services, and when responding to communications from us (e.g., questionnaires, surveys, promotional offers, etc.).
● Accounts. When you set-up a MyTraitRx account online or through our App, you are required to provide certain Personal Information such as your name, email address, and other contact information requested. To order your pharmacogenomic DNA test kit, you will need to provide your name, email address, age, gender, birth date, and any other similar information as requested at such time, as well as your name on the saliva collection tube in the DNA test kit. In order to provide you certain Services, we may at times need you to respond to certain questionnaires and/or surveys, whether online, written, or verbal.
● Questionnaires. We will collect all information you choose to provide in the course of completing any questionnaires or any other forms or surveys we may provide. Some information we request is required in order to use the Services or receive reports from us, such as your name, contact information, birth date, age, gender, zip code, personal attributes, health-related information (e.g., health goals, medication information, diseases, blood glucose levels, cholesterol levels, family medical history), and other similar types of information. Some information we request from you is optional, but it helps us provide Services more customized to you and our other users, and it helps us provide better Services. As Services and business plans evolve over time, MyTraitRx may modify the types of information and questions that are mandatory versus optional, from time-to-time. We will indicate what information is mandatory when we ask you to fill out the applicable questionnaire or survey. You may opt-out of participating in MyTraitRx questionnaires, forms, or surveys, however, we may not be able to provide you certain Services or reports without the requested information.
● Location. We may ask for your zip code or provide you the option to opt-in to location tracking to provide certain Services to you. For example, we need to know your approximate location in order to help find grocery stores near you. We also use location
information to customize our Services to you, to improve the Services, to help us with product development, and to send targeted advertisements to you. You may opt-out of location tracking in the settings within your account or by declining to permit location
tracking when prompted.
● Genetic Data. One type of Personal Information is genetic data. When you provide your saliva sample, it is collected by our designated third-party DNA testing company that we contract with, and they provide your raw genetic data to MyTraitRx.
● Pharmaceutical History; Medication List. We may collect all information you choose to communicate to us in the course of using the Services, including information that does not personally identify you, such as any drugs or medications which you may choose to
enter into or log while using the Services.
● Emails from Us. If you sign up or otherwise opt-in to receive newsletters or promotions from us, you will need to provide your e-mail address. You understand and agree that we will use this information to provide you with promotional and other electronic communications. In addition, we will send you information about how to interpret your MyTraitRx report when you order pharmacogenomic DNA testing services from us. You may opt-out of receiving promotional e-mails from us at any time by following the unsubscribe instructions contained in the applicable e-mail. We may use third-party e-mail providers to deliver these communications to you.
● Order and Payment Information. Purchases of products or services must be made by credit or debit card. All credit and debit card information is provided directly to our PCI-compliant third-party payment processor. MyTraitRx does not directly access, handle, or store your credit or debit card information. To make a purchase, you will need to provide your name and your credit or debit card type, number, expiration date, security code, and billing address. We will maintain a record of the purchases that you make using our website. Our payment processor, PayPal, may use your payment-related information in accordance with the PayPal Privacy Statement.
● Sweepstakes and Contests. We may offer sweepstakes, promotions, or contests that you may participate in at your option. To participate, you must submit certain information as set forth in the applicable terms and conditions, which may include Personal Information. Data collected via sweepstakes, promotions, and contests will be (i) used to contact you with promotional and related communications, (ii) shared with third-party vendors, and (iii) subject to additional terms provided to you at such time.
● User Content. MyTraitRx may, from time to time, provide member- or account-holder only areas of the Website for registered users to share or upload their user-generated content or material with other users. Any such content or related Personal Information
that you upload or share may become public information, may be posted on our website, and will not be treated confidentially (although we will not post your last name on our Website). We will use your content and related information as described in the
Terms of Use
Information Automatically Collected from Use of the Services IP Addresses and Related Data. The servers used to operate and provide the Services may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Services, including Internet protocol (IP), addresses assigned to the devices from where you access the Internet, your Internet service provider(ISP), your device name, year and class, your device ID number and manufacturer, your approximate geographic location, your web browser type, the pages you access on the Services, the websites you access before and after visiting the Services, the length of time you spend on the Services, date and time stamps, and clickstream data. MyTraitRx may use this information to administer, monitor, and analyze the Services, to monitor and help prevent fraud, to investigate complaints and violations of our policies, to track and identify potential marketing leads, to protect our rights and improve security, to improve the Services, to perform targeted advertising, and to help us with product development. The suppliers that we use to provide the Services may collect a similar type of information about your visits to the Services and other websites.
Cookies
Our Website and App automatically use cookies to track your use of our Website and App. Cookies are small pieces of information that are stored on your device’s hard drive by your web browser that provide us information about your activities.
Types of Cookies
Cookies can be either “first-party” cookies or “third-party” cookies. A first-party cookie allows your web browser to talk to the actual website that you are visiting, whereas a third-party cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We do not have access or control over third-party cookies and this Privacy Statement does not cover the use of third-party cookies. Most web browsers automatically accept cookies. You can disable cookies on your browser but disabling cookies may impact your use and enjoyment of the Services. Changing your cookie preferences in one web browser will not necessarily carry over to other web browsers. You may not be able to disable operationally necessary cookies.
What information is collected and how is that information used?
The types of information collected by a cookie and the purposes for which that information is used depends on the type of cookie. By way of illustration, the types of information collected by our Website’s cookies and the purposes for which that information is used are described below. We may also combine information collected by cookies with other information.
● Operationally necessary (also called “essential”). These are cookies that are required for the operation of our Website. For example, these cookies are required to identify irregular website behavior, prevent fraudulent activity, and improve security. They also allow users of our Website to make use of its functions, for example, shopping carts, saved searches, and similar functions. Without these cookies, services that you have requested cannot be provided.
● Functionality related. These cookies allow us to offer you enhanced functionality when accessing or using our Website. This may include remembering choices you make, for example, remembering your username, preferences, or settings, remembering if you reacted to something on or through our Website so that you are not asked to do it again, remembering if you have used any feature of our website before, restricting the number of times you are shown a particular advertisement, remembering your location, and enabling social media components. You may disable functional cookies, but then various functions of our website may be unavailable to you or may not work the way you want them to.
● Performance-related (also called “analytical ”). These cookies assess the performance of our Website, including as part of our analytic practices to help us understand how users visit or use and interact with our Website, for example, which pages on our Website users visit most often. These cookies also enable us to personalize content and remember your preferences (e.g., your choice of language, country, or region). These cookies help us improve the way our Website works and provide a better, personalized user experience. Some of our performance-related cookies are managed for us by third parties.
● Advertising or targeted. These cookies record your visits to our Website, the pages you visit, and the links you have clicked. They gather information about your browsing habits and remember that you have visited a particular website. MyTraitRx and its third-party
advertising platforms or networks may use this information to make our websites, their content, and advertisements displayed on our websites more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising). These cookies are also
used to limit the number of times you see an advertisement, provide aggregated auditing, provide research and reporting for advertisers, help improve our Services and help measure the effectiveness of advertising campaigns. To find out more about
interest-based ads and your choices, please visit: Digital Advertising Alliance, the Network Advertising Initiative, http://www.allaboutcookies.org, or http://www.youronlinechoices.com.
How long do cookies last? A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the applicable website. Persistent cookies exist for a set period of time, for example, six months or one year. Each time you visit a website that has implemented a persistent cookie, that cookie will remain active until its predetermined expiration date. You can also manually delete persistent cookies.
What about other tracking technologies? The Services may also use the following types of tracking technologies: web beacons (also called clear GIFs), flash cookies, and pixel tags. A web beacon is a tiny graphic with a unique identifier that functions similar to how cookies function. However, in contrast to cookies, web beacons are embedded invisibly on websites. Flash cookies collect and store information about your use of our Services and are commonly used for advertisements and videos. Pixels can be placed on websites or within emails to track your interactions with those websites and when emails are opened.
How can I control, disable, or opt-out of cookies? Most web browsers allow users to manage cookies in the browser’s settings. Please note that disabling or otherwise limiting cookies may impact your use and enjoyment of the Services and other websites. For your reference, we have included the below links to various web browsers’ instructions on managing cookies.
● Mozilla Firefox
● Google Chrome
● Internet Explorer
● Android Browser
● Safari(Desktop)
● Safari(Mobile)
More information. For more information about cookies, including about advertising cookies and your choices regarding cookies, we suggest you visit:
● https://www.consumer.ftc.gov/articles/0042-online-tracking
● http://www.allaboutcookies.org
● https://www.aboutcookies.org
● http://www.youronlinechoices.eu
Mobile App Tracking Usage Details
If you are using the Services through our App, MyTraitRx and its third-party service providers may automatically collect certain information to help us enable the App and create a better user experience, to provide targeted advertising, and help us improve the Services. For example, we may collect the time spent on each page, the buttons clicked, the location where the App was accessed, and when the App was accessed. We may also use Amazon Web Services, Inc. ("AWS") and Google Analytics to help us with such data collection.
Geolocation
MyTraitRx and its third-party service providers may collect the location of your device for the purpose of improving the Services and other product development purposes, as well as improving your user experience. You may disable this feature by declining to permit us to track your location if prompted.
App Stores
The specific app store from which you downloaded the App (e.g. Google Play or Apple's App Store) (together, "App Store") also tracks certain information, such as the number, location, and time of App downloads and installs.
More About Third-Party Analytics
The Services, including the App, may utilize third-party analytics tools (e.g., Google Analytics, AWS) to collect and process data about your use of the Services and other activities online. Our analytics providers may set and read cookies to collect data about your use of the Services and other websites that you visit and your web browser will automatically send such data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content, improve the user experience, for product development purposes or to provide and improve targeted advertising to you. We also use data gathered by these third-party analytics companies in public presentations and at conferences, but such data is in a de-identified and aggregated format. One type of third-party analytics that we use is Google Analytics. Google sets cookies and then your web browser will automatically send data to Google. Google uses this data to provide us with reports that we use to improve the website's structure and content. For more information on how Google uses this data that it receives directly from cookies that it places, visit Google’s Privacy Statement and Google’s page on How Google uses data when you use our partners' sites or apps. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each web browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent MyTraitRx from using other analytics tools and will not prevent data from being sent to the Services itself or to Google. For more information about how Google Analytics uses cookies to measure user-interactions on websites, visit Google Analytics Cookie Usage on Websites. You may disable cookies as discussed above, but that may impact your use and enjoyment of the Services. We also use third-party providers such as Criteo, Peaches, and Hubspot on our web-based platform to enhance our marketing efforts, which include tracking users via their IP address. The App Store and some mobile device manufacturers also collect analytics data about download rate and app usage, which they may provide to MyTraitRx.
Interest-based Advertising
The Services may use advertising networks and services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including Google Ads and advertising services provided by Facebook (sometimes referred to as the Facebook “tracking pixel”) and Instagram. These services collect information about your visits to and interactions with the Services and other websites and will use that information to target advertisements for goods and services. The information collected may be associated with your Personal Information. These targeted advertisements may appear on the Services or on other websites. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Services and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. To opt-out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Services. If you have a Facebook account, but do not wish Facebook to collect data relating to you via the Services, we suggest that you:(a) hide social media platform plug-ins using an ad blocker; (b) always log off completely from Facebook before visiting other websites and delete all related cookies; and (c) where the option is available, disable the advertising services and networks operated by Facebook. To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other web browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Other Advertising. When you access your account, we may direct advertisements to you to purchase certain recipes based on recommendations, as well as to purchase subscriptions to use additional add-on services. Our Social Media Pages. MyTraitRx is active on social media, including Facebook, Twitter, and Instagram. MyTraitRx reserves the right to post on its websites and social media pages any comments or content that you post on our social media pages. Anything you post on Social Media is public information and will NOT be treated confidentially. If you connect with Social Media through our Services, certain features may require those Social Media platforms to use cookies, plug-ins, and APIs to enable those features. Your use of Social Media is governed by the privacy policies and terms of the third parties that own and operate those Social Media websites and not by this Statement. The Services may use advertising networks and services offered by Social Media platforms to deliver advertising content.
Embedded Content
The Services incorporate content, including feeds scripts embedded in the Services’ code and visible content (for example, videos), provided by third parties. In some cases, MyTraitRx or those third parties collect data about how you interact with their content.
WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
How We Use and Share Personal Information
MyTraitRx may share your Personal Information with the following categories of third parties for the uses described in this Privacy Statement:
● Affiliates and employees
● Third-party laboratory for DNA testing services
● Third-party service providers and suppliers
● Third-party partners
● Government/law enforcement
● Professional advisors
● Subsequent owners, assigns, and successors
In addition to the uses and sharing described throughout this Privacy Statement, MyTraitRx may use and disclose Personal Information as described below. We do not use, sell, rent, or otherwise disclose Personal Information except as stated in this Privacy Statement and as permitted by applicable law. For the Purpose Collected. We will use and share your Personal Information for the purposes stated or agreed-to (or as was obvious) at the point of collection. For example, we use and share Personal Information to communicate with you in connection with your orders submitted through the Website, to administer your MyTraitRx account, to provide DNA testing reports back to you, to provide other MyTraitRx products and services, to provide you with information and communications that you request. Provision of DNA
Testing Services and Add-On Services - Use and Disclosure of Genetic Data
If you have purchased pharmacogenomic DNA testing services from MyTraitRx, we will use and share genetic data in order to provide you with those DNA testing services in accordance with our <Terms of Use>. Primarily, this means that the third-party laboratories we have engaged will analyze saliva samples to generate raw data (where you have provided a saliva sample) and MyTraitRx will analyze and process that data (and, where applicable, any DNA data uploaded by you), along with your answers to our questionnaires, in order to generate and provide you with customized genetic and pharmacogenomic reports. Other Personal Information collected when providing the DNA testing services (such as your contact information) is used as described throughout this Privacy Statement. We also use your genetic data, in a de-identified and/or aggregated format, in order to improve our products and Services (i.e. for our own internal research and development purposes). Except as described in this Privacy Statement, we do not share your genetic data outside of the MyTraitRx company in a personally-identifiable format, with any third parties unless you authorize us to do so. We also may share certain results, recommendations, and other data or research resulting from your de-identified or aggregated genetic data, so long as it no longer identifies you.
Personalized Analyses through the Services
As part of the Services, we analyze the information we collect from you, including Personal Information, and provide you with various
reports, views, and displays of your information. We sometimes add additional information to your information. IF YOU DO NOT AGREE TO HAVE THIS TYPE OF ANALYSES PERFORMED ON YOUR INFORMATION, YOU SHOULD NOT USE THE SERVICES.
Biobanking
By providing your consent to biobanking, MyTraitRx’s third-party genotyping laboratory will store your DNA sample and related personal information for up to five (5) years. Aside from providing your consent to biobanking, no additional action is required by you to
biobank your DNA sample. Biobanking is provided at no cost to you, and you can withdraw your consent at any time by emailing us at privacy@mytraitrx.com. There is no penalty for withdrawing your consent.
To Communicate with You.
We may use Personal Information to respond to your questions, comments, or complaints, to notify you of changes to our <Terms of Use> or this Privacy Statement, and to provide you with promotional materials and other communications as described above. If you provide us with your telephone number in connection with your account or your orders, we may call you at that telephone number regarding your account and your orders, as well as in response to any questions that may arise. If you contact us for support or assistance in using the Services, we may use Personal Information to determine whether or not your system meets the minimum requirements needed to access and use the Services and otherwise to contact you regarding your request. We may also use the Personal Information you provide through surveys and questionnaires to provide you additional information about the Services.
Product Development
You understand and agree that we use certain information, including Personal Information, in part, to help improve our products and Services and develop new products and services. When we use your information for such purposes, we first de-identify and/or aggregate any Personal Information so that it no longer identifies you individually. Advertising. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services, products or programs, to notify you of new features of our Website or App, and for other similar communications. Sharing Collected Information with Our Third-Party Service Providers and Suppliers. We may share Personal Information with our third-party service providers and suppliers. These third-party service providers and suppliers include the providers of our pharmacogenomic DNA test kits and the laboratories that analyze saliva samples, as well as our Website and App management and hosting suppliers, cloud storage providers, IT security providers, payment processors, marketing, advertising, and public relations service providers, e-mail service suppliers, suppliers that help us with product development, and shipping label providers. Our third-party service providers and suppliers are authorized to and may use and disclose Personal Information as necessary for them to provide the applicable services to us and, if applicable, as provided by their own privacy policies. Evaluation and Improvement of Our Services, User Demographics, and Aggregation. We may use and disclose Personal Information to: administer, analyze, develop, and improve the content, materials, products, and services that we make available (including the Services); tailor features, customer content, and preferences; manage profiles and accounts; troubleshoot problems; recognize you in the Services; to inform marketing and communication plans and strategies; to understand customer demographics and preferences; and to evaluate customer needs and customize website content, promotional emails, and users’ browsing experience. In addition, we may aggregate your Personal Information and other collected information to create aggregate data on users that describe users as a group but do not reveal the identity of individual users. We may use and share aggregated data in order to understand users’ needs, to determine usage patterns, to determine what kinds of products and services we can provide, and to improve and enrich our products and services.
Security and Protection of Rights
We may use and share Personal Information as required or permitted in accordance with subpoenas, court orders, law enforcement requests, and other legal processes. MyTraitRx will use Personal Information and share it with third parties if we believe doing so is necessary to protect our rights or the rights of others, including disclosing information necessary to identify, contact or bring legal action in the event of a violation of our contracts, terms, or policies.
Business Transactions
In the event MyTraitRx undergoes a change in control, acquisition, merger, reorganization, or asset sale, in whole or in part, we may transfer, sell, share, or otherwise disclose Personal Information to the subsequent owner(s) or successor(s) of the transaction. That owner(s) or successor(s) will be bound by this Privacy Statement as it applies to that information. Also, if MyTraitRx (or our assets) are acquired or if we go out of business, enter bankruptcy, or go through some other change in control or reorganization, Personal Information could be one of the assets transferred to or acquired by a third party. Professional Advice. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to MyTraitRx.
To Send You Push Notifications
The Services will automatically send you certain reminders or "push" notifications unless you opt-out by turning off those reminders in your account on the "Settings" page. With your consent, we may use and share your Personal Information in ways not specifically described in this Privacy Statement.
How Long We Retain Your Personal Information
Generally. MyTraitRx will retain Personal Information for as long as it is needed or otherwise serves the purposes outlined in this Privacy Statement and in accordance with our <Terms of Use> or other applicable agreement with you, subject to retention periods as required or permitted by applicable law (e.g., tax, accounting, and other legal requirements). MyTraitRx and our third-party genotyping laboratory will retain certain Personal Information (e.g., genetic data, date of birth, and sex) as required for compliance with applicable legal obligations, including the federal Clinical Laboratory Improvement Amendments of 1988 (CLIA) and laboratory accreditation requirements. However, your withdrawal of consent will not be effective regarding any uses or disclosures of genetic data, DNA samples, and Personal Information that MyTraitRx already used or disclosed in reliance upon your prior consent. For example, if any of your genetic data or DNA sample was used, or is currently in use, in research or analyses that began before you withdrew your consent, MyTraitRx and any third party with whom you consented that MyTraitRx may share such information will not delete your genetic data or DNA sample from resulting research or analyses or from any research and analyses in progress.
De-Identified Data
MyTraitRx may create de-identified or aggregated data from Personal Information it collects so that it no longer identifies an individual. MyTraitRx may use and disclose to third parties de-identified or aggregated information without restriction, in compliance with applicable laws. MyTraitRx is the sole and exclusive owner of any research or analyses resulting from or including your Personal Information, genetic data, or DNA samples.
Feedback Submitted by You
If you submit feedback to us about the Services or anything else relating to MyTraitRx, we may use and disclose that feedback for any purposes without compensation to you and we may, in our sole discretion, not treat such feedback as confidential.
Information Security
We have appropriate technical and organizational security measures in place to help protect against the loss, misuse, and alteration of Personal Information under our control, including Secure Sockets Layer (SSL) technology, which is used to encrypt information passed between your web browser and our systems. If your Personal Information is breached, we will notify you if required under applicable law. Nevertheless, by accessing or using the Services, you understand that no data transmission over the internet or a mobile device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide any Personal Information at your own risk.
Access by Minors
The Website, App, and Services are only intended for adults who are the age of majority in their state of residence (typically this is 18 or 19 years of age). MyTraitRx does not knowingly collect information from children under 18 through the Services.
Third-Party Websites and Services
The Services may link to, or be linked to, websites and services not maintained or controlled by MyTraitRx. MyTraitRx is not responsible for the privacy policies or practices of any third parties or any third-party websites or services. This Privacy Statement does not apply to any third-party websites or to any personal or other information that you may provide to third parties.
Access from Outside the United States
If you are accessing or using the Services from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States (where our and our suppliers’ servers and databases are located and operated). Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required in other jurisdictions.
Information for California Residents
California residents may, in accordance with applicable law, request access to, deletion of, and portability of your Personal Information or more information about our privacy practices. For purposes of this section, “California resident” and “personal information” have the meanings given in the California Consumer Privacy Act of 2018 (California Civil Code Section 1798.83) (the “CCPA”). Personal information does not include de-identified or aggregated information, information publicly available in government records, or certain information excluded from CCPA’s scope.
Right to Access
You can access much of your MyTraitRx personal information by logging into your MyTraitRx account. You may also, subject to applicable law and verification procedures, request details from us about the information we have collected from and about you over the past twelve (12) months, including:
● The categories of personal information we have collected about you,
● The categories of sources from which the personal information was collected,
● The purpose for our collection or sale of your personal information,
● The categories of third parties with whom we have shared your personal information, and
● The specific pieces of personal information we have collected about you.
If you wish to request such access to your personal information, please contact us at the e-mail or mailing address provided in the Contact Us section at the bottom of this Privacy Statement.
Right to Delete
You may, subject to applicable law and verification procedures, request that we delete any personal information we have collected about you, subject to a number of exceptions, including, but not limited to, if the information is necessary to:
● Complete a transaction with us;
● Provide you a good or service;
● Perform a contract between us and you;
● Protect your security and prosecute those responsible for breaching it;
● Fix our system in the case of a bug;
● Protect the free speech rights of you or other users;
● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §
1546 et seq.);
● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adhere to all other applicable ethics and privacy laws;
● Comply with a legal obligation; or
● Make other internal and lawful uses of the information that are compatible with the context in which you provided it. If you wish to request deletion of your personal information, please contact us at the e-mail or physical address provided in the Contact Us section at the bottom of this Privacy Statement. You may also delete data on your own, for example, by deactivating and permanently deleting your MyTraitRx account.
Verification Procedures
To protect the privacy of your information and account, we are required to verify your request. The verifiable request must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise your choices on your behalf, please select an agent registered with the Secretary of State of your state of residence and provide evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit
requests to exercise rights on your behalf.
Nondiscrimination
We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available through the Services may change or no longer be available to you. Any differences are related to your information.
“Shine the Light” Requests
You have the right to request and obtain from us once a year at no charge a list of all third-parties, if any, to which we have disclosed your personal information during the preceding calendar year for those third parties’ direct marketing purposes. If you would like such a list, please contact us at privacy@mytraitrx.com. For all such requests, you must put the statement “Shine the Light Request” on your request, as well as your name, street address, city, state, and zip code. Please note that we will not accept these requests by telephone, or fax, and are not responsible for notices that are not labeled or sent properly or that do not have complete information. If you are a California resident under eighteen (18) years old, you can request that we remove content or information that you have posted to our Services (California Civil Code Section §22581) by contacting us as per the "Contact Us" section below.
How to Access, Correct or Delete Your Personal Information
Generally. To access or update your Personal Information as it exists in our records, or to request that we delete any Personal Information we maintain about you, please visit the account settings section of your MyTraitRx account (if applicable) or contact us at privacy@mytraitrx.com or by sending a written request by United States mail, postage prepaid to the following address:
MyTraitRx, PLLC
P.O. Box 71864
Phoenix, Arizona 85050-9998
Attn: Privacy Officer
Biobanking
To withdraw your consent for biobanking and request that we delete the bio banked information, please email us at privacy@mytraitrx.com. We will make reasonable efforts to update or delete your Personal Information within a reasonable time period of your request. It may take up to 90 days to comply with your request to delete information. However, we may decline to delete certain Personal Information if we have a business reason for doing so (e.g., as reasonably necessary to comply with our legal obligations, to enforce agreements, to resolve disputes, etc.), as permitted by applicable law. We may require you to prove your identity before providing you access to, updating, or deleting your Personal Information. Except as prohibited by applicable laws, we may decline to process requests that are unreasonably repetitive, required is proportionate technical effort, jeopardize the privacy of others, or would be extremely impractical. However, the third-party genotyping laboratory we partner with will retain your Personal Information, including genetic data, as required for compliance with applicable legal obligations, including the federal Clinical Laboratory Improvement Amendments of 1988 (“CLIA”) and laboratory accreditation requirements. Once you submit a saliva sample, we cannot return it to you.
Contact Us
If you have any questions or concerns regarding this Privacy Statement, contact us by e-mail at privacy@mytraitrx.com or by United States mail, postage prepaid, at:
MyTraitRx, PLLC
P.O. Box 71864
Phoenix, Arizona 85050-9998
Attn: Privacy Officer