Platform Privacy Policy
This Privacy Policy is effective as of the 28th of May, 2024.
Almaden Genomics g.nome® Privacy Policy
This g.nome Privacy Policy (“Policy”), explains our use and your rights as it applies to the Personal Information (PI) collected and used by Almaden Genomics’ g.nome Software. Our objective when using your Personal Information is not only to meet our compliance obligations under applicable privacy laws, but also to honor the trust you place in us when using our Services. Your access and use of our Software and other Almaden products or services means you agree to this Policy, our website Privacy Policy, and Our Acceptable Use Policy and their terms and conditions.
In this Policy, “you” and “your” refers to a User or client user of our Services and “Almaden Genomics,” “Almaden,” “we,” “us,” and “our” refers to Almaden Genomics LLC and any affiliates and parent companies.
Who to Contact & How
Any questions or concerns about how we use or process your PI should be directed to the Customer or entity who collected that PI from you as a User, client, or patient. If you have questions for Almaden directly, please contact us at privacy@almaden.io, or at 1409 Botham Jean Blvd Suite 1007, Dallas, TX 75215, U.S.A. We are happy to help where we can.
How this Policy Applies to the g.nome Software
This Policy applies to our use of PI in our Software and the products and services we provide, which includes any third party materials we need for our Software to function (our Services). Unless we say otherwise in this Policy, this Policy replaces and supersedes all previous privacy policies applicable to our Services. Note our website or other products and services may have separate, distinct policies and terms specifically applicable those sites, products or services.
Why and How We Collect and Use Personal Information
User Information
To properly access and use our Services, certain pieces of PI, such as a name, email address, and company name, are collected from our Customer or by us directly from the User working on behalf of our Customer in the Services (“User Information”). This User Information is collected to:
- Enable communication with Users of the Services.
- Provide proper access, uniquely identity and secure authorization to Users of the Service.
- Maintain security, integrity and privacy of the system
- Ensure compliance with applicable laws.
- Support, maintain, monitor and improve the Services.
- Implement legal and regulatory requirements, do internal audits and conduct necessary reviews.
Note: The Services may collect and use other information as it relates to your specific use or activity and how we provide our Services to meet your expectations. We may also aggregate PI from your use of the Services with data from other Customers and Users for legitimate business purposes, such as conducting usage analysis and product testing to determine User and Software performance trends. When data is aggregated this way, Almaden de-identifies or anonymizes the data, removing User Information or other PI.
Genomic Information
The g.nome Services optimize and streamline reliable big-data analysis and team collaboration for genomic research and discovery. Our Services process genomic data, which may include PI. Genomic PI is Sensitive Personal Information (“SPI”) under GDPR and other data privacy laws. It is also considered Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) in the United States.
HIPAA applies when Almaden processes genomic PI from individuals in the United States; Almaden and the Customer (the HIPAA Covered Entity) will have entered into a Business Associate Agreement for the secure and lawful processing of that PHI in our Services. For information regarding the use of PHI in our Services, you will need to contact the Covered Entity directly.
For lawful use of Sensitive PI under GDPR and other data privacy laws where HIPAA does not apply, we have an agreement with our Customer which details the secure and lawful processing of that Sensitive PI in the Services. Almaden acts as the Processor or Service Provider in these instances. Our Customer is the entity which collects the genomic PI from the individual, and is the Controller or Processor of your Sensitive PI. If you want information about Almaden’s processing of your Sensitive PI on behalf of the Controller or Business, you will need to contact that Controller or Business directly.
Almaden processes PI in the United States.
No Sensitive PI about Users is collected, stored or used.
Marketing. We give users the option to some parts of our Service free of charge. This free Service is made possible by the fact that some users upgrade to one of our paid services. If you register for our Service, we will, from time to time, send you information about upgrades when permissible. Users who receive these market materials can opt out at any time. If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails.
No PI collected for the Services is Sold or Shared as those terms are defined under the California Consumer Protection Act.
Information Security and Accuracy
Data is secure throughout the system including encryption when in transit with TLS (1.2+) and at rest (AES 256 level encryption). Almaden employs commercially reasonable and industry standard data protection measures, including encryption, role-based access control management, and network monitoring and defense.
Retention Period
User Information will be retained for as long as a User ID is registered with the Services. If you choose to access, update or delete your User ID (see section “Controlling Your Personal Information” below), your PI will be provided, corrected or removed from the Services after all security, legal and regulatory obligations (e.g., audit, accounting, benefits, etc.) have been met.
Genomic PI will be retained as long as Almaden is retained by the Customer or entity who engaged our Services, in addition to any legally required retention periods that may exist, particularly as may be required under HIPAA.
Sharing of Personal Information
Access to PI is limited to the Services, technical, or system administrators. Individuals with access to PI must strictly adhere to all applicable laws and all Almaden policies, practices, and guidelines regarding the protection of PI and confidential information, including any Users of our Services. Both Users and Almaden personnel are not permitted to transfer PI to anyone without a lawful, legitimate business need.
Controlling your Personal Information
Any request to exercise your rights to access, update, correct, remove, or for a copy of the PI in the Services should be sent to the Customer or entity upon whose behalf you have accessed or otherwise made use of our Services. If a request through that Customer or entity is not possible, please reach out to Almaden at privacy@almaden.io, or send us a stamped, self-addressed communication at 1409 Botham Jean Blvd Suite 1007, Dallas, TX 75215, attention: Privacy Officer