Introduction

Mindera Health (“we”, “us” or “our”) respects your privacy and we are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit our Site or use our Services (as provided under our Terms of Service) and our practices for collecting, using, maintaining, protecting and disclosing that information.

Please read this Privacy Policy carefully to understand how we collect, use, protect or otherwise handle your information. If you do not agree with our policies and practices, you may choose not to use the Services. By accessing and using the Site or our Services, you accept and agree to this Privacy Policy.

Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in our other policies (e.g., our Terms of Service and Consent for Services).

This Privacy Policy applies to information we collect:

• On our Site;
• In email and other electronic messages between you and us;
• From your healthcare practitioner; and
• From our laboratory partners.

Information We Collect

We collect several types of information from and about users of our Site and Services. When creating an Account or requesting our Services, you may be asked to provide Personal Information (including but not limited to your name, mailing address, email address, family history, telephone number, and insurance information). We may also collect information from you and/or your healthcare practitioner to facilitate the provision of our Services. If you submit a biological sample for testing, we will also receive your test results from our laboratory partners. We may collect records and copies of your correspondence (including email addresses) if you contact us regarding our Site or Services. We will also collect information about the details of any transactions you carry out through our Site.

How We Use Your Information

In general, we use the information that we collect to provide the Services you request, to help improve our services and client experiences, and to help advance genetic research and science. More specifically, we may use the information we collect from you in the following ways:

• To present our Site and its contents to you.
• To create and manage your Account.
• To provide you with information or Services that you request from us.
• To send you notices and information about your Account.
• To respond to your customer service requests or correspondence.
• To notify you about changes to our Site, our policies, or any Services we offer or provide.
• To fulfill our obligations and enforce our rights under our Terms of Service and other agreements, including for billing and collection.
• In any other way we may describe when you provide the information.

Your information may be used to help us improve our Services and develop new tests and services. For example, your information and sample may be used to support internal quality control and validation studies, research and development, data analysis, and a research database.

Disclosure of Your Information

We do not sell or otherwise share your Personal Information, except as described in this Privacy Policy and any applicable Consent for Services. We may disclose your Personal Information and test results to your healthcare practitioners. We may share Personal Information with third parties who perform services on our behalf (e.g., our laboratory partner, third parties that assist with billing and collection efforts). We limit the information we share with these service providers to that which is minimally necessary for them to perform their services for us, and we require them to agree to maintain the confidentiality and security of such information. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.

We may disclose information about you (i) if we are required to do so by law or legal process (such as a judicial proceeding, court order, or government or regulatory inquiry), (ii) to law enforcement authorities or other government officials based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company, our customers or others. In addition we may disclose your Personal Information to enforce our Terms of Service and other agreements. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

We may disclose aggregated, de-identified information that does not identify any specific individual (e.g., aggregated trends about the use of our Services) without restriction.

With your consent, we may include your anonymized genetic information and results in our research database in order to support further research in genetics. With your consent, we may also use your de-identified sample and genetic information in our research efforts. We may engage in research with public, private and/or non-profit third parties to study a specific group or population, to identify potential areas or targets for genetic testing development, or to validate or improve existing technologies or processes. You can opt out of our research database and/or third party research by updating your Account settings or by contacting us directly. If you notify us that you wish to opt out of the research database and/or third party research, please note that we may not be able to recall anonymized or de-identified data that has already been released to the database or third parties. We will promptly update your information following an opt out request to exclude your information from any subsequent research related disclosures.

How We Protect Your Information

We have implemented a variety of measures designed to secure your information from accidental loss and from unauthorized access, use, alteration and disclosure.

Your information is stored behind secured networks and is only accessible to a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. We use regular Malware Scanning and implement a variety of other security measures when a user enters, submits, or accesses their information to maintain the safety of your Personal Information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of information transmitted to our Site. Any transmission of information to us is at your own risk. We are not responsible for the circumvention or breach of any of our physical, technical, or managerial safeguards. In the event of a data breach, we intend to comply with all applicable federal and state reporting requirements. You agree that we are not liable for the unauthorized release of your information, unless such release was the result of gross negligence or willful misconduct on the part of Mindera Health.

You may send us an email at support@minderahealth.com to request access to, or to correct or delete any Personal Information that you have provided to us. 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. In addition, we may be required to maintain certain information to comply with legal and regulatory requirements. If we delete your information from our active databases, some or all of your information may remain archived in back-ups for compliance with legal, regulatory, and other requirements. In addition, information that has already been de-identified, anonymized, and/or aggregated may not be retrievable or traced back for destruction, deletion, or amendment.

Age and Geographic Restrictions

Our Services are only available to United States residents who are 18 years of age or older. If you are not a United States resident 18 years of age or older, you must not access or use the Site or our Services.

Notice of Changes to Our Privacy Policy

At our sole discretion, we may make changes to this Privacy Policy at any time. When changes are made, we will post an updated Privacy Policy on our Site. If we make material changes to how we treat our users’ Personal Information, we will post a notice on the Site home page. All changes are effective immediately upon posting; the date the Privacy Policy was last revised is identified at the top of the page.

Contact Information

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us at:

Mindera Health
1221 Liberty Way
Vista, CA 92081
858.810.6070
support@minderahealth.com