1. Information We May Collect
A. Personally Identifiable Information (PII)-- information that can identify an individual (e.g. first and last name, birth date, home address, phone numbers, etc.)
B. Personal Data-- information relating to a person when that person can be identified, directly or indirectly, in particular by reference to an identification number (e.g. social security number, bar code information,) or factors specific to a person’s physical, physiological, mental, economic, cultural or social identity.
C. Self-Reported information-- information you provide to us about yourself, including input and answers to surveys, forms, questionnaires, etc.
D. Protected Health Information (PHI)-- information regarding your medical history, test and laboratory results, mental health conditions, insurance information that can identify you individually.
E. User Content-- information you may voluntarily post provided by the features of our websites whether publicly or privately transmitted, such as profiles, posts, emails, feedback, experiences, notes, messages, photos, or videos.
F. Web Information-- information on how you use our website (e.g. domains, page views, browser types, etc.) or other online media owned by Psomagen, and are collected through log files, cookies, or web beacon technology.
2. Information We Automatically Collect
A. Google Analytics
(i) Kean Health uses Google Analytics to capture and analyze visits and traffic to the Site. Google Analytics collects information about your visit to the Site, any referral website, the type of web browser and operating system you are currently using, and your network location and IP address. The information collected by Google Analytics is anonymous and aggregated. We reserve the right to use this information for any lawful business purpose, including selling or sharing the aggregated and anonymized data collected by Google Analytics. We may also use this aggregated and anonymized data to analyze trends or seek third-party advertisers.
(i) Cookies are small files that are sent to and stored in your computer by the websites you visit. Cookies are stored in your browser’s file directory. Cookies may be stored only for the time you are in a given site or they may remain stored in your browser for a defined period of time beyond your current session. Cookies work in combination with content within the website itself, to capture and remember information. To learn more about these technologies and how they work, please see www.allaboutcookies.org.
(iii) The cookies we use in connection with our Site and/or Services may include:
1) Session cookies. Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content.
2) Persistent cookies. Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Site and/or Services.
3) Third-party cookies. We may permit certain third-parties to place cookies through our Site to provide us with better insights into the use of our Site and/or Services and user demographics and to advertise our Site to you. These third-parties may collect information about your online activities over time and across different websites when you access or use our Site and/or Services. For example, we utilize Google Analytics to analyze usage patterns for our Site. Google Analytics generates a cookie to capture information about your use of our Site, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Site, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third-parties.
4) You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can review the options available to manage cookies in your browser. One option is to disable or turn- off, all cookies. If you turn cookies off, you may not be able to browse the Site. If you disable certain kinds of cookies, some aspects of our Site may not function properly or as well.
3. How We Use Your Information
A. Provide you with our Services
B. For Research and Research Studies
(i) When you use our Services, Kean Health may use your Personal Information and other data individually or in a limited data set (e.g. de-identified, pseudonymized, or aggregate forms) for ongoing research conducted by Kean Health that may help us better understand the microbiome and improve our genomic sequencing methods.
C. For Studies
(i) There are times where Kean Health may be involved in certain study research in collaboration with third parties such as non-profits, academic institutions, healthcare organizations, or commercial research partners with the intent to study specific disease conditions or a segment of the population.
(ii) If you have used our Services to participate in a study, your participation in that study is governed by an independent review board and your informed consent by way of accepting and participating in the study in the Consent Form contains specific details on the study, collaborator, and the type of information Kean Health would collect and share. If you believe you have used our services to participate in a study please refer to the informed consent form you accepted in participating in that specific study.
D. Provide Customer Service and Support
(i) When you contact Kean Health Customer Support we may use and request additional information as necessary to verify your identity, answer your questions, resolve disputes, and/or investigate problems or complaints.
E. Surveys and Testimonials
(i) We love to hear from you and encourage feedback on your experience with us. From time to time we may send you surveys or request a testimonial to see how we can improve our Services. All personal information you share with us about your experience is voluntary.
F. Marketing Communications
(i) When you create an account or use our Service, you agree to receive Service-related email communications according to our Terms.
(ii) If you do not wish to receive these electronic communications you may unsubscribe to these emails at any time.
1) You can find the unsubscribe instructions at the bottom of our emails.
(iii) We may also use your Personal Information to compile statistics on population usage and other data regarding the use of our Services and for other types of marketing and communication purposes, without asking for your explicit consent. We will never use your sensitive information for marketing communication purposes.
G. As Required By Law
(i)You acknowledge and agree that Kean Health is free to preserve and disclose any and all Personal Information to law enforcement agencies or other regulatory agencies that oversee manufacturing and logistics services, if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (i) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry); (ii) obligations that Kean Health may owe pursuant to ethical, regulatory (such as Food and Drug Administration), and other professional rules, laws, and regulations; (iii) enforce Terms of Service; (iv) respond to claims that any content violates the rights of third parties; or (v) protect the rights, property, or personal safety of Kean Health, its employees, the general public, and you.
H. Third Parties
(i) We may also share Personal Information in de-identified, pseudonymized, or aggregate forms (without your personal details or aggregated with the information of others so that you cannot reasonably be identified as an individual) for 1) Research and Research Studies; 2) strategic initiatives with Research partners; and 3) for other purposes, to the extent necessary, and as permitted by law.
a) Business Operations
(i)To use our Services you are required to disclose Personal Information to our third party vendors or service providers (e.g. eCommerce third-party services). The protection of those disclosures are subject to the service agreements or privacy policies of the specific Kean Health partner or service provider. In addition, we employ strong terms on data security, protection, and confidentiality of information (including customer data) shared in our agreements with third party vendors or service providers.
b) Business Transactions (Acquisition, Mergers, etc.)
In the event that Kean Health goes through a business transaction resulting in a merger or acquisition by another company, your Personal Information may be among the assets transferred.
4. Your Genetic Data (not including de-identified, pseudonymized, or aggregate forms)
- 5. Your Account Information and Opting Out
- A. Account Termination
- 1)Email: email@example.com or
- 2) Mail: Psomagen, Inc.
- Attn: Kean Health Privacy
- 1330 Piccard Drive, Suite 103
- Rockville, MD 20850
- (i) If you no longer wish to participate in our Services, you may contact Customer Support by:
- (ii) Once we confirm your request to terminate your account this process cannot be withdrawn. When your account is deleted all associated Personal Information may be deleted and stored samples discarded.
- B. Marketing Communications
- (i) You may choose to “unsubscribe” from email marketing communications, or you can contact Customer Support at the email or mailing address listed above in Section 5(a) to be removed from email marketing lists. Please be aware that you are not able to opt-out of receiving communications about your Kean Health account or related transaction with our Services.
- C. Your Genetic Data
- You may withdraw your express consent for your genetic data (not including de-identified, pseudonymized, or aggregate forms) by contacting Customer Support at firstname.lastname@example.org.
- If you choose to, you may request Psomagen to delete your genetic data (not including de-identified, pseudonymized, or aggregate forms).
- 6. Security
- We understand the importance of information security and will take reasonable measures to protect the security and confidentiality of your information. Please understand that no measures can guarantee 100% security. You are responsible for the security of your log-on information. Please do not share your username or password with anyone. If you believe your log-on password has been compromised, please contact us immediately. If we receive instructions using your Kean Health account login information, we will consider that you have authorized the instructions. We reserve the right, in our sole discretion, to refuse to provide our Site and/or Services, terminate Kean Health accounts, and remove or edit content.
- 7. Retention of Personal Information Including Test Results
- By registering and receiving the Services provided by Kean Health, you consent to have Kean Health store your Personal Information and Test Results as long as it is necessary for you to access your information or for Kean Health to access the information for further research purposes in a manner consistent with Kean Health’s Privacy Statement and Terms of Service.
- 8. Links to Third Party Sites
- 9. Children’s Information
- The Site is not intended for children under the age of 13 years old. We do not knowingly collect information from children under the age of 13. If we discover that we have information from a child under the age of 13, we will delete it immediately. If you believe that a child under the age of 13 may have provided his or her information to us, please send us an email at email@example.com. You are not permitted to enter any information about a minor anywhere on the Site.
- 10. Cross Border Transfer of Data
- We are located in the United States. If you are not a resident of the United States, your country’s laws governing data collection and use may differ from those in the United States; in particular, the United States may not provide the same level of protection as those in your own country. By using the Site and/or Services or providing your personal information to Kean Health, you are transferring your information to the United States, and you consent to the transfer, retention, and processing of such data in the United States. If you do not agree with such transfer, retention, and processing in the United States, please do not use the Site and/or Services.
- 11. General Data Protection Regulation
- The General Data Protection Regulation 2016/679 (GDPR) is a regulation in European Union (EU) law on data protection and privacy in the European Union and the European Economic Area. It also addresses the transfer of personal data outside the EU and EEA areas. The GDPR applies to all organizations that process the Personal Information of EU residents through services offered to them, regardless of whether the organization is in the EU. Kean Health is committed to GDPR compliance through our use of the latest in information technology for data protection. Our Privacy Statement, Terms of Service, and consent forms all provide information meant to help you with our practices. If you have any questions, please contact Customer Support at firstname.lastname@example.org.
- 12. California Residents’ Privacy Rights
- If you live in California and have an established business relationship with us, you can request a list of the Personal Information we have shared with third-parties for their marketing purposes. We will also give you a list of the third- parties that have received your information. You can make a request one time each year.
- For more information on your rights pursuant to the California Consumer Privacy Act (CCPA) of 2018, visit the following link: CCPA
- To exercise your rights, you can e-mail us at email@example.com or write to:
Attn: Kean Health Privacy
1330 Piccard Drive, Suite 103
Rockville, MD 20850
Mention in your letter that you are making a “California Shine the Light” inquiry. We will respond within 30 days.
- 13. Nevada Residents’ Privacy Rights
- Nevada’s Senate Bill 220 (“SB 220”), which is signed into law, requires operators of Internet websites and online services to follow a consumer’s direction not to sell his or her personal data. Kean Health does not sell its customer’s Personal Information.
- 14. New York Residents’ Privacy Rights
- Pursuant to the New York Consolidated Laws, Civil Rights Article 7, Section 79-L “Confidentiality of records of genetic tests,” Kean Health and Psomagen comply with this state law when you consent to use our Services.
- 15. Do Not Track
- Some browsers have a “do not track” feature that allows you to tell websites that you do not want to have your online activities tracked. At this time, due to a lack of industry standards, we do not respond to browser “do not track” signals. To learn more visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific.
- 16. Changes to Privacy Statement
- 17. Contact Information
Attn: Kean Health Privacy
1330 Piccard Drive, Suite 103
Rockville, MD 20850