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Privacy Policy

Effective date: January 28, 2019
Pink GenomiX, Inc. (“us”, “we” or “our”)
operates the www.pinkgenomix.com website (“Our Site”).

At Pink GenomiX, we appreciate the trust you have placed in us and are committed to ensure that your privacy and Personal Information is protected. This Privacy policy, informs you of our policies regarding the collection, use, storage, transfer and disclosure of information about you, including, but not limited to, personal information, optional self-reported information and genetic data, when you use our services.

By using one of Pink GenomiX’s DNA analysis solutions (“Service”) or by visiting Our Site, you consent to the collection and use of information in accordance with this policy. You understand that in order to use the Service, you may be required to provide us with information regarding your genotype which is typically generated through analysis of your saliva (“Genetic Data”) and self-reported health-related information including, but may not be limited to, disease history, personality traits, family information, ethnicity, and ancestry.

Children Privacy

The Service is not intended for anyone under the age of 18. As a result, we do not knowingly collect information online from children under the age of 18. If Pink GenomiX becomes aware that any person submitting information to the Service is under the age of 18, we will promptly take steps to delete any personal information collected and terminate the relevant account. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us at the contact information listed below.

Changes To Our Privacy Policy And Practices

This Privacy Policy was last updated on, and is effective as of, January 28, 2019. Pink GenomiX reserves the right, in its sole discretion, to modify, revise, delete and update this Privacy Policy from time to time. We will use reasonable endeavors to notify you of any modifications to the terms of this Privacy Policy. To inform you of any change, we may contact you by email and/or post the updated Privacy Policy on the applicable websites and indicate at the top of the Privacy Policy when it was updated. If you do not agree with the modifications, revisions, deletions or updates, your exclusive remedy is to cease using the Service. By continuing to use the Service after those changes are made, you shall be deemed to have accepted and agreed to the changes.

Collection And Use of Information

We may collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Registration Information

During the registration and creation of an account, the information provided will be collected. Such information includes but is not limited to name, email address, country, zip code, payment information, billing and shipping address.

Optional self-reported Information

This may include, but is not limited to information provided while filling in surveys about health information, ethnicity, family history or other information that you choose to share with us.

User content

User content constitute raw data information uploaded to our server, testimonials and reviews.

Information related to our genetic testing solutions

1. In order to generate reports, when a kit is purchased, Pink GenomiX collects information regarding your genotype through analysis of your saliva. To protect your privacy, your information is de-identified and processed anonymously throughout Pink GenomiX analyses.

2. For certain solutions, Pink GenomiX collects raw data files from customers for generating reports. These raw data files are generated by ancestry genetic testing companies other than Pink GenomiX. It contains the genetic information of the person typically in the form of quaternary figures A, T, G and C, their chromosome location and a standard alphanumeric identifier called the rsID.

Social Media

Our Site contains Social Media sharing buttons to Facebook, Instagram and Twitter. This feature may collect information related to IP, page visits and may incorporate the use of cookies to ensure that the features function properly.

Web Tracking information

1. Pink GenomiX uses cookies to help enhance user experience, provide security, collect demographic information and monitor marketing programs. By using Our Site, you authorize the site’s use of cookies by us or our service providers.

2. Information obtained by the use of cookies may be used in third party analytics tools like Google Analytics to generate reports and to track user behavior across devices and sessions. Such reports will not contain or be merged with any personal information. Marketing analysis using these reports will be based on aggregate information and not at the individual level. Learn more about how Google collects and uses data here by visiting their website page. To opt out of Google Analytics Advertising Features please use Google Ad Settings.

3. Pink GenomiX is actively invested in product development and introducing new applications and features. This may result in the collection of new information from different channels. As and when the need arises, the Privacy policy will be updated.

How we use your information

By signing up for Our Service or by registering an account on Our Site, the user consents to allow Pink GenomiX to communicate information to them. This information may be service or marketing related.

1. Service-related communication involves emails regarding data uploads and report delivery or any other such communications that are required for Pink GenomiX to fulfill service requirements.

2. Marketing communications includes but is not restricted to product upgrades, new product information and testimonial requests. The user may at any time choose to opt out of receiving such communications by clicking on unsubscribe at the bottom of the email or by emailing a request to [email protected]; this will not stop us from sending emails about your account or transactions with us or other information required for your use of the Service.

Research

Information that is used to conduct research projects will only be used after obtaining informed consent from the participant. Pink GenomiX will solicit customer feedback to optimize their services. Similar to marketing campaigns, users can at any time opt out of receiving such emails by unsubscribing or emailing a request to [email protected] Information shared with third parties.

1. By signing up for the Pink GenomiX’s Service you consent to the use of tools related to customer support, data storage and marketing. These tools are essential to be able to deliver customer support and for product requirements.

2. Access to data, be it registration information, genetic and self-reported information, automated information or data of any other kind will be shared with
regulatory authorities if Pink GenomiX is bound to comply with the requirements of the law of the land.

3. We may share de-identified data with vendors, service providers, and other third parties that perform services on our behalf. Our service providers act on Pink GenomiX behalf. While we implement procedures and maintain contractual terms with each service provider to protect the confidentiality and security of your information, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.

Your DNA, your choice

1. You may request deletion of your Pink GenomiX account, raw data and/or personal information from our server by sending an email request to
[email protected] Once you submit your request, we will promptly delete your account and/or all requested content. Once you confirm your request to delete your data, this process cannot be cancelled, undone, withdrawn, or reversed.

2. You may access, correct or update any and all details of your Personal Information that we hold about you by written request.

3. You have the right to change your mind about consenting to the use, disclosure and transfer of your Personal Information in accordance with this Privacy Policy by contacting us at [email protected] If you withdraw your consent for Pink GenomiX to process your Personal Information in accordance with this Privacy Policy, Pink GenomiX may not be able to provide you with all of parts of the Service.

HOW WE HOLD AND PROTECT YOUR INFORMATION

1. We take seriously the trust you have placed in us with your information. To protect against unauthorized destruction, loss, alteration, access, disclosure, or use (collectively, “Unauthorized Processing”), we maintain physical, technical, and administrative measures to prevent information security incidents in order to maintain the confidentiality, integrity and availability of information. All connections to Our Site are encrypted using Secure Socket Layer (SSL) technology and internal systems protected with anti-virus software.

2. Once we have received your Personal Information, we will use various procedures and security features (such as encrypting the Personal Information) to try to prevent unauthorized processing. Only authorized personnel of Pink GenomiX and contracted third parties have access to Information that is necessary for them to perform their jobs or services.

3. Unfortunately, despite these efforts, we cannot ensure or warrant the security of any information you provide to us. In addition, we are not responsible for the security of information you transmit to the Service over networks that we do not control, including the Internet and wireless networks. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted by a third party to us. As a result, we will not be liable for any loss or damage arising from any Unauthorized Processing of your information.

4. Protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Service. You should not disclose your authentication information to any third-party and should immediately notify us of any unauthorized use of your password. We cannot secure Personal Information that you release on your own or that you request us to release.

INTERNATIONAL TRANSFERS OF DATA

1. Pink GenomiX may transfer and/or store the Personal Information collected from you to third parties located in Canada or the United States of America or other jurisdictions in connection with the purposes set out in this Privacy Policy.

2. By submitting your Personal Information, you consent to the transfer, storage and/or processing of your Personal Information outside the jurisdiction in which the information was originally collected. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. Where we have engaged international third parties to perform services in relation to the Service, we will use contractual or other means to ensure such third parties offer a comparable level of protection in respect of the Personal Information. However, Applicable Laws in some jurisdictions may not provide the same level of protection for your Personal Information as does your home jurisdiction.

3. If you are visiting from the European Economic Area (“EEA”) or other regions with laws governing data collection and use, please note that we make Our Site and Service available to users across the world, and similarly, make use of service providers in jurisdictions outside the EEA. Please note that we may transfer your information to recipients in countries other than the country in which the

information was originally collected, including countries in North America. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy. By providing your information and/or using the Service you consent to any transfer and processing in accordance with this Privacy Policy.

HOW TO CONTACT US

If you have any questions, comments or concerns about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact us at [email protected] Our customer care representative will get back to you within 24-48 hours.