Privacy Policy

 Privacy Highlights

 

These “privacy highlights” provide an overview of some core components of our data handling practices. Please be sure to read our full privacy statement.

 

  1. We collect information when you register an account, self-report information through surveys, forms, features or applications, use our Services, upload your own content to our Services, use social media connections and features, refer your contacts to us, share information through various interactions with us and our partners, and via cookies and similar tracking technologies (see our Cookie Policy).
  2. We use information in general (i) to provide, analyze and improve our Services, (ii) as we reasonably believe is permitted by laws and regulations, including for marketing and advertising purposes, (iii) to protect the security and safety of our company, employees, customers as we reasonably believe permitted by laws and regulations, (iv) to comply with laws and regulations we are subject to, and (v) when you consent, for research purposes, the results of which could be used to develop therapeutics.

 

CONSENT TO THE USE OF SENSITIVE INFORMATION

 

By agreeing to our Privacy Statement and Terms of Service, you consent to sensitive information, such as information about your health, Genetic Information, and Self-Reported Information such as racial and ethnic origin and sexual orientation (where you provide it) being used by us to:

 

  1. analyze and provide you with our Services;
  2. analyze and provide you with information about the bacteria present in the provided stool sample;
  3. determine whether you would be suitable to take part in surveys, polls or questionnaires that we are conducting; and
  4. monitor and improve existing products or services that we offer or develop new products and services

We will not use your sensitive information without your consent unless: (i) the information has been anonymized or aggregated so that you cannot reasonably be identified as an individual; or (ii) a legal obligation requires us to use it in some way e.g. a court order requires us to disclose the information.

 

CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION

 

  1. By agreeing to our Privacy Statement and Terms of Service, you consent to the storing and processing of your personal information, including sensitive information, in the USA and countries outside of the country you live in. We use a range of measures to safeguard information but these countries may have laws that are different from those of your country of residence. You also consent to your personal information, including sensitive information, being transferred in the event of a business transition such as a merger, acquisition by another company, or other transaction or proceeding. In such a case, your information would be used as set out in any pre-existing Privacy Statement.
  2. We will not sell, lease, or rent your individual-level information (i.e., information about a single individual’s bacterial profile) to any third party or to a third party for research purposes without your explicit consent.
  3. We give you the ability to share information with other individuals through features like comparing with friends and comparing with people who share certain factors (i.e. vegetarians, or those struggling with weigh lost, etc). You will always need to take a positive action to share your information, for example, Sharing is subject to an opt-in requirement before we share your information with other users.
  4. You may independently decide to disclose your information to friends and/or family members, doctors, health care professionals, or other individuals outside our Services, including through third party services such as social networks and third-party apps always review the privacy policies of third-party apps and services before sharing your information.
  5. We may share anonymized and aggregate information with third parties; anonymized and aggregate information is any information that has been stripped of your name and contact information and aggregated with information of others or anonymized so that you cannot reasonably be identified as an individual.
  6. We will use your information and share it with third parties for scientific research purposes only if you sign this Consent Document. Note that we will disclose your individual-level information only if we obtain additional explicit consent from you.
  7. There may be some consequences of using uBioDiscovery Services that you haven’t thought of, you should read our guide of the surprising things you may find out from using the service before submitting your stool sample and personal information.
  8. If you have any questions about our privacy practices, please email us at contact@ubiodiscovery.com

 


 

Full Privacy Statement

 

This privacy statement applies to www.ubiodiscovery.com owned and operated by uBioDiscovery, Inc. Our Privacy Statement is designed to help you better understand how we collect, use, store, process, and transfer your information when operating our website, mobile apps, products, software and other services (collectively “Service” or “Services”).

 

  1. Key Definitions

 

  1. Aggregate Information: information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.
  2. Anonymized Information: information that has been stripped of your Registration Information (e.g., your name and contact information) and other identifying data such that you cannot reasonably be identified as an individual.
  3. Individual-level Information: information about a single individual’s microbiome as a result of our analysis, or any information disclosed by the customer in a questionnaire/survey, but which is not necessarily tied to Registration Information.
  4. Personal Information: information that can be used to identify you, either alone or in combination with other information. uBioDiscovery collects and stores the following types of Personal Information:
    1. Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, user ID and password, and payment information).
    2. Gut Microbiome Information: information regarding the bacteria present in your stool sample (e.g. which bacteria are present and in what proportions), generated through processing of your stool sample by uBioDiscovery or by its contractors, successors, or assignees; or otherwise processed by and/or contributed to uBioDiscovery.
    3. Self-Reported Information: all information about yourself, including your disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your uBioDiscovery account.
    4. Sensitive Information: information about your health, medication, information about your bacteria, and certain self-reported Information such as racial and ethnic origin and sexual orientation.
    5. User Content: all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials – other than Genetic Information and Self-Reported Information-generated by users of uBioDiscovery Services and transmitted, whether publicly or privately, to or through uBioDiscovery.
    6. Web Behavior Information: information on how you use the uBioDiscovery (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology.

 

  1. Service or Services: uBioDiscovery’s products, software, services, and website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by the user, regardless if the use is in connection with an account or not.

 

  1. Principles

 

The following are our core privacy principles:

 

  1. We collect and handle information (i) to provide, analyze and improve our Services, (ii) as we reasonably believe is permitted by laws and regulations, including for marketing and advertising purposes, (iii) to protect the security and safety of our company, employees, customers, (iv) to comply with laws and regulations we are subject to, and (v) when you consent, for research purposes, the results of which could be used to develop therapeutics.
  2. We will not sell, lease, or rent your individual-level information (i.e., information about a single individual’s bacterial profile, disclosed diseases or other customer-provided or learned information) to any third party or to a third party for research purposes without your explicit consent.
  3. We understand and respect the sensitive nature of the information you may provide to us, including information about your diet, lifestyle choices, medication use, diseases, racial and ethnic origin, etc. To that end, we strive to be transparent in our collection, use and disclosure of this information and to ask for your explicit consent to share such sensitive information with third parties. We are committed to providing a secure and safe environment for our Services.

 

Please review this Privacy Statement and our Terms of Service. By using our Services, you agree to all of the policies and procedures described in the foregoing documents. uBioDiscovery, Inc. is headquartered at Toronto, Ontario, Canada, and is referred to herein as uBioDiscovery (or “we,” “us,” “our”) and includes all of our commonly owned companies.

 

  1. What information we collect

 

  1. Information you provide directly to us:

 

  1. Registration Information. When you register an account with us or purchase our Services, we collect personal information, such as your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information such as your email and phone number.
  2. Self-Reported Information. You have the option to provide us with additional information about yourself through surveys, forms, features or applications. For example, you may provide us with information about yourself (e.g., weight, dietary restrictions), ethnicity, disease conditions (e.g. obesity, Irritable Bowel Disease) and other health-related information (e.g. medication use, exercise frequency etc.).
  • User Content. Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission (“User Content”). For example, User Content includes any post or message you place on uBioDiscovery’s community forums.
  1. Blogs. Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request that we remove or anonymize your personal information from our blog or community forum, contact us at contact@ubiodiscovery.com. Please note that whenever you post something publicly, it may sometimes be impossible to remove the information, for example, if someone has taken a screenshot of your posting. Please exercise caution before choosing to share personal information publicly on our blogs, community forums or in any other posting. Note also that you may be required to register with a third party application to post a comment. To learn how the third party application uses your information, please review their privacy statement.
  2. Social Media Features and Widgets. Our Web site includes Social Media Features, such as the Facebook Like or Share button and Widgets, and the LinkedIn Open ID application (“Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third party social media services to provide us information about you, including your name, email address, and other contact information. For example, if you use LinkedIn to sign in to our career portal, LinkedIn may import personal information from your LinkedIn profile in order to populate your job application. The data we receive is dependent upon your privacy settings with the social network. Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing it. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Service.

 

  1. Sharing. When you choose to share results information with another person, we will ask for that person’s email address. We will use the email address solely, as applicable, to make the referral or to share your results information, and we will let your contact know that you requested the communication. By choosing to share information with another person, you confirm that the person has given you consent for uBioDiscovery to communicate (e.g., via email) with him or her. The person you referred may contact us at contact@ubiodiscovery.com to request that we remove this information from our database. We do not control third-party site’s information practices, so please review their privacy policies and your settings on those sites carefully.
  • Gifts. If you provide us personal information about others, or if others give us your information for purposes of ordering the Service as a gift, we will only use that information for the specific reason for which it was provided to us. Once a gift recipient registers for his or her Services and agrees to our Privacy Statement, our Terms of Service, and if applicable, Consent Document, his or her information will be used consistent with this Privacy Statement and those agreements, and we will not share any of the gift recipient’s personal information with the user who purchased the gift.
  • Customer service. When you contact our Customer Care center or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Service, Privacy Statement or applicable laws or regulations; and analyze and improve our Services.

 

  1. Information related to our microbiome testing services

 

  1. Stool sample and bio-banking. To use our genetic testing services, you must purchase, or receive as a gift, as uBioDiscovery SUPERBIOME® testing kit, register an online account, and ship your stool sample to our laboratory. Once received, your stool sample will be identified by its unique code, along with your gender and your date of birth. The barcode label identifies you to us but not to our third-party laboratory. Your unidentified stool samples and DNA will be stored (called “bio-banking”) after the laboratory completes its work.

 

  1. Microbiome Information. Microbiome Information refers to the bacteria that was identified in your stool sample after Next General Sequencing and analysis of the data output. Microbiome Information includes the uBioDiscovery Results information reported to you as part of our Services, and may be used for other purposes, as outlined in Section 4 below.

 

  1. Information collected through tracking technology (e.g. from cookies and similar technologies)

 

Web Behavior Information. We and our third party partners use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to help us recognize you, customize and improve your experience, provide security, analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service), gather demographic information about our user base, to offer our products and services to you, to monitor the success of marketing programs, and to serve targeted advertising on our site and on other sites around the Internet. We and our third party partners do not use your sensitive information, such as Microbiome Information and Self-Reported Information, for targeted advertising. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. For more information, including the types of cookies found on uBioDiscovery, please read our Cookie Policy.

 

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you, such as your user profile ID or order number. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.

 

When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.

 

Because uBioDiscovery relies on third party ad networks who may track you across websites over time for advertising purposes, we are not able to respond to your selection of the “Do Not Track” option provided by your browser. We cannot advise on whether your selection of “Do Not Track” option will have any effect on the collection of cookie information by the third parties who collect such cookie information on our site. Please see Section 4.d.ii, below, to learn more about our third party advertising partners, and visit our Cookie Policy to learn more about tracking cookies.

 

Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use Flash Cookies (Local Shared Objects) to collect and store information. To learn how to manage privacy and storage settings for Flash cookies click here.

 

  1. Other Types of Information.

 

We are always working to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our privacy statement, as needed.

 

  1. How we use and share information

 

uBioDiscovery will use and share your personal information with third parties only in the ways that are described in this privacy statement.

 

Using information to provide, analyze and improve our Services

We use the information described above in Section 3 to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with other commitments in this privacy statement, to:

 

  1. open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., sharing);
  2. host our website, run our mobile application(s), authenticate your visits, provide custom, personalized content and information, and track your usage of our Services;
  • conduct analytics to improve and enhance our Services;
  1. offer new products or services to you, including through emails, promotions or contests;
  2. implement online marketing campaigns and targeted advertising, including by utilizing third party ads (subject to your cookie settings and preferences), and to measure the effectiveness of our marketing and targeted advertising;
  3. conduct surveys or polls, and obtain testimonials;
  • process and deliver your genetic testing results;
  • perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities.
  1. You may be able to opt-in, opt-out or otherwise adjust your preferences of having your information used for certain of these activities.

 

Using information with your consent

 

By providing consent you are choosing to participate in uBioDiscovery Research. “uBioDiscovery Research” refers to research aimed at publication in peer-reviewed journals and other research funded by the federal government (such as Health Canada) conducted by uBioDiscovery. uBioDiscovery Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or pharmaceutical companies.  uBioDiscovery Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. uBioDiscovery uses your aggregate or individual-level Microbiome Information, but not your name, and Self-Reported Information as specified in the Consent Document.

 

  1. Consent process for research. Your Microbiome and Self-Reported Information may be used for uBioDiscovery Research only if you have consented to this use by accepting this Consent Document. If you have accepted this Consent Document:
    1. uBioDiscovery may use unidentified- individual-level Microbiome Information and Self-Reported Information internally at uBioDiscovery for Research purposes. In addition, we may allow select third party research contractors to access your unidentified-individual level Microbiome and/or Self-Reported Information onsite at uBioDiscovery’s offices for the purpose of conducting scientific research, provided that all such research contractors will be supervised by uBioDiscovery and subject to uBioDiscovery’s access rules and guidelines.
    2. When your Microbiome Information and/or Self-Reported Information is being used for research purposes, it will not be linked to your Registration Information.

 

  1. Withdrawing your Consent.

 

You may withdraw your consent to participate in Research at any time by changing your consent status by sending a request to the contact@ubiodiscovery.com. uBioDiscovery will not include your Microbiome Information or Self-Reported Information in new research occurring after 30 days from the receipt of your request. Any research involving your data that has already been performed or published prior to our receipt of your request will not be reversed, undone, or withdrawn. If you withdraw your consent for research your Microbiome Information and Self-Reported Information may still be used by us and shared with our third-party service providers to provide and improve our Services (as described in Section 4.a), and shared as Aggregate Information that does not identify you as an individual (as described in Section 4.d).

 

  • What happens if you do NOT consent to uBioDiscovery Research?

 

If you do not complete this Consent Document, your information samples will not be processed.

 

Recruiting for external research and Information we share with third-parties

 

Academic institutions, healthcare organizations, and other groups are always conducting interesting new research projects. Your unidentified data will aid this research. While we do not share individual-level Microbiome Information or Self-Reported Information with third parties we share the information described above in Section 3 with our service providers, as necessary to provide their services to us. Service providers are third parties (other companies or individuals) that help us to provide, analyze and improve our Services. For example, we work with third-party laboratories and contractors to process and analyze your stool sample for purposes of generating your Microbiome Information.

 

NOTE: Our service providers act on uBioDiscovery ‘s behalf. While we implement procedures and contractual terms 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.

 

Aggregate information. We may share aggregate information with third parties, which is any information that has been stripped of your Registration Information (e.g., your name and contact information) and aggregated with information of others so that you cannot reasonably be identified as an individual (“Aggregate Information”). This Aggregate Information is different from “individual-level” information. Individual-level Microbiome Information or Self-Reported Information consists of data about a single individual’s bacteria present in the given stool sample, diseases or other self-declared disease, medication use, diet or lifestyle information. For example, Aggregate Information may include a statement that “30% of our female users share a particular bacteria in high quantities compared to only 5% of male users,” without providing any data or testing results specific to any individual user. We may provide such Aggregate Information in commercial arrangements with our business partners. In contrast, individual-level Microbiome Information could reveal whether a specific user has a particular bacteria in their sample, or all of the Microbiome Information about that user.

 

Information we share with commonly owned entities. We may share some or all of your information with other companies under common ownership or control of uBioDiscovery which may include our subsidiaries, our corporate parent, or any other subsidiaries owned by our corporate parent in order to provide you better service and improve user experience. We may provide additional notice and ask for your consent if we wish to share your information with our commonly owned entities in a materially different way than discussed in this Privacy Statement.

 

Disclosures required by law

Under certain circumstances your information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. uBioDiscovery will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that uBioDiscovery may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the uBioDiscovery Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of uBioDiscovery, its employees, its users, its clients, and the public.

 

  1. Your choices

 

  1. Access to your account

 

If your Registration Information changes, you may access, correct or update most of it from your Account Settings page. You may also modify and delete certain of your information. You may be able to correct or reset Self-Reported Information entered into a survey, form, or feature from your account on the surveys page. Please note that you may not be able to delete User Content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third parties, though we can work with you to prohibit your data from being shared with third parties in the future. We will respond to your request to access within 30 days.

 

  1. Marketing communications

 

By registering for an account, you are agreeing that we may send you promotional emails about our Services. You can opt-out of receiving certain messages or notifications from us by visiting your Account page (go to Account, Settings, Notifications) or by contacting our Privacy Administrator at contact@ubiodiscovery.com. You can also click the “unsubscribe” button at the bottom of promotional email communications. Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

 

For more information about our online advertising, please also refer to Section 4.d.ii above under the heading “Targeted Advertising Service Providers”, and also refer to our Cookie Policy.

 

  1. Information you choose to share with others

 

uBioDiscovery gives you the ability to share information with other individuals who have uBioDiscovery accounts. You may decide to disclose your personal information to friends and/or family members, doctors or other health care professionals, and/or other individuals outside of our Services, including through third-party services such as social networks and third-party apps. These third parties may use your personal information differently than we do under this Privacy Statement. Please make such choices carefully and review the privacy policies of all other third parties involved in the transaction. For example, if you have enabled a uBioDiscovery sharing feature with another person who downloads a third-party app, your information may also be obtained by that third-party app developer and, potentially, by other users of that third-party app.

 

In general, personal information, once shared or disclosed, can be difficult to contain or retrieve. uBioDiscovery will have no responsibility or liability for any consequences that may result because you have released or shared personal information with others. Likewise, if you are reading this because you have access to the personal information of an uBioDiscovery customer through a multi-profile account, we urge you to recognize your responsibility to protect the privacy of each person within that account. It is incumbent upon all users to share personal information and account access only with people they know and trust. Users with multi-profile accounts (e.g., where family member accounts are linked) should use caution in setting profile-level privacy settings.

 

  1. Account closure

 

If you no longer wish to participate in our Services or no longer wish to have your personal information be used, you may close your account by sending a request to Customer Care (contact@ubiodiscovery.com). When closing an account, we remove all Information within your account (or profile) within thirty (30) days of our receipt of your request. As stated in any applicable Consent Document, however, Microbiome Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in uBioDiscovery Research cannot be removed from ongoing or completed studies that use the information. Our contracted genotyping laboratory may also retain your Microbiome Information as required by local law and we may retain backup copies for a limited period of time pursuant to our data protection policies. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) as long as your account is active or as needed to provide you services, as well as for accounting, audit and compliance purposes.

 

  1. Important Information

 

Security measures

 

uBioDiscovery takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, uBioDiscovery uses a range of physical, technical, and administrative measures to safeguard your Personal Information. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.

 

Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify uBioDiscovery of any unauthorized use of your password. uBioDiscovery cannot secure Personal Information that you release on your own or that you request us to release.

 

Your information collected through the Service may be stored and processed in the United States or any other country in which uBioDiscovery or its subsidiaries, affiliates or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

 

Business transactions

 

In the event that uBioDiscovery goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

 

Linked websites

 

uBioDiscovery provides links to third-party websites operated by organizations not affiliated with uBioDiscovery. uBioDiscovery does not disclose your information to organizations operating such linked third-party websites. uBioDiscovery does not review or endorse, and is not responsible for, the privacy practices of these organizations. We encourage you to read the privacy statements of each and every website that you visit. This Privacy Statement applies solely to information collected by uBioDiscovery.

 

Children’s privacy

 

uBioDiscovery is committed to protecting the privacy of children as well as adults. Neither uBioDiscovery nor any of its Services are designed for, intended to attract, or directed toward children under the age of 13. A parent or guardian, however, may collect a stool sample from, create an account for, and provide information related to, his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to uBioDiscovery about his or her child is kept secure and that the information submitted is accurate.

 

Changes to this Privacy Statement

 

Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our customers’ account login pages for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes prior to the change becoming effective.

 

  1. Contact Information

 

If you have questions about this Privacy Statement, please email uBioDiscovery ‘s Privacy Administrator at contact@ubiodiscovery.com

 

*This Privacy Statement was last updated on April 3, 2017.