This Privacy Statement applies to all websites owned and operated by Codex Genetics Ltd. ("Codex"), including codexgenetics.com, and any other websites, pages, features, or content we own or operate, and to your use of the Codex mobile app and any related Services. Our Privacy Statement is designed to help you better understand how we collect, use, store, process, and transfer your information when using our Services.
Please carefully review this Privacy Statement and our Terms of Service. By using our Services, you acknowledge all of the policies and procedures described in the foregoing documents. If you do not agree with or you are not comfortable with any aspect of this Privacy Statement or our Terms of Service you should immediately discontinue use of our Services.
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
De-identified 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, also known as pseudonymized information.
Individual-level Information: information about a single individual's genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.
Personal Information: information that can be used to identify you, either alone or in combination with other information. Codex collects and stores the following types of Personal Information:
Registration Information: information you
provide about yourself when registering for and/or purchasing
our Services (e.g. name, email, address, password, and payment
Genetic Information: information regarding certain features of your genotype (the As, Ts, Cs, and Gs at particular locations in your genome), generated through processing of your saliva sample collected using one or more cheek swabs by Codex or by its contractors, successors, and assignees; or otherwise processed by and/or contributed to Codex.
Self-Reported Information: information you provide directly to us, 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 Codex account.
Sensitive Information: information about your health, Genetic Information, and certain Self-Reported Information such as racial and ethnic origin, sexual orientation, and political affiliation.
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 Codex Services and transmitted, whether publicly or privately, to or through Codex.
Web-Behavior Information: information on how you use Codex Services collected through log files, cookies, web beacons, and similar technologies, (e.g., browser type, domains, page views).
1. Information you provide directly to us
Registration Information. When you purchase our
Services or create a Codex account and register your kit, we
collect Personal Information, such as your name, date of birth,
billing and shipping address, payment information (e.g., credit
card) and contact information (e.g. email, phone number and
Self-Reported Information. You have the option to provide us with additional information about yourself through surveys, forms, features and applications. For example, you may provide us with information about your personal traits (e.g., eye color, height), ethnicity, disease conditions (e.g. Type 2 Diabetes), other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), and family history information (e.g. information similar to the foregoing about your family members). Before you disclose information about a family member, you should make sure you have permission from the family member to do so.
Social media features and widgets. Our Services include Social Media Features, such as the Facebook "Like" or "Share" button and widgets ("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. The information 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 statements of the third party companies providing them. 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.
Third party services (e.g., social media). If you use a third party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person's name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third party site. We do not control the third party site's information practices, so please review the third party’s privacy statement and your settings on the third party’s site carefully.
Referral information and sharing. When you refer a person to Codex or choose to share your Codex results with another person, we will ask for that person's email address. We will use their email address solely, as applicable, to make the referral or to communicate your sharing request to them, and we will let your contact know that you requested the communication. By participating in a referral program or by choosing to share information with another person, you confirm that the person has given you consent for Codex to communicate (e.g., via email) with him or her. The person you referred may contact us at [email protected] to request that we remove this information from our database.
Gifts. If you provide us with Personal Information about others, or if others give us your information, for the purpose 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, certain Consent Documents, his or her Personal Information will be used in manners consistent with this Privacy Statement, and will not be shared with the purchaser, unless they independently choose to share their own Personal Information through the Services with the purchaser.
Customer service. When you contact Customer Support 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.
2. Information related to our genetic testing services
Saliva sample. To use our genetic testing
services, you must purchase, or receive as a gift, a Codex
testing kit, create an online account and register your kit, and
ship your saliva sample to our owned or third-party processing
facility. The facility will process your DNA from your saliva
sample for analysis. Your saliva sample and DNA are destroyed as
part of providing the genetic testing services, and are
discarded after the facility completes its work, subject to the
facility’s legal and regulatory requirements.
Genetic Information. Your Genetic Information is generated when we analyze and process your saliva sample, or when you otherwise contribute or access your Genetic Information through our Services. Genetic Information includes the Codex results reported to you as part of our Services, and may be used for other purposes, as outlined in Section 3 below.
3. Web-Behavior Information collected through tracking
technology (e.g. from cookies and similar technologies)
1. help us recognize you when you use our Services;
2 customize and improve your experience;
3. provide security;
4. analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service);
5. gather demographic information about our user base;
6. offer our Services to you;
7. monitor the success of marketing programs; and
8serve targeted advertising on our site and on other sites around the Internet.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.
If you reject cookies, you may still use our site, but your
ability to use some features or areas of our site may be
We may receive reports based on the use of these technologies from third party service providers as de-identified, Individual-level Information or as Aggregate Information (as described in section 4.3). Unless we have your specific consent, we and our third party service providers do not use your Sensitive Information, such as Genetic Information and Self-Reported Information, for targeted advertising.
Google Analytics. Google Analytics is used to perform many of the tasks listed above. We use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions). We have enabled the following Google Analytics Advertising features: Remarketing, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and DoubleClick Campaign Manager integration. We do not merge information collected through any Google advertising product with individual-level information collected elsewhere by our Service. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.
4. Other Types of Information
We continuously work 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 and/or obtain your prior consent to new processing, as needed.
Codex will use and share your Personal Information with third parties only in the ways that are described in this Privacy Statement.
1. To provide you with Services and analyze and improve our
We use the information described above in Section 2 to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with this Privacy Statement to:
1. open your account, enable purchases and process payments,
communicate with you, and implement your requests (e.g.,
2. enable and enhance your use of our website and mobile application(s), including authenticating your visits, providing personalized content and information, and tracking your usage of our Services;
3. contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.);
4. enforce our Terms of Service and other agreements;
5. monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks; and
6. 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.
2. To process, analyze and deliver your genetic testing
As described above, to receive test results, you must create a Codex account, register your kit, and submit your saliva sample to our or our contracted processing facility, which processes and analyzes your sample to provide us with raw Genetic Information. Once we receive your raw Genetic Information from the facility, we further analyze it to provide you with our result reports. Codex continuously works to improve our Services based on our research and product development, and genetic associations identified in scientific literature. If you are eligible to receive additional reports or updates in the future, you may be notified of or may directly access these updates.
3. To allow you to share your Personal Information with
Codex gives you the ability to share information, including Personal Information, through the Services. You have the option to share directly with individuals with Codex accounts through (i) our Forums and (ii) other sharing features and tools. You may also have the ability to share information directly with individuals who have not participated in our Service via a unique, shareable URL or through a social media platform (such information is "User Content"). Some sharing features, including receiving sharing invitations, may require that you opt-out, however you will always be required to take a positive action, such as opting in, to share sensitive data.
4. To allow you to share your Personal Information for Codex
By consenting to use the Services, you consent to the use of your de-identified Personal Information for Codex Research purposes. You have the choice to complete an Individual Data Sharing Consent Document, in which case your identifiable Personal Information may be used in Codex Research in accordance with the terms of the Individual Data Sharing Consent Document. “Codex Research” means scientific research that Codex performs with the intent to publish and to test, improve and develop products and services.Codex 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. Codex Research may study a specific group or population, identify potential areas or targets for product 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. Codex Research uses Aggregate and/or Individual-level Genetic Information and Self-Reported Information as specified in the appropriate Consent Document(s), as explained in greater detail below.By consenting to use the Services, you agree that your De-identified Genetic and Self-Reported Information may be used for Codex Research, including by sharing it with select third-party research collaborators for Codex Research purposes:
i. Your Genetic Information and/or Self-Reported Information may
be used for research purposes, but it will be de-identified and
will not be linked to your Registration Information.
ii. Codex may use individual-level Genetic Information and Self-Reported Information internally at Codex for research purposes.
iii Codex may share summary statistics, which do not identify any particular individual or contain individual-level information, with our qualified research collaborators.
Withdrawing your Consent. You may withdraw your
consent to the use of your identifiable Personal Information for
Codex Research at any time by contacting
[email protected] It may take up to 30 days to withdraw
your information after you withdraw your consent. Any research
involving your data that has already been performed or published
prior to your withdrawal from Codex Research will not be
reversed, undone, or withdrawn. You may also discontinue your
participation in Codex Research by deleting your Codex account
(as described in section 5.4).
What happens if you do NOT consent to the use of your identifiable Personal Information for Codex Research? If you choose not to complete an Individual Data Sharing Consent Document or any additional agreement with Codex, your identifiable Personal Information will not be used for Codex Research other than for internal Codex purposes as described in this document. However, your de-identified Genetic Information and Self-Reported Information may still be used by us and shared with our third party service providers to as outlined in this Privacy Statement.
5. To recruit you for external research
We want to ensure interested participants are aware of additional opportunities to contribute to interesting, novel scientific research conducted by academic institutions, healthcare organizations, pharmaceutical companies, and other groups. From time to time we may inform you of third party research opportunities for which you may be eligible. However, we will not share Individual-level Genetic Information or Self-Reported Information with any third party without your consent. If you do not wish to receive these notifications, you can manage them by editing your preferences in your Account Settings.
6. To provide customer support
When you contact Customer Support, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one customer’s Personal Information to resolve another customer’s dispute or request. For example, if a customer reports behavior that violates our Terms of Service, we will separately process both customers’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another customer without your consent.
7. To provide you with marketing communications
By creating a Codex account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link or go to the “Preferences” section of your Account Settings to edit your email notification preferences. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
1. General service providers.
We share the information described above in Section 2 with our third party service providers, as necessary for them to provide their services to us and help us perform our contract with you. Service providers are third parties (other companies or individuals) that help us to provide, analyze and improve our Services. While Codex directly conducts the majority of data processing activities required to provide our Services to you, we engage some third party service providers to assist in supporting our Services, including in the following areas:
Order fulfillment and shipping. Our payment processor processes certain Registration Information, such as your billing address and credit card information, as necessary to enable you to purchase a Codex kit from the Codex online store. Our distribution centers ship your kit(s) to you, and in some cases help return your kit safely to our third party facility so your sample can be processed.
Genetic Testing. To use our genetic testing services, you must purchase, or receive as a gift, a Codex testing kit, and ship your saliva sample to our or our designated third party processing facility. Once delivered, receiving personnel at the facility remove and discard kit packaging, which in some cases may contain "sender information" (e.g., name, address), before testing personnel receive the samples for processing. Receiving personnel do not perform testing, and testing personnel handle biological samples that are only identified by a unique barcode. When the facility has completed their analysis, they securely send the resulting Genetic Information to us identified by your unique barcode.
our saliva sample and DNA are safely discarded after the facility completes its work, subject to the facility's legal and regulatory requirements. As detailed further in Section 5.4. (Account Deletion) the facility will retain certain information as necessary to comply with applicable regulatory and legal obligations.
Customer Support. Our Customer Support team uses a number of tools to help organize and manage the requests we receive. These tools help to ensure we provide timely, high quality support.
Cloud storage, IT, and Security. Our cloud
storage providers provide secure storage for information in
Codex databases, ensure that our infrastructure can support
continued use of our Services by Codex customers, and protect
data in the event of a natural disaster or other disruption to
the Service. Our IT and security providers assist with intrusion
detection and prevention measures to stop any potential attacks
against our networks. We have these third party experts perform
regular penetration tests and periodically audit Codex’s
Marketing and analytics. When you use our Services, including our website or mobile app(s), our third party service providers may collect Web-Behavior Information about your visit, such as the links you clicked on, the duration of your visit, and the URLs you visited. This information can help us improve site navigability and assess our Marketing campaigns. Per applicable data protection regulations, our EU, UK, and International websites present visitors with a cookie opt in to allow the processing described above via Functionality and Advertising Cookies.
NOTE: Our service providers act on Codex's behalf. We implement procedures and maintain contractual terms with each service provider to protect the confidentiality and security of your information. However, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.
2. "Targeted advertising" service providers
3. Aggregate information
We may share Aggregate Information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. This Information is different from "Individual-level" information and is not Personal Information because it does not identify any particular individual or disclose any particular individual’s data. For example, Aggregate Information may include a statement that "30% of our female users share a particular genetic trait," without providing any data or testing results specific to any individual user. In contrast, Individual-level Genetic Information or Self-Reported Information consists of data about a single individual's genotypes, diseases or other traits/characteristics information and could reveal whether a specific user has a particular genetic trait, or consist of all of the Genetic Information about that user. Codex will ask for your consent to share Individual-level Genetic Information or Self-Reported Information with any third party, other than our service providers as necessary for us to provide the Services to you.
4. Information we share with commonly owned entities
We may share some or all of your Personal Information with other companies under common ownership or control of Codex, 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. Generally, sharing such information is necessary for us to perform on our contract with you. We may provide additional notice and ask for your prior consent if we wish to share your Personal Information with our commonly owned entities in a materially different way than discussed in this Privacy Statement.
5. As required by law
Under certain circumstances your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. For example, we may be required to disclose Personal Information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Codex 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 Codex may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Codex 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 Codex, its employees, its users, its clients, and the public.
6. Business transactions
In the event that Codex goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets your Personal 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.
1. Access to your account
We provide access to your Codex data within your Codex account. You can access and download data processed by Codex within applicable Reports, Tools, and features. If you lose access to your Codex account or account email address, please contact Customer Support for assistance. If you lose access to your Codex account, in certain circumstances, we may require that you submit additional information sufficient to verify your identity before providing access or otherwise releasing information to you. If you choose not to submit the required documentation, or the information provided is not sufficient for the purposes sought, Codex will not be able to sufficiently verify your identity in order to complete your request.
2. Marketing communications
As noted in Section 3.8. you may be asked to opt-in to receive product and promotional emails or notifications when creating your Codex account depending on where you are located. Otherwise, you may view or update your email notification preferences by visiting your Account Settings or by contacting our Privacy Administrator at [email protected] You can also click the "unsubscribe" button at the bottom of promotional email communications.
3. Sharing outside of the Codex Services
You may decide to share your Personal Information with 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 that connect to our website and mobile apps through our application programming interface ("API"). 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 statements of all other third parties involved in the transaction. Codex does not endorse or sponsor any API applications, and does not affirm the accuracy or validity of any interpretations made by third party API applications.
In general, it can be difficult to contain or retrieve Personal Information once it has been shared or disclosed. Codex 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 a Codex customer through a multi-profile account, we urge you to recognize your responsibility to protect the privacy of each person within that account. Users with multi-profile accounts (i.e., where multiple family members register their kits to one account) should use caution in setting profile-level privacy settings.
4. Account deletion
If you no longer wish to participate in our Services, or no longer wish to have your Personal Information be processed, you may delete your Codex account and Personal Information by contacting [email protected] Once you submit your request, we will send an email to the email address linked to your Codex account detailing our account deletion policy and requesting that you to confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated Personal Information is deleted and any stored samples are discarded, subject to the following limitations:
Information previously included in Codex Research. As stated in any applicable Consent Document, Genetic Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in Codex Research cannot be removed from completed studies that use that information. It may take up to 30 days to withdraw your information after your account is closed.
Legal Retention Requirements. Codex and our third party processing facility, if applicable, will retain your Genetic Information, date of birth, and sex as required for compliance with applicable legal obligations. Codex will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, and record of legal agreements for a limited period of time as required by contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.
Codex takes seriously the trust you place in us. Codex implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information.
Codex produces secure applications by design. Codex incorporates explicit security reviews in the software development lifecycle, quality assurance testing and operational deployment.
De-identification/Pseudonymization. Registration Information is stripped from Sensitive Information, including Genetic and Self-Reported Information. This data is then assigned a randomly generated ID so an individual cannot reasonably be identified.
Encryption. Codex uses industry standard security measures to encrypt Sensitive Information both at rest and in transit.
Limiting access to essential personnel. We limit access to Personal Information to authorized personnel, based on job function and role. Codex access controls include multi-factor authentication, single sign-on, and strict least-privileged authorization policy.
Detecting threats and managing vulnerabilities. Codex uses state of the art intrusion detection and prevention measures to stop any potential attacks against its networks. We have integrated continuous vulnerability scanning in our processes and regularly engage third party security experts to conduct penetration tests.
Managing third party service providers. Codex requires service providers to implement and maintain accepted industry standard administrative, physical and technical safeguards to protect Personal Information.
Your Responsibility. Please recognize that 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 Services. You should not disclose your authentication information to any third party and should immediately notify Codex of any unauthorized use of your password. Codex 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 Hong Kong SAR or any other country in which Codex 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.
Codex is committed to protecting the privacy of children as well as adults. Neither Codex nor any of its Services are designed for, intended to attract, or directed toward children under the age of 18. A parent or guardian, however, may collect a saliva sample from, create an account for, and provide information related to, his or her child who is under the age of 18. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to Codex about his or her child is kept secure and that the information submitted is accurate.
Codex provides links to third party websites operated by organizations not affiliated with Codex. Codex does not disclose your information to organizations operating such linked third party websites. Codex 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 Codex and our service providers on our behalf.
Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our website 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. Codex may provide additional "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify Codex’s privacy practices or may provide you with additional choices about how Codex processes your Personal Information.