Privacy policy

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ABOUT CEN4GEN SERVICES

CEN4GEN is a Canadian owned, licensed corporation that offers quality, important and diverse genetic testing and personalized medicine, as well as advanced genome research services to patients, healthcare specialists and researchers. CEN4GEN services are rendered with cutting edge technologies and use up-to-date scientific and medical resources from a qualified staff having experience in genome science, bioinformatics, molecular diagnostics and personalized medicine. In addition, CEN4GEN services are undertaken in accredited environments, which further reinforce the high standards, reliability, and quality of CEN4GEN services.

DESCRIPTION OF SERVICES

CEN4GEN provides genetic diagnostic, personalized medicine and genome research services. Clients who choose CEN4GEN diagnostic services are required to provide his/her personal health information and family genetic history, name and contact information of his/her health care representative, in conjunction with billing and shipment information. Clients who choose CEN4GEN research services are required to provide billing and shipment information, together with relevant details of their research project.

PRIVACY STATEMENT

Brief Statement

This privacy policy is for the exclusive use of this website only and CEN4GEN services. CEN4GEN follows voluntary consent practices in the collection and distribution of ‘Personally Identifiable Information’ (PII) in compliance with Canadian Privacy laws, as well as the General Data Protection Regulation (GDPR) Policy of the European Union (EU).

We value your privacy while you visit our website, provide information, avail our services and interact with the content or services on our site and therefore, we have established a policy below; and your use of this website and CEN4GEN services signifies your acceptance of our Privacy Policy. This Policy demonstrates our commitment to taking all reasonable steps to secure ‘Personally Identifiable Information’ (PII) that can be used on its own or with other information to identify, contact, or locate an individual, or to identify an individual in context.

Please read the Policy carefully before availing any of our services.

INFORMATION COLLECTED

On request of any service from CEN4GEN, customer information is gathered which may include name, address, gender, ethnicity, contact details, service questions, purchase history and medical information for the purpose of completion of transaction/service, marketing, customer service, customer relationship management, placing orders or warranties. CEN4GEN does not distribute, sell, rent or trade personal information to any third party except for only relevant information necessary for shipment with freight companies, its contractors and for completing transactions via financial institutions.

Types and Purpose of Information Collected

CEN4GEN collects different information for specific purposes to provide uninterrupted services. When visits are made to our web site, we collect information about your computer, including the type of operating system and browser you use, your computer’s location, and what pages you visit on our site.

Express Consent Required

CEN4GEN collects sensitive or potentially sensitive information related to purchase history, service questions, service preferences, opinion about the services and health information only after taking expressed consent from you.

Implied Consent Required

For some specific purposes, CEN4GEN assumes implied consent on the part of the client when he/she proceeds with the transaction or to verify the client’s credit, process a refund or even placing a special order. CEN4GEN collects information related to purchase history, service questions, service preferences, opinion about the services and health information only for the above listed purposes as far as it is necessary to complete the transaction. CEN4GEN does not deny the processing of any transaction on non-submission of such personal information except in circumstances where it becomes Reasonable, Relevant and Really essential to collect it.

Opt-out Consent

CEN4GEN provides options to the clients to opt-out of giving/sharing any personal information related to service questions, purchase history, service preferences and opinion about the services when such information is collected for the purposes of marketing, administering a customer loyalty program, promotional/advertisement purposes or customer relationship management. Such opt-out consent shall be facilitated by an opt-out box/pop-up box which the client may decline or accept, or by contacting CEN4GEN by email or fax to request opt-out. Our website may use your geographical/demographical location for assessing marketing demographics, legal compliance, troubleshooting, and so on. To the extent the information is not mandatory for our services, you have an option to ‘opt-out’ or decline ‘consent’ to the retention or collection of such information, as well as to request a copy of your personal information we have on file.

CEN4GEN undertakes that the PII shall be used for the specific purpose only and if the information is to be used for any other purpose later, consent of the client shall be required again.

Who Collects the Information?

Business-related, healthcare-related or any other personal information is collected only by CEN4GEN client representative who is responsible for administering information requests. The information is not disclosed to/collected by any other CEN4GEN staff or CEN4GEN contractor where it may be prone to risk of inappropriate use or disclosure. The information related to opinions about services or surveys may be collected by CEN4GEN Market Representatives for marketing/customer service or customer relationship management with prior consent of the client.

When is the Information Collected and how is it Used?

When you access or use our Services, we automatically collect information about you, including:

  • Usage Information: If you choose to post messages on our message boards or other message areas or leave feedback for other users, we retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the Website, we may collect such information into a file specific to you.

  • Log Information: We log information about your use of our Website, including your browser type and language, access times, pages viewed, and your IP address.

  • Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity (“IMEI”) and mobile network information.

  • Location Information: With your consent, we may collect information about the location of your device to facilitate your use of certain features of our Services, determine the speed at which your device is traveling, add location-based filters, and for any other purposes.

  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. A “cookie” is a small data file transferred to your computer’s hard drive that allows a Website to respond to you as an individual, gathering and remembering information about your preferences in order to tailor its operation to your needs, likes and dislikes. Overall, cookies are safe, as they only identify your computer to customize your Web experience. Accepting a cookie does not provide us access to your computer or any Personally Identifiable Information about you, other than the information you choose to share. Other servers cannot read them, nor can they be used to deliver a virus. Most browsers automatically accept cookies, but you can usually adjust your website browser to notify you of cookie placement requests, refuse certain cookies, or decline cookies completely. If you turn off cookies completely, there may be some Website features that will not be available to you, and some Web pages may not display properly. To support the personalized features of our Website (such as your country, language codes and browsing functions) we must send a cookie to your computer’s hard drive and/or use cookie-based authentication to identify you as a registered Website user. We do not, however, use so-called “surveillance” cookies that track your activity elsewhere on the Web. We may also collect information using web beacons (also known as “tracking pixels”).

  • Web beacons” or clear .gifs are small pieces of code placed on a Web page to monitor behaviour and collect data about the visitors viewing a Web page. For example, Web beacons or similar technology can be used to count the users who visit a Website or to deliver a cookie to the browser of a visitor viewing that page. We may use Web beacons or similar technology on our Services from time to time for this and other purposes.

CEN4GEN uses the personal information in three different ways: Firstly, to provide you with improved services that you request; Secondly, to keep you informed about periodic emails, fax or mailed brochures regarding additional information about our services providing that you opt-in for such services; and Thirdly, we may use your aggregate responses to improve our services and provide potential clients with better services each time our site is visited.

CEN4GEN transmits information such as name, address, phone number, and bank account numbers to third party financial partners only for the payment process. The information including postal address, name, phone number, email address, purchase history, customer satisfaction information etc may be used for secondary purposes such as marketing, promotions, customer relationship management and warranties.

How We Share Your Information?

As a matter of policy, we will not sell, trade, or rent information about you and we will not disclose information about you in a manner inconsistent with this Privacy Policy except as required by law or government regulation. We cooperate with law enforcement inquiries, as well as other third parties, to enforce laws such as those regarding intellectual property rights, fraud and other personal rights.

We will not share the personal information we collect about you with any third party for their own marketing purposes without your consent. We may share your data with our contractors who process your personal information to provide services to us or on our behalf. We have contracts with our contractors that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else, or using it for other purposes.

You may decline to submit Personally Identifiable Information through the Services, in which case we may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please discontinue use of our Service; your continued usage of the Service will signify your assent to and acceptance of our Privacy Policy and Terms of Use.

WE CAN (AND YOU AUTHORIZE US TO) DISCLOSE ANY INFORMATION ABOUT YOU TO LAW ENFORCEMENT, OTHER GOVERNMENT OFFICIALS, ANY LAWSUIT OR ANY OTHER THIRD PARTY THAT WE, IN OUR SOLE DISCRETION, BELIEVE NECESSARY OR APPROPRIATE IN CONNECTION WITH AN INVESTIGATION OF FRAUD, INTELLECTUAL PROPERTY INFRINGEMENT, OR OTHER ACTIVITY THAT IS ILLEGAL OR MAY EXPOSE US, OR YOU, TO LIABILITY.

Ensuring Information Is Accurate And Up-To-Date

We take reasonable precautions to ensure that the Personal Information we Collect, Use and Disclose is complete, relevant and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. That is why we recommend that you:

a) Let us know if there are any errors in your Personal Information; and

b) Keep us up-to-date with changes to your Personal Information such as your name, address, email address, phone and fax number.

SPECIAL CATEGORIES OF PERSONAL DATA

Some of the data that you provide us, will fall within what European Union (EU) data protection law, describes as ‘special categories of personal data’, such as your ethnic origin, or information concerning your health.

We use this information in the same way we use all the other information we collect, but the law requires that we have your explicit consent to collect and use it.

By accepting our Privacy Policy, you consent to CEN4GEN using this information.

LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA

CEN4GEN is committed to the lawful, fair and transparent use of personal data. For every use of your personal data we have described so far, we process your personal data on the grounds that our processing is necessary for legitimate interests we pursue as an enterprise, namely that our enterprise relies entirely on the ability to use your personal data to provide our services, and insight for our clients.

If you have any questions about the grounds under which we process your personal data, or would like to find out more about the approach we take to determine that these grounds apply, please contact our Data Protection Officer using the contact details in the ‘Contact Us’ section.

TRANSFERRING PERSONAL DATA OUTSIDE THE EEA

We take all steps possible to ensure that your personal data remains within the European Economic Area (“EEA”). However, in some cases we need to share data with other CEN4GEN contractors, partner enterprises, or third parties that are in countries outside the EEA, as described earlier. These countries may not have similar data protection laws to the United Kingdom (UK) or EEA, and so they may not protect the use of your personal information to the same extent.

In these cases we put in place appropriate safeguards to make sure your personal data remains adequately protected. Specifically, we make use of the following:

  • Standard contractual clauses: We use standard contractual clauses for the transfer of personal data to organisations outside the EEA. These contractual commitments have been adopted by the European Commission and ensure adequate protection for personal data transferred to countries outside the EEA by binding recipients of personal data to certain data protection standards including obliging them to apply appropriate technical and security measures. We use standard contractual clauses when we transfer data to other contractors or partner enterprises and for transfers to recipients that are neither Privacy Shield certified nor located in a country covered by an adequacy decision.

  • EU-USA Privacy Shield: The Privacy Shield is a program agreed between the EU and the United States of America (USA) which aims to protect the personal data of anyone in the EU when it is transferred to the USA by placing data protection obligations on USA companies that receive personal data from the EU. We may rely on these safeguards when transferring data to contractors or partner enterprises based in the USA where those contractors are Privacy Shield certified.

  • Adequacy decisions: Where the European Commission has determined that a country outside the EU offers an adequate level of data protection, personal data may be sent to that third country without implementing any other safeguards mentioned above. We may rely on adequacy decisions when transferring data to contractors or partner enterprises based in countries where such assurances have been given.

Please contact us using the details at the end of this notice for more information about the protections that we put in place and to obtain a copy of the relevant documents

KEEPING INFORMATION SECURE

Security Tools

CEN4GEN website is scanned periodically for any security loopholes and known vulnerabilities in order to make your visit as safe as possible. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Information we collect. We use regular Malware and Anti-virus Scanning tools to remove any potential threats into the information systems. We also implement use of SSL (Secure Sockets Layer) certificate protocols for encrypted and secure connections and communications.

Children Privacy Protection

According to the provisions of Children’s Online Privacy Protection Act (COPPA), children below 13 years of age are not allowed to access online websites or access the contents without parental/guardian’s consent. CEN4GEN is committed to securing the privacy of children and does not intend to solicit or promote its services towards them or attract them. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which describes what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to individuals below the age of 18.

Disclosure to Third Parties

CEN4GEN shall not give, sell, rent, loan, trade, or otherwise partake any personal information to any third party unless: Firstly, you have consented us to do so; Secondly, law or enforcement agencies require us to do so in response to a subpoena, legal process or a court order and Thirdly, it is mandatory to do so to defend the property rights or intellectual rights of this website, CEN4GEN services or any other related party. We may however share aggregate, non-personal information about the usage of the website with a non-affiliate third party and such information would not fall within the category of PII.

The access to your information is provided to Client Service Representative or Marketing Representative only on ‘Need to Know’ Basis and only Reasonably Relevant information is collected and retained with the corporation. We may disclose financial/medical information only to such affiliated third parties or contractors who are authorized to access it.

Internet Links

We do not offer or include any internet links to third party products or services on our website.

However, any third party links provided to you by any third party vendor crediting our name may be unrelated to us and these websites may use technological tools such as cookies, JavaScript etc to track your IP and such personal information. However, we do not have access to any of their features and do not guarantee your security against the use of such information by these websites. You may find their respective privacy policy on their websites or you may contact the operator, for which we are not responsible.

Accessing and Updating Information and Preferences

Users or clients have a choice to request a copy or update their personal information which they want to disclose to CEN4GEN, our website and third party affiliates for any purpose. We make continuous efforts to identify any personal or sensitive personal data or information and rectify any defect/deficiency in it. We may deny to process requests that may infringe privacy of others or would be prima facie impractical.

Destruction of Information

CEN4GEN collects and stores contact information, purchase information, health information and other information in paper format and electronic files. CEN4GEN destroys any old file relating to such personal information that is no longer required for the specific purpose for which it was collected. CEN4GEN undertakes that the confidentiality and privacy of these records are not infringed.

ACCESS AND FAIR INFORMATION PRACTICES

Customer/client/visitor desirable to remove, correct, request a copy, or modify his/her personal information in our database must contact (in writing) our privacy officer at the following address:

Name: CEN4GEN Institute for Genomics and Molecular Diagnostics
Address: 6756 – 75 Street NW, Edmonton, AB T6E 6T9
Phone: 1 844-236-4436
Email: contact@cen4gen.org
Fax: 1-587-329-9566

You can also contact the Provincial or Territorial Privacy Commissioner’s office for more information:

Alberta Office of the Information and Privacy Commissioner of Alberta
410, 9925 – 109 Street, Edmonton, Alberta T5K 2J8
Phone: (780) 422-6860
Toll Free: 1-888-878-4044
Email: generalinfo@oipc.ab.ca
Web Site: http://www.oipc.ab.ca

We generally comply with the Fair Information Practices in compliance of which, in case of occurrence of any data breach, we shall notify the users via email or fax within reasonable period of time. CEN4GEN bears no liability for any unfortunate data breach by malicious entities or acts.

CAN SPAM Act

We collect your contact information in order to send you updates and information about our services, process orders, respond to queries and improve marketing strategies. We undertake not to use false or misleading subject or email addresses, include the incorrect address of our headquarters in any communication via mails, honor opt-out/unsubscribe requests. We rapidly allow users to conveniently opt-out by providing links. We shall promptly remove all correspondence history when you unsubscribe from our services except for the records that are reasonably necessary for us to retain for any future references.

CHANGE IN POLICY

Our website may update and change its privacy policy at its discretion and hence it is strongly advised that you periodically view the policy before using any of the features of our website and services.

INTELLECTUAL PROPERTY

The content of this website shall not be duplicated/copied/modified without written prior approval of the operator. Violation of any intellectual property of any product/design/document on the website shall be deemed illegal and appropriate action shall be taken forthwith.

Specific questions and comments should be directed to the appropriate department via our Contact Us page. While we make every effort to respond to all correspondence within 1 business week, we cannot guarantee a response to every electronic communication.

 

2018/07/04