Privacy Policy

 

Purpose

Genomix Co Pty Ltd (ACN 614 381 467) (“Genomix”) is committed to respecting the privacy and confidentiality of your personal information. Genomix must comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and any other privacy laws that govern how companies like Genomix handle your personal information (including your health information and the results of your tests).

The purpose of this Privacy Policy is to help you understand what information Genomix collects and holds about you and the way Genomix handles that information. The principles set out in this Privacy Policy will apply to any personal information you provide to us (including via our website www.genomix.co) and to information which we collect about you from other sources. In this Privacy Statement, “Genomix”, “we” and “us” means Genomix Co Pty Ltd as applicable.

Definitions

What is personal information?

Personal information is information or an opinion, whether it is true or not, about an individual whose identity is apparent, or can be reasonably ascertained, from that information or opinion. For the purposes of this Privacy Policy, a reference to personal information should be read as including sensitive and health information, unless otherwise specified.

What is sensitive information?

Sensitive information is a subset of personal information which is afforded a higher level of protection under the APPs. This includes information which relates to an individual’s race or ethnic origin, political opinions or memberships of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual preferences or practices, criminal record or health information about an individual. Our collection, use and disclosure of personal information, including sensitive information, will comply with the APPs.

What is health information?

Health information is personal information that is also information or an opinion about the physical, mental or psychological health of an individual, a disability of an individual, an individual’s expressed wishes for the future provision of their healthcare, or a health service provided to an individual. Health information also includes personal information that is collected to provide a health service or in connection with the donation of an individual’s body parts, organs or body substances, or personal information that is genetic information about an individual that is predictive of the individual’s health. For the avoidance of doubt, Genomix also treats genetic and biometric information as health information. Our collection, use and disclosure of health information will comply with the Health Privacy Principles under various state and territory information.

How we handle your personal information

The APPs regulate how we may collect, use, disclose and store personal information and how individuals may access and correct personal information which we hold about you.

In order to provide you with the product that you order from us and the services that you have requested, we will need to collect and use your personal information. If you provide incomplete or inaccurate information to us or withhold personal information from us we may not be able to provide you with the products and or services you are seeking. The interpretation of your test results is critically dependent on the information you provide and incomplete or inaccurate information or withdrawal of information may result in recommendations that are misleading and potentially be harmful or dangerous to your health.

What information do we collect?

We collect information from you that is necessary to provide you with personalised health care services, including interpreting and delivering your results. We will only ask you for information that we need to provide you with the particular test or service you have registered for. The type of personal information we collect about you includes your name, email address, address, telephone number, payment or billing information (including credit card details, billing address and invoice details) for the supply of our product. We may also ask you for health information about your health history, family history, or your current lifestyle which are used to assist in analysing your test results. In addition, we may need to collect sensitive information about your sex (gender), ethnicity and date of birth, all of which are important in interpreting your test results. In particular, the results of genetic tests are highly reliant on ethnicity information since expected genetic variations will differ significantly across ethnicities. Again, we will only collect sensitive information where it is essential to ensuring accurate interpretation of your test results.

Some of our tests are requested by your doctor for you. In this case, we will collect your email address and telephone number from your doctor in order to contact you in relation to your test. We will also collect some of your doctor’s personal information. We will collect the doctor’s name, AHPRA number, provider number, email address and practice name, address and telephone number. Once you have ordered a test, as requested by your doctor, your doctor’s details will be linked to your details.

Where you order a test that involves a family member, we will need to ask for some basic personal information about your family member. We will not ask you to divulge any health or sensitive information about your family member, other than their date of birth, which we use for security and identification purposes only. When you provide us with this information, we assume that you have your family member’s permission – it is your responsibility to ensure that your family member has agreed to allow you to do so. It goes without saying that we treat your family member’s information with the same care as we do yours, and that all the provisions of this Privacy Policy apply to their information equally.

We also collect and store your test results, delivered from our laboratory partners using secure, industry standard electronic protocols. These results include detailed information about your genetic code (specific to that particular test), analysis and interpretation of any genetic variations, and any recommendations based on that analysis. Where your test has been requested by your doctor, your test results will be provided to your doctor, unless you tell us that you do not want this to happen. If your doctor wishes to add notes to your record they will be able to and this information will be stored and be available to you.

Our genetic tests require you to send us a sample of your saliva, it must be your own saliva that you return to us. Our laboratory partners will store your genetic code in electronic form and your physical DNA sample, in keeping with best practice protocols and standard laboratory procedures. We do not share your name with laboratory partners outside Australia and instead use a unique identifier which only Genomix has access to. 

How do we collect your information?

We will usually collect your personal information directly from you. For example, we may collect personal information about you via our website and your use of it, when you contact our customer care or correspond with us about our service over the phone, letter or email or in person. For some customers, we will be provided with your contact details from your doctor or genetic counselor or your family member in order to contact you about a test.

Our website 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. 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.

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, age range, language, country, friends lists or followers) depending on your privacy settings on the third-party site. We do not control third-party site's information practices, so please review their privacy policies and your settings on those sites carefully.

How do we use your information?

We will use the personal information collected for the purposes disclosed at the time of collection, or otherwise as set out in this Privacy Policy. Your personal information will not be used for any other purpose without first seeking your consent, unless authorised or required by law. Generally, we will only use and disclose your personal information:

a) To provide the products or services you have requested from Genomix;

b) To answer your inquiry;

c) To assist us to make our products and services more valuable to our customers;

d) For direct marketing of products or services and to keep you informed of new developments we believe may be of interest to you. If we contact you in this way without obtaining your prior consent, we will provide you with the opportunity to decline any further marketing communications;

e) For research and business development purposes; and,

f) To third parties where we have retained those third parties to assist us to provide products or services you have requested.

For our customers, there are a select number of third parties that we may disclose your personal information to, although this will only ever be in the context of the primary purpose for which it was collected. These third parties include our laboratory partners (Macrogen Inc), genetic counselors, and your doctor.

We’ll need to provide saliva sample with unique identifier, gender and age to our laboratory partner, Macrogen Inc. Not only does this ensure that your data is consistently and uniquely identified, but it forms the basis to an accurate analysis and interpretation of your genetic code, and therefore ensures that your results are helpful, useful and relevant. We do not share your name with third parties outside Australia and instead use a unique identifier which only Genomix has access to. Note that Macrogen Inc will retain your physical DNA sample to comply with local law and best laboratory practice.

Unless your doctor has ordered a test on your behalf, you will initially need to discuss the results of any Genomix tests with a genetic counsellor, regardless of the test outcome. A Genetic Counsellor is a highly trained health professional, expert in understanding and explaining genetics. They have made a career out of helping people understand genetic tests, interpreting and explaining genetic test results and walking people through their options if tests show potentially bad outcomes. Genetic Counsellors will need to access your personal information and your test results in order to walk you through your results and answer any questions you might have.

If your doctor has ordered a test on your behalf, we will send your test results directly to your doctor, who will then discuss these with you in the context of any ongoing care or treatment provided by them. Your doctor will need to access your personal information and your test results in order to walk you through your results and answer any questions you might have. If your nominated doctor has changed or your doctor’s details have changed, you must let us know. Your nominated doctor may separately keep a copy of your test results, and we may do so on their behalf.

We recognise the sensitivity of our customers’ genetic information and take the security of this information seriously. We only work with partners and providers who have the same values. This means that we will take reasonable steps to ensure that our providers do not breach the APPs. In particular, Macrogen Inc has policies and procedures in place, which afford substantially similar protections to our own privacy policy.

Academic institutions, healthcare organisations, and other groups are always conducting interesting new research projects. We want to make you aware of these opportunities. While we do not share individual-level Genetic Information or Self-Reported Information with third-parties without your consent, from time to time we may inform you of third-party research opportunities for which you may be eligible. For example, if a university tells us about a new cancer research project, we may send an email to Genomix members who potentially fit the relevant eligibility criteria based on their Self-Reported Information to make them aware of the research project and provide a link to participate with the research organization conducting the study. If you do not wish to receive these alerts, you can manage them in your settings.

How can Genomix customers ensure the accuracy of data quality and security in regard to their personal information?

All the information you have entered is collected and stored by us. Registered customers can view and alter this information by logging in with their username and password and accessing their account information. The information includes addresses, and past orders. Access to this information by Genomix staff can only be performed by staff members with a secure password, with access only performed when required. Access to this information is recorded by log files to track unauthorised access and modifications.

We are committed to ensuring the information you provide us is secure. We will use technologies and processes such as access control procedures, network firewalls, encryption and physical security to protect your privacy and prevent unauthorised access, modification to or disclosure of that information.

Where possible, we will retain your data within Australia. However for technical, performance and best practice security reasons, we may need to make use of data storage companies that are owned and exist outside Australia. We will only work with partners who take your privacy as seriously as we do

How can you access, correct or remove your personal information

You have a right to access your personal information that we hold. We will, on request, provide you with a suitable means of access to your personal information unless there is an exception which applies under the Privacy Act 1988 (Cth). In particular, this means that we will not provide customers with access to their test results prior to their session with a genetic counsellor or their doctor. Your request to obtain access will be dealt with in a reasonable time. Please note that Genomix may recover reasonable costs associated with supplying this information to you. Should you wish to obtain access to your personal information, you can contact us at contact@genomix.co and Genomix can give you more detailed information about our access procedure.

Keeping your personal information up-to-date

Genomix will take reasonable steps to ensure that your personal information which we may collect, use or disclose is accurate, complete and up-to-date. If you believe that any of the personal information we hold about you is inaccurate, incomplete or out-of-date then you have the right to request we amend it. Please contact Genomix at contact@genomix.co. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it. Personal information is destroyed or de-identified when it is no longer needed.

Note that Macrogen Inc will retain your physical DNA sample for a period of time, unless you explicitly ask us not to during your registration process. It is retained to comply with local law and best laboratory practice, and potentially to provide future testing services which are requested. Customer’s extracted DNA will be stored in an access-controlled, secure cold storage facility on the laboratory premises in accordance with best practice laboratory procedures.

Does Genomix use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow cookies in your settings) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We use cookies to help us remember and process the items in your shopping cart.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still place orders by contacting customer service.

Collection of computer data

When you visit genomix.co, our company servers will automatically record information that your browser sends whenever you visit our website. This data may include:

Your computer’s IP address;

  • The type of browser that you are using;
  • The webpage you were visiting before you came to our site;
  • The pages within Genomix that you visit; and,
  • The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics.

This information is collected for analysis and evaluation in order to help us improve our site and the services and products we provide. This data will not be used in association with any other personal information.

Google Analytics and Google Adwords Remarketing

Genomix uses Analytics Remarketing with Google Analytics, and AdWords Remarketing with Google AdWords to advertise online. Third-party vendors, including Google, may show Genomix ads on sites across the Internet. This could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Genomix website.

Genomix and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on someone’s past visits to our website, and to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site.

Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.

You can opt-out of Google Analytics for Display Advertising and customise Google Display Network ads here.

You can also use this Analytics opt out tool here.

Do we disclose any information to outside parties?

We will not sell, lease, or rent your individual-level personal information (i.e., information about a single individual's genotypes, diseases or other traits/characteristics) to any third-party or to a third-party for research purposes without your explicit consent.

This does not include trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety. However, non-personal visitor information may be provided to other parties for marketing, advertising, or other uses.

Changes to our privacy policy

If we decide to change our privacy policy, we will update the Privacy Policy modification date below.

This policy was last modified on 28/08/16.

Cross Border Disclosures

Genomix will have laboratory partnerships with companies based in the United States (including Macrogen Inc). These laboratory partners will undertake the testing of your saliva sample. This means that we will share those aspects of customers’ personal information that are relevant to a particular test with them, and as such will involve transfer of data outside of Australia. We note that Macrogen Inc is a “covered entity” and is governed by the US Health Information Privacy Act (HIPAA). We believe that HIPAA affords substantially similar protections to Australian Law and our own privacy policy. More information on HIPPA can be found here http://www.hhs.gov/ocr/privacy/hipaa/understanding/.

Genomix may enter into arrangements with third parties to store data we collect, and such data may include personal information, outside of Australia. Genomix will take reasonable steps to ensure that the third parties do not breach the APPs. The steps Genomix will take may include ensuring the third party is bound by privacy protection obligations which are the same (or substantially the same) as those which bind Genomix and requiring that the third party have information security measures approved by Genomix.

Complaints about privacy issues

If you have a complaint about this privacy policy or our information handling practices you lodge a complaint with our Privacy Officer or the Federal Privacy Commissioner.

Contacting us

If there are any questions regarding this privacy policy you may contact us using the information below.

Privacy Officer

Genomix Co Pty Ltd

contact@genomix.co

INCUBATE, Wentworth Building (G01) University of Sydney NSW 2006