GREENWAY DNA PRIVACY STATEMENT
At GreenWay DNA, Inc. (“GreenWay”), your privacy is of paramount importance. GreenWay is committed to clarity around how your Personal Information is managed and will work diligently to ensure it is handled in a responsible manner. We will work ever so hard to secure your Personal Information (as defined herein) with administrative, technical, and physical safeguards.
Further, at GreenWay, we believe in a moral compass and value-matched expectations regarding your GreenWay experience. This is supported by an understanding that clarity and honesty is necessary when it comes to your data.
We are dedicated to seeking clarity around what Personal Information we collect and process. In doing so, we will strive to meet your expectations and communicate ours in simple, easy-to-understand language. Additionally, we want you to be informed and feel that you are in an informed position regarding GreenWay and our Services (as defined herein). Your Personal Information is yours, and we are using it to provide to you our Services. As such, we give you the control over the Personal Information you share with us, including your DNA Data (as defined herein), and how it is used, shared, and retained. Lastly, you always maintain ownership of your DNA and DNA Data—you can manage and delete it as described herein.
At GreenWay, we strive to improve your path to wellness through genetic sequencing. As a result, with your consent and cooperation, we collect, process and store your Personal Information as you seek to benefit from our DNA analysis and reporting services (collectively the “Services”) that you have requested. Personal Information is the type and kind of information that identifies you. For example, information such as your name, email or street address is the kind of information that could reasonably be linked back to you. It naturally follows of course that certain Genetic Information qualifies as Personal Information. This GreenWay DNA Privacy Statement (the “Privacy Statement”) describes how we manage your Personal Information (i.e. our practices for collecting, processing and storing your Personal Information) and the controls that you have with respect to managing such information within our Services.
- ACCOUNT CREATION AND YOUR ENGAGEMENT WITH GREENWAY SERVICES
The Personal Information required to initially create and open a basic GreenWay account is only your name, an email address, your physical address and a password that you create and confirm. Naturally, to obtain a GreenWay DNA Test Kit and submit DNA samples requires additional Personal Information, including payment details (including a billing address which may be different from your physical address referred to above), and a saliva sample from which we can extract Genetic Information.
Account creation also requires you to agree to both the GreenWay DNA Terms and Conditions of Service and this Privacy Statement. This will be accomplished by clicking “Continue” on the account creation page or in the case of certain situations, the execution of an acknowledgment that you have in fact read the GreenWay DNA Terms and Conditions of Service and this Privacy Statement and consent to the same (the clicking of “Continue” or submission of an acknowledgement are referred to herein as the “Consent”).
By way of your Consent, you are telling us that you do in fact consent to GreenWay collecting, processing, and sharing your Personal Information (including your Genetic Information if you have submitted a sample) as described in this Privacy Statement and in any other documents referenced in this Privacy Statement.
At any time, you can request that we delete information you have uploaded into your account, such as your Genetic Information. Please see Section 9 for specific details about deleting your data.
If you no longer wish to have a GreenWay account, please go to your Account Settings or contact us in writing and request that your account be deleted.
- WHAT INFORMATION DO WE COLLECT FROM YOU?
The table below describes the information we collect from you as you proceed with Greenway’s Services. In this Privacy Statement, we refer to this as your “Personal Information.”
INFORMATION CATEGORY USE DESCRIPTION
- Your name;
- An email address that is personal to you. By providing us with your e-mail address, you are representing to us that said email address is personal to you and that it is password protected by you;
- A password that you provide us when you create a GreenWay account;
- A mobile phone number that you may voluntarily provide so we can notify you of DNA test result status, or when you contact GreenWay Member Services.
Credit Card/Payment Information:
- Payment information, such as your credit card number, and your billing and shipping address(es), when you purchase something from GreenWay, such as a GreenWay DNA Test Kit.
DNA Kit Activation Information: When you activate a DNA Test Kit, we collect:
- Your DNA Test Kit code;
- Your birth sex (naturally, we respect and support any sexual orientation, but for purposes of our Services, your sex at birth is needed);
- Your year of birth.
- We collect the information that you provide when you voluntarily create a user profile.
- Information you provide about yourself or others (with respect to “others,” this must be provided as per the GreenWay TOS and compliance thereto) when you voluntarily contribute to the Services.
- We extract your DNA from the saliva sample you submit as part of the GreenWay DNA Test Kit at our CLIA certified partner laboratory when you send it back to us in the packaging provided with your GreenWay DNA Test Kit.
- As is standard in the genomics arena, we convert your DNA into machine-readable code (“DNA Data”), which is used to provide you with a GreenWay DNA report setting forth information regarding how your body relates to or reacts to certain cannabinoids or other compounds.
- A note about your DNA and Saliva: Once our laboratory partner has processed your DNA and produced your DNA Data, the DNA and saliva (also referred to as “biological samples”) are stored so that they can be available for future testing. Future testing may be done, provided you agree to our Informed Consent for Research or if you otherwise consent to future testing of your biological sample. Sections 7 and 9 below describe how you can control both your DNA Data and your biological samples.
Social Media Information:
- If you use Facebook or other social media forums to log into GreenWay, we collect information from your Facebook profile that by doing so, you have chosen to provide to us (e.g. your Facebook profile information).
Additional User Information:
- Information that you provide to us when you answer GreenWay’s initial questionnaire/survey (such information is very valuable to our being able to provide you the Services), email surveys or other online questionnaires offered through the Services.
Contests and Promotions:
- Information when you voluntarily participate in contests and special promotions we may run through our Services from time to time.
- WHAT INFORMATION DOES GREENWAY COLLECT THROUGH YOUR USE OF THE SERVICES?
INFORMATION CATEGORY USE DESCRIPTION
Computer and Mobile
- Information about how you access our Services, including the website you visited before and after GreenWay’s site.
- The Internet protocol (“IP”) address of your computer, mobile device, or the proxy server that you use to access the Internet, in addition to other technical information, such as:
- Your computer operating system, and
- Your web browser.
- Your mobile device identifier provided by your mobile device operating system and your mobile operating system.
- The name of your internet service provider or mobile carrier.
Information from Cookies
and Similar Technologies:
Information shared through
Social Media Features:
- If you interact with social media through the Services, for example “Like,” “Tweet,” “Pin,” or “Follow Us” links to sites such as Facebook, Twitter, Pinterest, Instagram, and YouTube, GreenWay will collect these interactions and whatever account information these services make available to us.
- Your interactions with these features are governed by the privacy statement of the applicable third-party company.
Information from your
use of the Services:
- Information about your use of the Services, such as when you search or access your GreenWay report, blogs, records, and which pages you view or links you click on, etc.
- HOW DOES GREENWAY USE YOUR PERSONAL INFORMATION?
INFORMATION CATEGORY USE DESCRIPTION
Personal Information (generally):
- We use your Personal Information to provide, personalize, improve, update and expand our Services. This includes:
- Authenticating your access to the Services and improving GreenWay information security;
- Processing your payments for GreenWay DNA Test Kits, and other products and features;
- Building new and improving existing Services and/or products;
- Issuing surveys and questionnaires to collect Additional User Information for use in the Services, as well as facilitating any Service of product development and research initiatives;
- Conducting scientific, statistical, and historical research; and
- Detecting and protecting against error, fraud, or other criminal or malicious activity and enforcing our TOS.
- We use your Personal Information to communicate with you about the Services, such as when we:
- Respond to inquiries you may make to GreenWay.;
- Inform you of Service changes or new products and services;
- Ask you to participate in GreenWay media productions or testimonials; and,
- Provide you with information or request certain actions in response to technical, security, and/or other operational issues.
Market new products and offer:
- We use your Personal Information to market any new GreenWay Services and offers from our business partners. This includes, but may not be limited to, personalized communications with you based on your interests.
- GreenWay uses your Genetic Information for the following primary purposes:
- Providing you other insights into what your DNA reveals about traits and personal characteristics; we may also invite you to participate in surveys and questionnaires (entirely optional) based on your DNA data.
- Studying aggregated Genetic Information to better understand population trends, demographics, physical conditions, etc.;
- Conducting scientific, statistical, and historical research; and,
- Improving features and functionality in our existing DNA-related Services, enhancing the customer experience across our GreenWay Services, improving the quality of our laboratory processes and technology.
- We will seek additional consent from you before we collect and process additional sensitive Personal Information as part of your interaction with the Services.
- WHEN MIGHT WE SHARE YOUR INFORMATION AND WITH WHOM?
Except as otherwise described in this Privacy Statement, GreenWay does not share your individual Personal Information (including your Genetic Information) with third-parties without your additional consent other than as described in this Privacy Statement. Particularly, we will not share your Genetic Information with insurance companies, employers, or third-party marketers without your express consent. Notwithstanding the above, the following sets forth those certain third parties with whom your information will be shared absent additional consents and the circumstances regarding the sharing:
THIRD PARTY CIRCUMSTANCES
- We use other companies to help us provide the Services to you. As a result, these partner companies may have some of your information in their systems. Please be advised, that our partners are subject to contractual obligations governing data security and confidentiality consistent with this Privacy Statement and applicable laws.
These processing partners include our:
- Laboratory partners;
- DNA test shipping providers;
- Payment processors;
- Cloud services infrastructure providers;
- Biological sample storage facilities (i.e. bio banks);
- Vendors that assist us in marketing; analytics, and fraud prevention; and
- Some Member Services functions.
- We share your Genetic Information with research partners only when you provide us with your express consent to do so through our “Informed Consent to Research”.
- Research partners may include commercial or non-profit organizations that conduct or support scientific research, the development of therapeutics, medical devices or related material to treat, diagnose or predict health conditions. In some circumstances, a research partner or GreenWay may have a financial interest in the research arrangement.
Legal or Regulatory Process:
- We may share your Personal Information if we believe it is reasonably necessary to:
- Comply with valid legal process (e.g., subpoenas, warrants);
- Enforce or apply the GreenWay Terms and Conditions of Service (the “TOS”);
- Protect the security or integrity of the Services; or
- Protect the rights, property, or safety, of GreenWay, our employees or users.
- If we are compelled to disclose your Personal Information for Legal or Regulatory reasons, we shall do our best to provide you with advance notice, unless we are prohibited under the applicable law from doing so.
If GreenWay is Acquired:
- If GreenWay or its businesses are acquired or transferred (including in connection with bankruptcy or similar proceedings), we will share your Personal Information with the acquiring or receiving entity. The duties and obligations set forth in this Privacy Statement shall continue to apply to your Personal Information that is transferred to the new entity.
A Note about Aggregated Data:
- GreenWay may disclose user information in an aggregated form as part of the Services, as part of our marketing, or in scientific publications published by us or our research partners, if any. Such disclosure will never include Personal Information.
- YOUR CHOICES AND ACCESS TO YOUR PERSONAL INFORMATION
Subject to certain exceptions, you have a right to request access to your Personal Information and to be provided with a copy of certain information you provided in a portable form, as well as to seek to update, delete or correct this information by using the tools described below or by contacting GreenWay. Details and options for accessing this information are listed below.
- You can access and update the Personal Information (such as your email address, username, profile information, etc.) that you provide to GreenWay at any time in the privacy settings:
Genetic Information Download:
- Your DNA Data belongs to you. You always have the option of downloading a file with your DNA Data.
- WHAT ARE GREENWAY’S RETENTION PRACTICES?
GreenWay Services are fundamentally premised on the notion that the path to wellness is an ongoing and constantly improving process rather than a one-time event. Additionally, and with particular regard to our users, members and DNA customers, the ongoing enhancement of GreenWay’s research, records and DNA features provide the benefits of new discoveries and insights to our users, members and DNA customers over time. As a result, GreenWay’s retention practices reflect this ongoing value by retaining user accounts on our system until our users (account holders) inform us of their desire to delete their data or close their accounts, which can be done at any time and at the sole discretion of the user, member and DNA customer.
INFORMATION CATAGORY RETENTION PERIOD
Account: GreenWay will retain the Personal Information you provide while creating your account until such time as you ask us to close it.
DNA: GreenWay retains your DNA data as needed to provide you with the features and functionality you purchased (or were gifted), including continuously updated features as new features based on your DNA data, and the ever-evolving science related to gene function.
Usage Information: In some cases we choose to retain usage information (e.g., visits to sites) in a depersonalized or aggregated form. Once aggregated, this information ceases to be personal and will not be subject to GreenWay user deletion requests.
- HOW CAN I DELETE MY PERSONAL INFORMATION?
You can delete your Personal Information from GreenWay in a number of ways.
INFORMATION CATEGORY HOW TO DELETE
Personal Information: You can delete your Personal Information from GreenWay by logging into your Account Settings.
Please direct any request to remove information from linked archival records to the responsible archival entity.
We will consider requests for removal of Personal Information from the searchable indexes of the records we hold on a case-by-case basis in accordance with applicable law.
Note: If you request that GreenWay delete your DNA Data, we will delete all Genetic Information, including any derivative Genetic Information from our production, development, analytics, and research systems within thirty (30) days.
To request the destruction of your biological samples, you must contact Member Services. Please note that if you have agreed to our Informed Consent to Research, we will not be able to remove your Genetic Information from active or completed research projects, but we will not use it for any new research projects.
Further note: Please note that there may be some latency in deleting your Personal Information from our backup systems after it has been deleted from our production, development, analytics, and research systems. Also, our laboratory partners may retain information they receive from us in order to comply with laws or regulations that may require them to do so, such as the Clinical Laboratory Improvements Amendments regulations administered by the U.S. Food and Drug Administration. GreenWay may also retain certain information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.
GreenWay maintains a comprehensive information security program designed to protect our customers’ Personal Information using administrative, physical, and technical safeguards.
The specific security measures used are based on the sensitivity of the Personal Information collected. We have measures in place to protect against inappropriate access, loss, misuse, or alteration of Personal Information (including Genetic Information) under our control.
GreenWay’s Security Team regularly reviews our security and privacy practices and enhances them as necessary to help ensure the integrity of our systems and your Personal Information.
We use secure server software to encrypt Personal Information (including Genetic Information), and we only partner with security companies that meet and commit to our security standards. While we cannot guarantee that loss, misuse or alteration of data will not occur, we use reasonable efforts to prevent this.
It is also important for you to guard against unauthorized access to your Personal Information by maintaining strong passwords and protecting against the unauthorized use of your own computer or device.
- CHANGES TO THIS STATEMENT
We may modify this Privacy Statement at any time, but we will provide advance notice of any material changes to this Statement, such as posting a notice through the Services, on our website, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services.
We will also notify you of non-material changes to this Statement as of their effective date by posting a notice through the Services, on our websites, or sending you an email. Your continued use of our Services after notice of non-material changes means that you Consent to the updated Privacy Statement.
If you object to any changes, you may delete your account through your Account Settings.
- CALIFORNIA’S SHINE THE LIGHT LAW
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits Users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, GreenWay currently does not share any Personal Information with third parties for their own direct marketing purposes.
- LEGAL BASIS UNDER EU GENERAL DATA PROTECTION REGULATION FOR PROCESSING PERSONAL INFORMATION OF EU RESIDENTS.
Where you have consented to data processing, your Consent provides the legal basis to process your Personal Information. We rely on your Consent to process your Genetic Information. You have the right to withdraw Consent at any time. Please note that your withdrawal of Consent to collect and process your Personal Information will not affect the lawfulness of processing your Personal Information based on your Consent before you withdrew your Consent.
We may also process your Personal Information on the basis of contractual necessity to perform a contract we have with you. For example, we process your credit card details when you provide them in order to use our Services or purchase access to premium features such as our DNA testing services.
We may also process your Personal Information on the basis of our legitimate interests, including in providing and improving the Services. For example, GreenWay has a legitimate interest in understanding your login history so we can assess your interaction with our Services. We also have a legitimate interest in providing and developing interesting features to provide to our users. We use your Personal Information to keep our Services safe and secure and we do so as it is necessary to pursue legitimate interests in ensuring that our Services are secure, and to protect against fraud, spam and abuse.
Where we rely on legitimate interests to process your Personal Information, you have the right to object to such processing (meaning that you can ask us to stop). You can use your Privacy Settings to control certain ways in which we process your data. You can also contact us, using the details below, to object to other forms of processing.
- IDENTITY AND CONTACT DETAILS OF THE DATA CONTROLLER
If you reside in the United States, GreenWay, Inc. is responsible for the use of your data and for responding to any requests related to your Personal Information.
Contact information is listed at the bottom of this Statement.
Contact Details of GreenWay Member Services
Email: email@example.com – Please state “ATTN: DATA PROTECTION” in the Subject Line.
GreenWay members can reach us using this phone number:
Press “1” for the Support Team; “2” for the Sales Team, and “3” for the Administrative Team.
GreenWay business hours are currently 8:00 AM to 7:00 PM.
The system will automatically go to Voice Mail outside of the above Business Hours.
Official correspondence must be sent via postal mail to:
GreenWay DNA, Inc.
P.O. Box 51237
Eugene, Oregon 97405
ATTN: Member Services