Current as of
6/15/2009
INTRODUCTION
Please read this privacy policy (the "Privacy Policy") to
learn more about how Interleukin Genetics, Inc. ("Interleukin,"
"we," or "us") treats personally identifiable information that you
provide to us when you create a user account and order Services on
our website www.inherenthealth.com (the "Website").
Unless otherwise defined herein, capitalized terms shall have the
meanings assigned to such terms in the Terms and Conditions of Use
Agreement for the Website found here. If you have comments, suggestions,
questions, or concerns about our Privacy Policy, please contact us
at privacy@InherentHealth.com.
What This Privacy Policy Covers. This policy
covers our treatment of personally identifiable information that we
obtain from you when you register as a new customer and when you
purchase Services that may be offered for sale on our
Website. Personally identifiable information also includes
health information that you disclose to us and information
generated from tests that we conduct for you. We regard personally
identifiable information as information that someone can use to
identify or contact you in person, such as real name, telephone
number, email address, physical mailing address, financial account
information, Genetic Information, and certain medical information
you voluntarily provide to us such as your birth date, gender, and
personal and family disease history. Information that we use
internally to identify you as a customer in our system, such as
your selected username or password, is not considered personally
identifiable information.
What This Privacy Policy Does Not Cover. This
policy does not cover the privacy practices of third parties that
we do not own or control, such as our partners and advertisers. In
addition, we may provide links to other services and on occasion to
other sites that may interest you. All of these sites operate
independently and they have their own privacy or security
practices. We have no control over, do not review, and cannot be
responsible for these outside websites or their content.
Accordingly, we encourage you to review their policies before
submitting any personal information to them.
HOW INFORMATION IS COLLECTED
1. Information You Provide.
Required Registration
Information. When you register as a customer, we collect
the following information from you: full name, email address, and
the username and password you have created.
Required Information When
You Order Products. When you order products on our
Website, we collect your full name, your billing and shipping
address, telephone number, credit card number, expiration date and
security code.
Email Information.
In addition to providing the foregoing information to us, if you
choose to correspond with us through email, we may retain the
content of your email messages together with your email address and
our responses. We provide the same protections for these electronic
communications that we employ in the maintenance of information
received by mail and telephone. It will remain safeguarded
and not be shared with any outside services or companies, except as
necessary to provide the services that you have requested.
Access to Your Personal
Information. In general, we make it easy for you to view
the personally identifiable information we have collected from you
in your customer profile, where you can add, edit, or delete it as
you see fit.
2. Information We Track. Similar to other
commercial web sites, our Website utilizes a standard technology
called cookies and Web server logs to collect information about how
our Website is used. Information gathered through cookies and Web
server logs may include the date and time of visits, the pages
viewed, time spent at our Website, and the websites visited just
before and just after our Website. This information is collected on
an aggregate basis. None of this information is associated with you
as an individual.
Cookies are stored on computers to increase the security of your
personal information and make it easier for you to navigate a
website. Session cookies are automatically deleted when you
close your web browser, while other cookies, called persistent
cookies, remain on your computer for long periods of time. To
remove persistent cookies from your computer, follow the
instructions in the help menu of your web browser. If your
internet settings block cookies altogether, you will not be able to
log into an account on the Website.
INFORMATION WE DO NOT COLLECT
1. Personal Information of Children Under the Age of 13.
You should be aware that our Website is not intended for, or
designed to attract, children under the age of 13 and as such, we
do not intentionally gather personally identifiable information of
children who are under the age of 13. If you believe that we have
collected personal information about a child who is under the age
of 13, please contact us at privacy@InherentHealth.com
and such personal information will be deleted.
HOW PERSONALLY IDENTIFIABLE INFORMATION IS USED,
CONTROLLED, AND SECURED
1. Use of Your Personally Identifiable Information That
You Provide To Us. We may use your personally identifiable
information for the following purposes:
- To process and fulfill your order, including to send you emails
confirming your order status and shipment.
- To generate and send you requested test results.
- To communicate with you and to send you information by email,
mail, or other means about our products, new services, and special
offers we think you will find valuable.
- To notify you about important changes to our Website.
As a customer, you will be given the opportunity, at least once
annually to notify us of your desire not to receive promotional
offers.
2. Use of Information We Collect From
Cookies. We may use the information we collect from
cookies for the following purposes:
- To analyze trends and statistics about the use of our
Website
- To design our Website in the most user-friendly manner so that
we can enhance your shopping experience
- To help us improve our Website, products and services and
better serve our existing and potential customers
3. Control of Your Personally Identifiable
Information. Except as otherwise described in this Privacy
Policy, personally identifiable information you provide to us will
not be shared outside of Interleukin and its controlled
subsidiaries and affiliates without your permission.
4. Security of Personally Identifiable
Information. To prevent unauthorized access to personally
identifiable information, we have put into practice a number of
procedures set forth below:
- User access is protected using personally assigned usernames
and passwords.
- DNA samples are assigned a unique, anonymous barcode to track
the Genetic Information independent of the user information.
- User information is always stored separately from Genetic so
that Genetic Information remains anonymous to laboratory
personnel.
- This Website is encrypted to secure personally identifiable
information. All personally identifiable and transactional
information is encrypted using industry standard SSL encryption
where the consumer sends confidential personal and credit card
information to us on our Website, a secure server software which we
have licensed encrypts all information entered before it is sent to
us. The information is scrambled en route and decoded once it
reaches our Web site.
- Our network is secured using server firewalls. In addition, the
Website will use firewall to protect information from unauthorized
access, disclosure, alteration, and/or destruction.
- Archives containing personally identifiable information are
securely stored on the database server which will be securely
stored behind the firewall
- Employee and third party consultant access to personally
identifiable information is limited to their needs related to
provision of Services. Employees and third party consultants may
only access this information using a password.
All employees and third party consultants with access to
personally identifiable information are trained appropriately and
are required to sign a confidentiality agreement that aligns with
this privacy policy.
Please note that email correspondence that you may send to us
may not be secure unless we advise you that security measures will
be in place prior to your transmitting the information. For that
reason, we ask that you do not send confidential information such
as Social Security or financial account numbers to us through an
unsecured email.
HOW INFORMATION IS SHARED AND
DISCLOSED
1. With Third Parties. We may provide anonymous, aggregate
information about our customers, sales, Website traffic patterns
and related information to our affiliates, partners or reputable
third parties, but this information will not include personally
identifiable information.
2. Linked Services. In some cases, we may allow
you to access or link to other products or services through our
Website. In all of these cases, our partners may choose to collect
your personal information as they deem appropriate. We are not
responsible for or in control of how our partners collect, use, or
disclose your information obtained through these linked services.
We encourage you to be aware when you are using these partner
services and, for your best online experience, we encourage you to
review their policies before submitting any personal information to
them.
3. As Necessary In Certain Legal
Circumstances. We reserve the right to disclose your
personally identifiable information as required by law and when we
believe that disclosure is necessary to protect the rights,
property or safety of Interleukin or others, respond to claims
and/or to comply with a judicial proceeding, court order, or legal
process served on us.
TEST RESULTS
Customer samples are processed in our state-of-the art
CLIA-certified laboratory with the utmost standards of quality and
according to government regulations.
Your DNA sample will only be tested for the information
requested. Results will be provided by mail to the address
designated or electronically via a secure, password protected
Website. No one outside our laboratory will have access to
the results unless directed to do so in writing. This
includes family members.
To further protect your privacy, we will destroy samples within
ten days after completing your requested test.
COMMUNICATION
We will contact customers using the method of
communication they specify. Information will not be
communicated to any other individual unless the customer directs us
to do so in writing or it is required by law.
ACCOUNT TERMINATION
If a customer decides to terminate his or her account with
Interleukin, we will delete the customer's user account,
access and personally identifiable information from our
system. However, we are required by law to
archive and retain copies of the test report for 7 years.
FEDERAL LAWS PROTECTING YOU
Some people worry that once they know a genetic fact about
themselves, they could be forced to share that information with an
insurer or employer. The United States instituted a new law
on May 21, 2008 called the Genetic Information Nondiscrimination
Act (GINA), which protects Americans against unfair treatment from
employers and insurers on the basis of genetic information.
As a result, you are not required to disclose genetic information
to an employer or insurer, nor can they legally discriminate
against you.
STATE LAWS PROTECTING YOU
There are also state laws that prevent insurers, employers
and others from using genetic test results for discriminatory
purposes. You may have additional protection under these laws,
depending on where you are located.
NOTICE TO CALIFORNIA RESIDENTS
California Civil Code Section 1798.83 permits customers
who are California residents and who have provided Interleukin with
"personal information" (as that term is defined in Section 1798.83)
to request certain information about the disclosure of that
information to third parties for their direct marketing
purposes. If you are a California resident with questions
regarding this, please contact Interleukin at privacy@InherentHealth.com
or at Interleukin Genetics, Inc., 135 Beaver Street, Waltham,
Massachusetts 02452, U.S.A.
FOR OUR CANADIAN CUSTOMERS
Canadian citizens, except under circumstances defined by
law, are entitled to access their own Personal Information
collected by Interleukin by writing to: Interleukin Genetics, Inc.,
135 Beaver Street, Waltham, Massachusetts 02452, U.S.A. We may ask
you to pay an administrative fee for accessing or copying your
information, but will inform you of the anticipated charges and
confirm that you want us to proceed before processing your request.
If you believe that the personally identifiable information about
you that we have collected is incomplete or inaccurate, we will
correct the information upon verification of the omission or error
and of the identity of the person requesting the change. If you
wish additional information about our personal identifiable
management, to access, correct or have us investigate any matters
in relation to your personally identifiable information, please
contact us at the address provided above.
NOTICE TO VISITORS OUTSIDE OF THE UNITED
STATES
You should be aware that the United States and other
countries have not harmonized their privacy regulations. Because
Interleukin and its servers is located in the United States, we
have written our Privacy Policy to satisfy United States
regulations. By registering as a customer, you expressly agree to
the transfer into and out of the United States and the use of your
personally identifiable information as necessary to provide the
services that you request. You also agree to the level of privacy
protection set out in this Privacy Policy.
LINKED WEBSITES
This Website contains links to third-party Websites
operated by other organizations. We are not responsible for
their privacy practices and we encourage our customers to read the
privacy policies of each Website that collects personally
identifiable information. We will not disclose our customers'
personal information to these organizations.
BUSINESS TRANSITION
In the event that Interleukin undergoes a business
transition such as a merger or an acquisition by another company,
or if any personally identifiable information is transferred to
another company, we will require the successor to comply with the
terms of this policy.
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy is subject to occasional revision, and
changes will be posted on the Website. If we make any
substantial changes in the way we use or disclose your personally
identifiable information, we will notify you at the email address
listed in your customer profile. If you object to any such changes,
you may request that we delete your customer account.