Privacy Policy

Effective as of November 15, 2018.        

This “Privacy Policy” describes the privacy practices of Nebula Genomics, Inc. and our subsidiaries and affiliates (collectively, “Nebula”, “we”, “us”, or “our”). This Privacy Policy describes how we collect, use, disclose and otherwise process personal information, and explains the rights and choices available to individuals with respect to their information. This Privacy Policy applies to our website nebula.org, our genetic information analysis and sharing services, any to any other websites that we own or control that post a link to this Privacy Policy.

Nebula may provide additional or supplemental privacy notices to individuals at the time we collect their data. This privacy notice will govern how we may process the information you provide at that time.

This Privacy Policy does not apply to the Nebula’s processing of employee or contractor data.

Table of Contents

Personal Information We Collect

How We Use Your Personal Information

How We Share your Personal Information

Your Choices

Security

International Transfer

Other Sites and Services

Changes to this Privacy Policy

Contact Us

Personal Information We Collect

Information you give us

We collect personal information about individuals who interact with the Nebula, including by using our website or services. We collect information when individuals provide it directly to us, or when they authorize another party to provide it to us (such as by establishing a link between your Nebula account and an account on another website or online service)

The types of personal information we collect directly from these individuals include:

Genetic information and biological specimens

We collect genetic information via the website and our services. This information may include whole or partial genomic information, lab results, interpretations, and similar information, along with conclusions and inferences that may be drawn from your genetic information. Genetic information may be used to reveal information that is deemed sensitive under applicable law, such as information related to racial or ethnic origin and health.

We may enable you to provide genetic information to us through biological specimen collection kits (typically, a saliva sample) or by uploading or transferring to us genetic results that you have already obtained via a third-party source. We may use independent laboratory partners to perform genetic sequencing and to store your biological specimen.

You are not required to provide any genetic information to us; however, we may need genetic information to be able to provide certain features or functionality of the website or our services. If you choose to provide your genetic information to us, you must consent to our processing of the information as described in this Privacy Policy. If you do not consent, you must not submit such genetic information to us.

Information we obtain from social media networks

We may maintain pages for our company and our services on a variety of third-party platforms, such as Facebook, LinkedIn, Twitter, Google+, YouTube, Instagram, and other social networking services. When you interact with our pages on those third-party platforms, the third party’s privacy policy will govern your interactions on the relevant platform. If the third-party platform provides us with information about our pages on those platforms or your interactions with them, we will treat that information in accordance with this Privacy Policy.

Referrals

Nebula users of may have the opportunity to refer friends or other contacts to us. You may only submit a referral if you have permission to provide the referral’s contact information to us.

Information automatically collected

When you access our websites, we, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity on our websites or services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, the website you visited before browsing to our websites, general location information such as city, state or geographic area; and information about your use of and actions on our websites, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and length of access.  This information is collected using cookies, pixel tags, and similar technologies. Pixel tags (which are also known as web beacons and clear GIFs) are used on our websites and HTML formatted emails to track the actions of users on our websites. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of our websites or engagement with email notices, so that we can manage our content more effectively. Please refer to the Cookies and Similar Technologies  section for more details.

Cookies and Similar Technologies

What are cookies?

Cookies are small data files stored by a website on the device you use to access the website. Our websites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our websites.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our websites; and (2) third-party cookies, which are served by service providers and business partners on our websites, and can be used by such service providers and business partners to recognize your computer or mobile device when it visits other websites.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Essential Cookies

These cookies are essential to provide you with services available through our websites and to enable you to use some of its features. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.

Functionality Cookies

These cookies allow our websites to remember choices you make when you use our websites. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our websites.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our websites and how users use our websites. The information gathered may include the types of information described above in the section titled “ Information automatically collected .” We use this information to help operate our websites more efficiently, to gather broad demographic information, monitor the level of activity on our websites, and improve the Site.

We use Google Analytics and Mixpanel for this purpose. Google Analytics and Mixpanel use their own cookies. You can find out more information about Google Analytics cookies here  and about how Google protects your data here .  You can prevent the use of Google Analytics relating to your use of our websites by downloading  and installing the browser plugin available here .  You can find out more about Mixpanel’s services here , its privacy practices here , and opt out of tracking by Mixpanel by enabling “Do Not Track” in your browser.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” (or similar) button on our websites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this.

Targeted and advertising cookies

These cookies track your browsing habits to enable us and third-party advertising networks to deliver ads that may be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests or browsing behavior. Based on the cookies that the third-party advertising network sets on our websites and other sites, advertisers can display advertisements that may be relevant to your interests on our websites and while you are on third-party websites.

You may opt out of the use of your browsing behavior for purposes of targeted advertising as described in the section titled “ Online Behavioral Advertising ” below.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” menus).  Many browsers are set to accept cookies until you change your settings.  

For further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org .

If you do not accept our cookies, you may experience some inconvenience in your use of our websites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our websites.

How We Use Your Personal Information

To provide our services

We use your personal information to provide our services in the following ways:

To sequence your genetic information and provide access to your genetic information and related reports and analyses

We use your biological samples to provide to our independent laboratory partners, which sequence your genetic information; and, if you agree, to store for future research purposes. We use your genetic information to provide you with online access to your genetic information (including by indexing and creating metadata regarding your genetic information), to perform analyses on your genetic information and create reports, and to make such reports available to you.

To help researchers identify individuals whose genetic information they wish to purchase and facilitate offers to purchase genetic information

We may make available certain information (such as information that you have provided about your health or medical-related information, information about your personal traits and characteristics, information about your employment and commute, and information about your behavior) to academic institutions, non-profit organizations, healthcare organizations, and pharmaceutical or biotech companies (collectively, “Researchers”) to help the Researchers identify individuals whose genetic information may be relevant to their research and from whom the Researchers would like to obtain genetic information.

Although Researchers will be able to contact you through the service, we do not disclose your name or contact information to them. However, the Researcher’s name and institutional or corporate affiliation will be visible to you.

To disclose your health and genetic information to third parties

We may disclose your information, including your genetic information, to Researchers who request it. You can read more about sharing with Researchers and the choices available to you in the “Your Choices” section below. When we share your information with Researchers, we do not share your name or contact information along with your health or genetic information.

Any genetic, health and medical information we disclose to a third party will be subject to that third party’s privacy policy and practices. We do not control how that third party uses your personal information after we provide it to them.

To communicate with you

If you request information from us (such as by signing up for our newsletter or publications), register on our websites, we may send you Nebula-related marketing communications as permitted by law. You will have the ability to opt out of such communications.

To comply with law

We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. Please see the “ Security ” section for additional information.

With your consent

We will request your consent to use your personal information where required by law, such as where we use certain cookies or similar technologies or would like to send you certain marketing messages.  If we request your consent to use your personal information, you have the right to withdraw your consent any time in the manner that was indicated when we requested the consent or at any time by contacting us . If you have consented to receive marketing communications from our third-party partners, you may withdraw your consent by contacting those partners directly.

To create anonymous data for analytics

If you consent, we may create anonymous data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by excluding information that makes the data personally identifiable to you and use that anonymous data for our lawful business purposes.  

For compliance, fraud prevention and safety

We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. Please see the “ Security ” section for additional information.

How We Share your Personal Information

Affiliates  

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

Service Providers

We may employ third-party companies and individuals to administer and provide our services on our behalf (such as customer support, email delivery, hosting, data storage and cloud infrastructure, and database management services). These third parties may use your information only as directed by Nebula and in a manner consistent with this Privacy Policy and are prohibited from using or disclosing your information for any other purpose.

Researchers

We may disclose your information (including health and genetic information) to Researchers; however, we will not provide your name and contact information along with any health or genetic information that we share. You can read more about sharing with Researchers and the choices available to you in the “Your Choices” section below.

Independent Laboratory Partners

If you provide a biological specimen (e.g., saliva sample) for sequencing, one of our independent laboratory partners will sequence your genetic information. That independent laboratory partner may also receive your name and contact information in connection with the sequencing services they are performing. We may request that an independent laboratory partner retain your biological specimen on our behalf for future use.

Professional Advisors

We may disclose the information we maintain in the course of our business to professional advisors, such as lawyers, bankers, auditors and commercial insurers, where necessary in the course of the professional services that they render to us.

Compliance with Laws and Law Enforcement; Protection and Safety

We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our websites; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. Please see the “ Security ” section for additional information.

Corporate Transfers

In the event that the Nebula sells or transfers some or all of its businesses, operations, or assets (or enters into negotiations for such a sale or transfer), such as via a merger, consolidation, acquisition, reorganization or sale of assets, or bankruptcy proceeding, the information that we maintain about you (which may include your personal information and information that has been encrypted) typically will be included as part of that sale or transfer. We will make reasonable efforts to require the recipient to honor this Privacy Policy.

Your Choices

Access, Update, Correct or Delete Your Information

An individual who has registered for an account with us may contact us to review, update, correct, or delete the personal information in their account.

Marketing communications

You may opt out of marketing-related emails by following the instructions contained at the bottom of our emails, or by contacting us at support@nebula.org . You may continue to receive service-related and other non-marketing emails.

Online Behavioral Advertising

Some of the business partners that collect information about users’ activities on our websites may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking  here  or the Digital Advertising Alliance by clicking  here .

If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We do not respond to browser-based Do Not Track signals at this time. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com .

Choosing not to share your personal information

You may choose not to provide personal information, including your genetic information, to us. However, we may not be able to provide services to you if we are required to collect your personal information or if we need your personal information in order to provide the services.  We will tell you what information you must provide to receive our services by designating it as required or through other appropriate means.

Similarly, you may choose not to share your personal information, including your genetic information, with Researchers.

Receiving notice before we share your genetic information

If you request to receive notice before we share your genetic information (by selecting this option via the settings available on the website), we will notify you via the website or service at least three days before we share your information in order to provide you an opportunity to direct us not to share your genetic information with the Researcher who requested it. We may also provide notice via additional mechanisms at our discretion, such as via email. The notice you receive will apply only to our disclosure of genetic information with Researchers, and not any other information that we may share with Researchers.

Security

We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it.  These measures include encrypting genetic information at rest and in transit. However, no security safeguards are 100% secure and we cannot guarantee the security of your information.

In the future, we may implement certain security mechanisms that would require multiple individuals to provide independent decryption keys before the genetic information that we maintain could be decrypted. This security mechanism, if implemented, may limit our ability to provide governmental authorities or other parties with access to your genetic information.

Children

Our website and services are not directed to individuals under the age of 18, and we request that such individuals not use our website or services.

International Transfer

Nebula is headquartered in the United States and may have service providers in other countries. Your personal information may be transferred to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

Other Sites and Services

Our websites may contain links to other websites and services.  These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third-party websites or services and are not responsible for their actions. Other websites and services may follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites. We may (and, where required by law, will) also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the service (which may include posting an announcement on our websites).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of our website or service after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Contact Us

If you have any questions or concerns at all about our Privacy Policy, please feel free to  email us at support@nebula.org , or write to us at:

Nebula

Attn: Legal – Privacy

73 Sumner St, Apt. 401
San Francisco CA 94103