At its core, the GDPR enables individuals in the EU to find out what personal data we hold about them, why we hold it, and who we disclose it to. We developed this guide to comply with those guidelines, but customers in all geographies may use this tool to help better understand our information practices and exercise your rights as they relate to held personal data.
What device information do we collect?
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect the following device information:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
How do we use your device information?
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
What personal information do we collect?
Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed.
- Name and Contact Information. When you fill-in our online form, we collect your full name, company, phone number, email address, and any comments given by you.
- Credentials. When you register for an account we collect your full name, email address, and account log-in credentials.
- Payment Data. When you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information, email address, and phone number. We refer to this information as “Order Information.” Credit card information is not stored on our Site and is handled through a PCI-compliant third party payment processor, such as Stripe.
- Other Methods. You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.
- Customer Support and Service. When Customers contact us for support or other customer service requests, we maintain support tickets and other records related to the requests, including any information provided by Customers related to such support or service requests. We may also collect call recordings related to support and customer service-related calls.
How do we use your personal information?
We use the Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:
- Facilitate account creation and login process with your consent;
- Communicate with you;
- Display your name and company information when opted into use with the Phylos Galaxy;
- Screen our orders for potential risk or fraud; and
- When in line with the preferences you have shared with us, provide you with educational information or advertising relating to our products or services.
Will your information be shared with anyone?
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.
We only share and disclose your information in the following situations:
- Order Fulfillment and Payment Processing. We use Stripe for payment processing--you can read more about how Strip uses your Personal Information here: https://stripe.com/us/privacy.
- Service Providers. We work with third-party service providers to provide website hosting & infrastructure, virtual infrastructure, mail delivery, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us, including abiding by policies and procedures designed to protect your information.
- Google Analytics. We use Google Analytics to inform how customers use our Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- Compliance with laws. We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice if a transaction takes place, as well as any choices you may have regarding your information.
Advertising & Marketing Communications
As described above, we use your Personal Information to provide you marketing communications we believe may be of interest to you.
We also may permit certain third-party companies, such as Google or Facebook, to help us tailor advertising we believe may be of interest to you and to collect and use other data about your activities on our Sites and/or Services (e.g., to allow them to tailor ads on third-party services). This type of advertising is also referred to as “retargeting” or “remarketing” and means an advertisement will be shown to you across the internet based on your behavior on our Sites and/or Services. These companies may also deliver ads that place cookies and otherwise track user behavior.
As always we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other third-party advertising system. The practice of remarketing or retargeting advertisements allow us to tailor our marketing to better suit your needs and only display ads that are relevant to you.
- You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Phylos Customer Dashboard account settings, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database.
- Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages related to your customer account activity from us regarding our Services.
- For tailored advertising, you can opt out by visiting Google’s opt-out page (http://www.google.com/settings/ads), the Network Advertising Initiative opt-out page (http://optout.networkadvertising.org) and the Digital Advertising Alliance’s opt-out portal (http://optout.aboutads.info). Please note, you will continue to receive generic ads.
Do not track
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
How is your information stored and secured?
Customer personal data we collect is stored in our database and can only be accessed by authorized individuals with the proper credentials. We use data hosting service providers in the United States to host the information we collect, and we use technical measures to secure your data. While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. In the event that your information has been compromised, we will report the situation to you as soon as possible.
Phylos is fully compliant with Payment Card Industry (PCI) data security standard practices. No credit card data is stored on our servers. All transactions are handled by secure vendors such as Square and Stripe; these vendors act as data processors on our behalf.
How long do we keep your information?
We generally retain your account information indefinitely unless it is requested to be removed by you. In some circumstances, we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.In specific circumstances, we may also retain your personal data for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
- Marketing Preferences: If you have elected to receive marketing emails from us, we retain information about your marketing preferences unless you specifically ask us to delete such information. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. This tracking data does not contain personally identifying information.
- Genotype Profile: As stated in our Data Policy, the genetic information associated with your account will be retained after account removal for research purposes.
- Purchase Records: We retain certain aspects of your account information indefinitely to comply with legal obligations and support internal business operations. This information will not be made available to third parties and will be anonymized wherever possible.
- Aggregate Data: Phylos may also disclose information about you that is not personally identifiable. For example, we may provide our merchants, business partners, or other third parties with reports that contain aggregated data, statistical data, and/or anonymized data.
How can you access and control your information?
There are several options available to you for managing the personal information stored in your Phylos account:
- Access and update your profile information: You can update your personal and company profile information by navigating to your Account Profile and Company Profile on your Phylos account dashboard: http://phylos.bio/sims/dashboard. Here you have access to an overview of all the personally identifying information stored in your account.
- Marketing communications: You may decide to opt-out of marketing communications at any time by updating your account profile or by using the unsubscribe link within each email.
- Galaxy Profile: Navigate to your Phylos account dashboard to edit your Galaxy profile. Your Galaxy Profile information is publicly displayed on Genotype Reports and throughout the Phylos Galaxy. Changes made to your Galaxy Profile will take effect immediately on Genotype Reports, and can take up to two hours to be reflected in the 3D Galaxy.This profile data will be visible on your verified genetic locations in the Phylos Galaxy.
How can you download your information?
To download a copy of your account data, go to https://phylos.bio/sims/export.
How can you remove your personal information?
If you decide that you no longer want access to your Phylos account, you may contact our Customer Success team and request that your account be removed. This process may take up to 30 business days, and will entail the removal of your personally identifying information from our servers and the disabling of future access to our services via your account. (See “How Long Do We Keep Your Information?” above for specifics.)
For California Residents:
Our information practices have been developed to abide with the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act, A.B. 375. For more information, see the full text here.
Limitation on your right of access and data portability
We may share De-identified, Aggregate Information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. Aggregate Information is different from "Individual-level" information and is not personal data because it does not identify any particular individual or disclose any particular individual’s data.
Aggregate information is not personal data, and therefore is not subject to Right of Access or Right to Portability under the GDPR.
Do we collect information from minors?
The Site is not for use by children under the age of 16 years and Phylos does not knowingly collect, store, share or use the personal data of children under 16 years. If you are under the age of 16 years, please do not provide any personal data, even if prompted by the Sites to do so. If you are under the age of 16 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify Phylos to will delete all such personal data.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us using one of the following methods:
Phone: 503-206-6599 ext. 1 for international: +1 503-206-6599 ext. 1
Mailing Address: 959 SE Division St., Suite 500, Portland, OR, 97214, United States