Privacy Policy

1. What does this Privacy Statement apply to?

This Privacy Statement applies to your Personal Information collected or processed by Verge Analytics, Inc. d/b/a Verge Genomics, and/or its affiliated entities (collectively, “Verge Genomics,” “we,” “us” or “our”), through their websites or other sites that display this Privacy Statement (collectively, the “Site” or “Sites”). This Privacy Statement applies to your Personal Information, which can include information or a combination of information that could directly or indirectly be used to identify you, in particular by reference to an identifier such as a name, an email, an online identifier, and any other information collected from or about you (hereinafter, “Personal Information”). Please note, the definition of Personal Information can vary by jurisdiction. If we collect information from you that is considered Personal Information in your jurisdiction, we will treat it as such in accordance with this Privacy Statement.

Please read this Privacy Statement carefully to understand our policies and practices regarding your Personal Information and how we will treat it. This Privacy Statement may change from time to time. We will notify you of material changes to this Privacy Statement by posting a notice on our home page for a reasonable period of time and changing the “Last Updated” date above. Please check it periodically for updates.

2. What categories of Personal Information do we collect and process?

We may collect or process various categories of Personal Information that you provide to us. We may disclose Personal Information to service providers or licensing partners for business and legal purposes. This may include the following categories of Personal Information:

(a) Contact Information Identifiers

Identifiers sourced directly from you or from third party service providers. They may be used to provide and improve the features, products and services you request; to communicate with you and provide you with information; to provide you with personalized content and other information on our products or affiliates; when we perform our obligations under a contract with you; to deliver relevant advertising; and/or for research purposes.

(b) Records

Personal Information categories contained in records are sourced directly from you. They may be used to provide and improve the features and services you request; to communicate with you and provide you with personalized content, information and other information on our products or affiliates; and when we perform our obligations under a contract with you; to deliver relevant advertising; and/or for research purposes.

(c) Internet Activity

Internet or other similar network activity is sourced directly or indirectly from you (e.g., from observing your actions on our Sites) or from third party service providers, such as a data analytics provider. They are used to provide and improve the features, products and services you request; to provide you with personalized content and other information on our products or affiliates; and/or to deliver relevant advertising.

(d) Third Party Sources

We may collect information from third party service providers or other sources. This data may be combined with other information that we collect and used for the purposes described in this Privacy Statement. Likewise, certain third-party service providers on our Sites may collect Personal Information about you when they are performing services on our behalf and/or when you are using certain functions on our Sites that are operated by these third parties. Any information, including Personal Information, collected by such third-party service providers will be subject to those third parties’ privacy notices or privacy policies, rather than this Privacy Statement.

3. What specific pieces of Personal Information may be collected?

(a) Personal contact details

Including information such as names, addresses, telephone numbers, or e-mail addresses, such as when you provide them to us when doing business with or otherwise engaging with us. Some Sites may allow you to establish a username and password to set up an account, in which case login credentials will also be collected.

(b) Information collected from our Sites and social media pages

This includes information collected when you interact with us, such as comments, photos, or other information that you post through blogs, message boards, or social networking opportunities or other interactive forums, as well as information that you may provide when making an inquiry about our products and services, such as estimated budget ranges.

(c) Internet activity and device data

Your Internet Protocol (IP) address or device identifier and associated general geographic location, your device’s operating system, browser type, websites visited before or after you visit our Site, pages viewed and activities at our Site, as well as your interaction with advertisements that may appear on our Site.

(d) Third-party collection

Third-party service and advertising partners may also collect information automatically.

(e) Other information

Other information we have collected from you with your consent.

4. Why do we collect and how do we use your Personal Information?

We may use your Personal Information for a variety of legitimate purposes including:

(a) Providing the features, products and services you request

We may use the Personal Information we collect about you to fulfill your requests for, and enable your use of, our features, products and services.

(b) To communicate with you and provide you with information

We may use your Personal Information to communicate with you, to respond to your questions or comments, and to provide you with updates and news.

(c) To provide you with personalized content, offers, and other information

We may use your Personal Information to provide you personalized offers and content. Where required by law, we ask visitors providing e-mail addresses to indicate if they would like further information or updates from us, such as information about our available products and services. We also offer visitors an “opt-out” option if they wish to cease receiving e-mails or other information from us. In some circumstance you may be asked to “opt-in” before we contact you in certain ways or before certain services may become available.

(d) When we perform our obligations under a contract with you

We may use your Personal Information to carry out our obligations under any agreement that we may have with you.

(e) To improve the features, products and services that we offer through the Site

We may use the Personal Information that we collect to improve Verge Genomics’ products and services, as well as our Sites and features.

5. How do we share and disclose your information?

We may share or disclose your Personal Information:

1. With vendors or agents. For example, we may share your Personal Information with companies we have hired to provide services on our behalf. When we share Personal Information with these other companies to provide services for us, they are not allowed to use it for any other purpose and must keep it confidential unless you otherwise consent.
2. Where your Personal Information may be transferred along with other business assets.
3. Where we have received your direction or consent to the disclosure of your Personal Information.
4. To comply with the law or respond to legal process or lawful requests, including from law enforcement and government agencies.
5. To conduct investigations of consumer complaints or possible breaches of law, to protect the integrity of the Site, to fulfill your requests, or to cooperate in any legal investigation.
6. To protect the rights or property of Verge Genomics’ or our customers, including enforcing the terms governing your use of the services.
7. To act on a good faith belief that access or disclosure is necessary to protect the safety of our associates, customers or the public.
8. To support other legitimate business purposes including but not limited to legal compliance.

Please note that the Sites may include links or otherwise refer to third-party websites whose privacy practices may differ from our privacy practices. If you submit Personal Information to any of those websites, your information is governed by the privacy policies on those websites. We encourage you to review the privacy policy of any website you visit. We may share anonymized or de-identified information we collect under any of the above circumstances. We may also share it with third parties to develop and deliver targeted advertising on the Sites, and on websites of third parties. We may combine anonymized or de-identified information we collect with additional anonymized or de-identified information collected from other sources. We also may share aggregated and anonymized information with third parties, including advisors, advertisers, and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Site and the most popular features or services accessed.

6. What about children’s privacy?

The Sites are intended for adults over the age of 18. We may ask visitors to enter a birth date to restrict those who are underage from accessing certain services, websites, areas or features. If you become aware that a child under 13 has registered for any email newsletters, or otherwise provided us with their Personal Information, please report the use to dataprivacy@vergegenomics.com. If we become aware of a user under the age of 13 providing information on our Sites, we will purge our databases of all Personal Information provided by that user to the extent feasible.

7. Cookies notice

(a) What are cookies and how do we use them?

“Cookies” are data files that a website sends to your computer while you are viewing the site. These data files include information that allows our Sites to remember important information that will make your use of the Sites more efficient and useful to you. Our Sites may use cookies for a variety of purposes. We may use cookie technology and IP addresses to obtain information from online visitors and to provide visitors with the best possible personalized online experience. Information obtained via cookies may include Personal Information.

Visitors to our Sites use different web browsers and different computers. To make your visits as easy as possible with the technology you use, we may automatically keep track of the type of browser (e.g., Internet Explorer) and operating system (e.g., Windows, Mac) used by a visitor, and the domain name of the visitor's Internet service provider. We may also track the total number of visitors to our Sites in an aggregate form to allow us to update and improve our Sites. This data tells us if more visitors prefer certain features or areas to others, which helps us keep our Sites fresh and interesting to the majority of our visitors.

(b) How do we use cookies to personalize your experience at our sites?

Cookie technology helps us deliver content tailored to a visitor’s interests and allows us to make the functions of our sites easier for our visitors. Sites that offer online shopping use cookies to remember and process the items in your shopping cart, for example. Where appropriate under our disclosed practices and policies, we may associate Personal Information with a cookie file in such instances.

(c) Do third parties use cookies on our site?

We do not allow third party cookies on our site, whether for advertising or other purposes.

(d) Different types of cookies used by us

• Strictly necessary cookies let you move around the Site and use essential features. These cookies don't gather any information about you that could be used for marketing or remembering where you've been on the Internet.
• Performance cookies collect information about how you use our Site, e.g., which pages you visit, and if you experience any errors. These cookies don't collect any information that could identify you – all the information collected is anonymous and is only used to help us improve how our Site works, understand what interests our users, and measure how effective our advertising is.
• Functionality cookies may be used to provide services or to remember settings to improve your visit.
• Targeting cookies may be linked to services provided by third parties, such as ‘Like’ buttons and ‘Share’ buttons. The third party provides these services in return for recognizing that you have visited our Site.

(e) What are web beacons and how do we use them?

Some of our Site pages and e-mail updates may contain electronic images called Web beacons, sometimes known as one pixel GIFs, clear GIFs or pixel tags. On the Sites, these allow us to count visitors who have viewed our pages. In promotional e-mail messages/newsletters, they allow us to count how many users have read them. Web beacons allow us to develop statistical information about the activities and features that most interest our consumers for the purpose of providing more personalized content. They are not used to access your Personal Information without your consent.

(f) How can you opt-out of cookies?

If you don't want cookies, you can set your operating system to warn you each time a cookie is being sent or turn off all cookies through your browser (e.g., Internet Explorer or Firefox). Check your browser HELP menu to learn the correct way to change or update your cookies. Alternatively, you may wish to visit other sources which contain comprehensive information on how to do this on a wide variety of browsers. You can also look up details on how to delete cookies from your system as well as more general information about cookies. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual. Please be aware that restricting cookies may impact the functionality of Verge Genomics Sites.

(g) How we respond to Do-Not-Track disclosures

We do not support “Do Not Track” browser settings and do not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your Personal Information.

8. What else do you need to know?

(a) Where is your information stored and processed?

Personal Information collected on our Site or received by Verge Genomics from you or third parties may be stored and processed in the United States or any other country where we or our service providers maintain facilities. The servers and databases in which Personal Information may be stored may be located outside the country from which you accessed the Site and in a country that does not have the same privacy laws as your country of residence. The Personal Information you provide us may be transmitted abroad in accordance with legal requirements, but we will collect, process and use personal information only in accordance with this Privacy Statement.

By visiting the Site and submitting information, you consent to such collection, processing, transfer and/or storage of any Personal Information that you submit. Please note: our policies may differ by region, so if you visit one of our Sites in a different region, please check to see if there is a Statement specific to that location.

(b) How long do we store your Personal Information?

We retain and store your Personal Information only for as long as we have a legitimate business purpose to do so and in accordance with our data retention policies.

(c) What about Personal Information that is publicly available (such as in chat rooms, message boards, or other interactive forums)?

We may offer chat rooms, message or bulletin boards, or interactive areas where visitors may post comments or information for our visitors’ enjoyment. If there is a chat room, bulletin or message board, social networking opportunities or other interactive areas where Personal Information may be posted at this Site, be sure to check posted rules before entering, as you will be bound by them as well as our Terms of Service. Anything you post online is public information, and we are not responsible for anything you voluntarily post online. Users should exercise caution when disclosing Personal Information online.

(d) How do we safeguard your Personal Information?

We have implemented administrative, physical and technical safeguards designed to protect your Personal Information. No security measures can be 100% secure, however, and so we recommend that you take additional measures to protect yourself and your Personal Information, including by installing up-to-date anti-virus software, closing browsers after use, keeping confidential your log-in credentials and passwords, as applicable, and making sure that you regularly update software and apps you have downloaded to ensure you have enabled the latest security features on your devices.

(e) Individuals in the European Union, European Economic Area, United Kingdom, and Switzerland

The purpose of this section is to provide information and additional provisions that apply regarding Verge Genomics’ processing of Personal Data of persons located in the European Union (“EU”), European Economic Area (“EEA”), United Kingdom (“UK”), and Switzerland in accordance with the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation (collectively referred to herein as the “GDPR”). THIS SECTION ONLY APPLIES TO YOU IF YOU ARE LOCATED IN THE EU, EEA, UK, OR SWITZERLAND. In the event of a conflict between this section and the remainder of the Privacy Notice, this section shall control for those persons located in the EU, EEA, UK, or Switzerland. Terms used but not defined herein have the same meanings set forth under the GDPR.

Legal Basis for Processing

Our legal basis for processing the Personal Data (as defined in the GDPR) described in this Privacy Notice will depend on the Personal Data concerned and the context in which we process it. We process Personal Data from you:

• where we need it to perform a contract with you;
• where the processing is in our legitimate interests (including the purposes described, above, in “Why do we collect and how do we use your Personal Information?”);
• where the processing is necessary for us to meet our applicable legal obligations; or
• if we otherwise have your consent.

Marketing

Verge Genomics does not process Personal Data for the purpose of marketing without first obtaining your express, opt-in consent or having a legitimate interest for doing so. You have the right to object to the processing of personal data for marketing purposes at any time by contacting us at support@vergegenomics.com.

Special Category Personal Data

“Special Category Data” is any data that reveals your racial or ethnic origin, political opinions, religious, moral or philosophical beliefs, trade union membership, political views, genetic data, biometric data for the purpose of identifying a person, and data concerning health or a person’s sex life and/or sexual orientation. When we collect such data, we will only do so after obtaining your prior express consent.

Automated Decision Making

Verge Genomics does not make any automated decisions on your behalf or about you without first obtaining your express, opt-in consent. In the event we secure your consent to do so, you have the right to object to the processing of Personal Data via automated decision making at any time by contacting us at support@vergegenomics.com.

Transfers to Third Parties and Countries

Personal Data that we collect or receive may be transferred to and/or processed by third parties that are located outside of the EU, EEA, UK, or Switzerland, some of which EU, EEA, UK, and Switzerland authorities may not consider to have an adequate level of protection for Personal Data. Verge Genomics will only transfer data subject's Personal Data to third parties located outside of the EU, EEA, UK, and Switzerland when it has ensured appropriate safeguards for such Personal Data through use of the standard contractual clauses or other approved methods.

Your GDPR Rights

Pursuant to the GDPR, you have the right to:

• Request access to your Personal Data.
• Request correction of your Personal Data.
• Request erasure of your Personal Data. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Data.
• Request restriction of processing of your Personal Data.
• Request the transfer of your Personal Data to you or to a third party.
• Withdraw consent at any time where we are relying on consent to process your Personal Data.

To exercise your GDPR privacy rights, please submit a request to us at dataprivacy@vergegenomics.com. Depending on where you are located, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your Personal Data. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.

9. What are your California privacy rights?

California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below and put “Data Subject Request” in the subject line of your request.

10. What should you do if you have questions or want to contact us?

We take steps to keep your Personal Information accurate. Where our processing of your Personal Information is based on your consent, you may have the right to withdraw your consent by contacting us. Note that your withdrawal of consent will not affect the lawfulness of our processing of your Personal Information based on your consent prior to your withdrawal.

We are intent on resolving any issues relating to our handling of your Personal Information, and you may contact us at any time regarding any questions or concerns. We are committed to working with you to resolve any complaints you may have regarding this Privacy Statement or the treatment of your Personal Information. If you have a concern, please contact us and your communication will be promptly addressed. You may contact us by emailing dataprivacy@vergegenomics.com.