This privacy policy (the “Privacy Policy”) applies to the information collection and use practices of our online services, which are made available to you through a variety of platforms, such as through the Oral Genome Corp.. mobile application (the “App”), our website, located at oralgenome.com (the “Site”), and through our social media accounts on @oralgenome (collectively, “Social Media”), all owned and operated by Oral Genome Corp. (“Oral Genome,” “we,” “us,” or “our”). The App, the Site, and our Social Media accounts are collectively referred to as the “Platform.” We have created this Privacy Policy to tell you what information the Platform collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By visiting and/or using our Platform, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
Key terms
It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | Oral Genome Corp., Oral Genome |
| Our representative | 7720 Rancho Santa Fe Rd, Ste 225 Carlsbad, CA 92009 |
| Personal information | Any information relating to an identified or identifiable individual |
Personal Information We Collect About You
We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Specific Types of Personal Information Collected
- Identifiers, such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Characteristics of protected classifications under California and/or federal law.
- Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- In addition, individually identifiable information that you provide to us for purposes of obtaining medical care from the providers that have contracted with us (the “Providers”) (such information is also referred to as “Protected Health Information” or “PHI”) will also be subject to each Provider’s Health Insurance Portability and Accountability Act Notice of Privacy Practices (the “HIPAA Notice”), which each Provider may make available to you. The HIPAA Notice describes how the Providers can use and share your PHI and also describes your rights with respect to your PHI.
- Biometric information.
- Data generated from our saliva tests
- Geolocation data.
- Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
- Audio, electronic, visual, thermal, olfactory, or similar information.
- Professional or employment-related information.
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA).
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.
How Your Personal Information is Collected
- From third party providers who collect saliva samples from you on the request of you or your Provider(s);
- From publicly accessible sources (e.g., property records);
- Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
- From a third party with your consent (e.g., your bank);
- From cookies on our website; and
- Via our IT systems, including:
- Door entry systems and reception logs;
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; and
How and Why We Use Your Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our Reasons |
|---|---|
| To provide products and services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or Oral Genome. | For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you |
| Conducting checks to identify our customers and verify their identity | To comply with our legal and regulatory obligations |
| Screening for financial and other sanctions or embargoes | To comply with our legal and regulatory obligations |
| Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator | For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you |
| Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring business policies are adhered to, e.g. policies covering security and internet use | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Operational reasons, such as improving efficiency, training and quality control | Any information relating to an identified or identifiable individual |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services [and those of selected third parties] to: - existing and former customers; - third parties who have previously expressed an interest in our services; - third parties with whom we have had no previous dealings. | For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
| External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
The above table does not apply to special category personal information, which we will only process with your explicit consent.
Promotional Communications
We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organizations outside the Oral Genome group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at info@oralgenome.com;
- Using the “unsubscribe” link in emails or “STOP” number in texts; or
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With
We routinely share personal information with:
- Our affiliates, including companies within the Oral Genome group;
- Service providers we use to help deliver our products and services to you, such as Healthcare Providers payment service providers, warehouses and delivery companies;
- Other third parties we use to help us run our business, such as marketing agencies or website hosts;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Credit reporting agencies;
- Our insurers and brokers;
- Our banks
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
Aggregate information
We may share 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. This Information is different from "Individual-level" information and is not Personal Information because it does not identify any particular individual or disclose any particular individual’s data. For example, Aggregate Information may include a statement that "30% of our female users in San Diego County have tested positive for periodontal inflammation," without providing any data or testing results specific to any individual user. Oral Genome will always ask for your consent to share any Individual-level or Self-Reported Information with any third party, other than our service providers as necessary for us to provide the Services to you.
Personal Information We Sold or Disclosed for a Business Purpose
In the preceding 12 months, we have sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under California or federal law;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Biometric information;
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
- Characteristics of protected classifications under California or federal law;
- Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
- Biometric information;
- Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
- Geolocation data;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
- Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Where Your Personal Information is Held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or while we are providing products and services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
- With our offices outside the EEA;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA; or
- Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
If you would like further information, please contact us (see “How To Contact Us” below).
Your Rights Under the GDPR
| Right to Access | The right to be provided with a copy of your personal information (the right of access) |
| Right to Rectification | The right to require us to correct any mistakes in your personal information |
| Right to be Forgotten | The right to require us to delete your personal information—in certain situations |
| Right to Restriction of Processing | The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data |
| Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| Right to Object | The right to object:
|
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.
California Users: Your Rights Under the CCPA (If Applicable)
| Disclosure of Personal Information We Collect About You | You have the right to know:
Please note that we are not required to:
|
| No Personal Information Sold or Used for a Business Purpose | California residents have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. Importantly, we will never sell or disclose your information, so you will never need to opt-out. |
| Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is necessary to:
|
| Protection Against Discrimination | You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things, discriminate via:
|
| Right to Data Portability | The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| Right to Object | The right to object:
|
| Right Not to be Subject to Automated Individual Decision-Making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
It would be helpful to start by explaining some key terms used in this policy:
Do Not Track
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, we do not currently alter our practices when we receive a “Do Not Track” signal from your browser. To find out more about “Do Not Track” you may visit www.allaboutdnt.com.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to Exercise Your Rights
If you would like to exercise any of your rights as described in this Privacy Policy, please:
- Email us at info@oralgenome.com
- Mail use at 7720 Rancho Santa Fe Rd., Ste 225, Carlsbad, CA 92009
If you choose to contact directly by email or in writing, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number if applicable);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.
How to File a GDPR Complaint
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. Please contact your local supervisory authority as appropriate.
Changes to This Privacy Notice
This privacy notice was published on July 31, 2023 and last updated on July 31, 2023. We may change this privacy notice from time to time–when we do, we will inform you via our website or a change to the date at the top of this policy.
How to Contact Us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
| Our contact details | info@oralgenome.com |
| Address | 7720 Rancho Santa Fe Rd., Ste 225, Carlsbad, CA 92009 |
Do You Need Extra Help?
If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).