Privacy Policy

Details of our privacy policy

Your privacy is extremely important to us. This privacy policy will explain how we collect and use the information that you provide to us.

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Collection and use of information

Navigenics collects a variety of information regarding your use of our website and services, including personally identifiable information. The "personally identifiable information" addressed by this policy refers to the following:

• "Your Account Information" means the information that you or your physician provide to us when creating or updating your Navigenics account, or purchasing our services, that can be used to uniquely identify you, such as your name, telephone number, email address, billing/shipping address or credit card number.
• "Your Genetic Data" means the genotyping results that we generate for you or your physician through our services (namely, the set of "A"s, "G"s, "T"s and "C"s at particular locations in your genome) but only to the extent such results, by themselves or when linked to other personally identifiable information, are sufficient to uniquely identify you.
• "Your Phenotype Information" means your gender, your birth date and, optionally, other personal information about you that you or our physician may voluntarily provide to us, which may include your ethnicity/ancestry, the geographic regions where you or your ancestors have lived, any diseases or other health conditions that run in your family, and personal traits such as height and weight.

We collect and use Your Account Information and other personally identifiable information about you to authenticate your use of our website and services, to process your purchase transactions, to provide you with the services you or your physician have requested, to communicate with you or your physician, and to send you or your physician relevant information and materials. However, we will not, without your explicit consent, disclose or share personally identifiable information about you with third parties except as required to provide the services you have requested, in the event Navigenics is acquired by or merges into another company, or as otherwise required by applicable law. We limit access to Your Account Information and other personally identifiable information about you to appropriate Navigenics personnel on a need-to-know basis.

Navigenics may freely collect, use and disclose any non-personally identifiable information collected on our website, unless otherwise prohibited by this privacy policy or applicable law. This information may include your computer's internet protocol (IP) addresses and cookies which are placed on your computer when you access our website (see the cookies section below), as well as the date and time, your computer's operating system and web browser type, the identity of your internet service provider, and a list of web pages you have visited. In some cases, this information is collected automatically and stored in log files. Navigenics contracts with third-party web analytics companies to help us use this information, which is not intended to uniquely identify you, to track and analyze aggregate usage volume and patterns regarding our website. Under certain circumstances, we may need to review this information in combination with Your Account Information to identify and resolve an issue regarding your access to our website.

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Research

Navigenics believes in bringing you the highest quality service available and helping further scientific and medical research. To that end, we may analyze our members' genetic data and associated phenotype information on an aggregated basis and de-linked from any member account information, to:

• Improve the quality and features of our website and services
• Provide our members with new and more accurate analysis of genetic data
• Discover or validate associations between certain genetic variations and certain health conditions or traits, as well as other insights regarding human health
• Publish our findings and insights without disclosing Your Genetic Data in a quantity sufficient to uniquely identify you, and without otherwise disclosing your identity

As the number of our members grows, potentially surpassing the size of currently available public data sets that we use to calculate risk estimates, our ability to study the aggregated genetic data and phenotype information we have collected from our members, and to publish our findings and insights, will help us to further the advancement of scientific and medical research and fulfill our mission to help you live healthier, longer.

We may also give you the opportunity to contribute your genetic information to science. If you elect to contribute your genetic information to science through the Navigenics service, you allow us to share Your Genetic Data and Your Phenotype Information (de-linked from Your Account Information) with not-for-profit organizations who perform genetic or medical research, and you allow such not-for-profit organizations to separately or jointly publish study results that include Your Genetic Data and Your Phenotype Information (but not Your Account Information), in peer-reviewed scientific and medical journals and otherwise, and to deposit such data and information into public data repositories or otherwise make them publicly available to the extent required by such journals.

If you elect not to contribute your genetic information to science through the Navigenics service, we will not share Your Genetic Data or Your Phenotype Information with such organizations.

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Cookies

Navigenics uses a combination of session and persistent cookies to track your navigation and use of our website, and your web browser must be configured to accept cookies in order for you to create a Navigenics user account and access many of the features on our web site. Cookies are small pieces of information that are stored by your web browser on your computer's hard drive. Our cookies enable us to facilitate access to different aspects of your account across our website, and to enhance your experience on our website. For example, by showing when and how you and other users visit our website, cookies help us to see which pages of the website are particularly helpful to customers for providing information. This helps us improve our website, because we can eliminate pages that are unpopular and update and improve those pages that are visited frequently. Cookies also improve your ease of using our website, for example, by remembering your address or ordering information when you request information or services on our website. We also use cookies to securely link your Navigenics account with the computer you used to set up your account; if you choose to access your account from another computer, you will be asked to follow additional steps to verify your identity.

Please note that session cookies expire automatically when you close your computer's web browser, whereas persistent cookies are stored on your computer's hard drive until deleted. If you set up or access your Navigenics account from someone else's computer, or a publicly accessible computer, we recommend that when your session is complete you delete any persistent cookies on the computer by following the web browser's instructions and then close the web browser.

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Communications from us

We will be sending at least three types of emails: emails required to provide you with services you have requested; alerts giving you relevant and new information about service updates; and emails informing you about promotional services. Alerts and promotional email messages will contain a link that will allow you to opt out of future mailings.

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Advertising

The Navigenics Health Compass is not an advertising-subsidized service. Navigenics does not derive revenue from the use of banner advertisements. However, we may describe our collaborators' products and services on our website or in our communications to our members from time to time, and we may feature links to our collaborators' websites.

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Privacy practices of third-party websites

This website may contain links to other websites. Navigenics is not responsible for the privacy policies or practices of any third-party websites, including websites of any sponsors, collaborators or linked websites, or for the privacy policies or practices of any other third parties. To the extent that you disclose personally identifiable information to any collaborator websites, linked websites or other third parties, different rules may apply to their use or disclosure of any personally identifiable information you disclose to them, and we encourage you to review their privacy policies before disclosing personally identifiable information to them.

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Minors

This website is not directed toward minors under 18 years of age. Given the ethical, privacy and informed consent considerations regarding genetic testing of minors for predisposition or carrier status of adult-onset genetic disorders, Navigenics does not knowingly collect or use information from minors under the age of 18.

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Legally required disclosure

We may be legally compelled in the future to disclose personally identifiable information about you to satisfy a court order, subpoena, government request, law, regulation or other legal process. We will use reasonable and lawful efforts to limit the scope of any such legally required disclosure, and we will make every attempt to notify you in advance insofar as we are legally permitted to do so.

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Termination of your account

If you do not renew your account subscription with Navigenics, or if at any time you request us to terminate your Navigenics user account, we will delete Your Genetic Data and Your Phenotype Information within 90 days from all operational Navigenics systems, and Your Genetic Data and Your Phenotype Information will not be included in any future archive of these systems, unless we are required by applicable law to retain any such data and information, in which case we will do so only for so long as required, and only for the purposes of such law. However, we will not be obligated to delete your Genetic Data or Your Phenotype Information from historical archives of our systems.

Upon account termination, you will be given an opportunity to withdraw your consent for us to use Your Genetic Data and Your Phenotype Information (de-linked from Your Account Information) for our internal research purposes as described above. If you previously have elected to contribute your genetic information to science through the Navigenics service, you will also have the opportunity upon account termination to withdraw your consent for not-for-profit organizations to begin new studies using Your Genetic Data and Phenotype Information after the 90-day period. However, Your Genetic Data and Your Phenotype Information will not be removed from any ongoing or completed studies or publications in which Your Genetic Data or Your Phenotype Information was utilized.

Finally, we may retain Your Account Information solely to the extent required for our accounting and compliance purposes, and as otherwise required by applicable law.

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Changes to this Privacy Policy

Navigenics reserves the right to modify or amend this privacy policy at any time. Any material changes will be conspicuously posted on this website, and we will notify members by email. Changes will be effective 30 days after posting to this website and email notification.

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Viewing and changing your Personal Information

As a Navigenics account holder, you may view or change Your Account Information online by signing into your account at www.navigenics.com and clicking on the Manage Profile link in the top right corner of the page. You may also correct Your Account Information by sending email to Navigenics Member Service at memberservice@navigenics.com, or by phoning Navigenics Member Service at (866) 522-1585.

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Contacting Us

If you have any questions or concerns regarding this Privacy Policy, or if you wish to have access to or request corrections or updates to personally identifiable information in our records, please contact:

Chief Privacy Officer
Navigenics, Inc.
(650) 585-7700
privacy@navigenics.com

EFFECTIVE DATE: June 19th, 2009

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