When we provide our Services to you, we collect your/your child’s individualized Personal Information which includes:

• De-identified Information: This includes information that has been stripped of identifying data to the extent that a person can no longer reasonably be identified.
• Purchaser Information: This includes information that you provide when you purchase our services including: your name, payment information and shipping address.
• Registration Information: This includes information that you provide to us when you activate your/your child’s account. This may include: your name, your child’s name, your child’s date of birth, your child’s sex at birth, confirmation that your child is healthy.
• Genetic Information: This includes the genetic data and reports we provided to you in connection with our Services.
• Sample Information: This includes information regarding the saliva sample that you provide to us that we analyze in order to determine your Genetic Information.
• Self-Reported Information: This includes information that you provide to Nurture such as your birth sex, gender, health-related information including medical history, or anything else you provide to us as we provide you our Services.
• User Content: This includes information, data, text, messages, or other materials (other than Genetic Information and Self-Reported Information) that is generated by users of our Services and transmitted to or through Nurture. For example, exchanges you may have with our customer support team.
• Web-Behavior Information: This includes information on how you or your devices use our Services and is collected through log files, cookies, web beacons, and similar technologies. This includes, but is not limited to, your device information, device identifiers, your IP address, your browser type, or your location.

Aggregate Information is not the same as Personal Information. Aggregate Information does not contain information about a specific individual and it cannot reasonably be linked to a specific individual. Aggregate Information is information about a group of people.

• From You: We collect the information you provide to us when you request or purchase our Services, register for our Services, use our Services or otherwise interact with us.
• From Service Providers: At times, we may collect information through service providers who use tools such as cookies, web beacons, pixels, and tags when you visit or interact with our Services. For more detail on how we collect and use Web-Behavior Information, please see our Cookie Policy.
• From Other People: We may receive information about you from other individuals, who you may or may not know. For example, if someone purchases a testing kit for you or your child as a gift, we may collect information about you.

We use your information to:

• Provide our Services. This includes operating, improving, maintaining, and protecting those Services, as well as developing new Services
• Analyze any trends and usage of the Services
• Communicate with you and to share information we think may be relevant to you
• Personalize, contextualize and market our Services to you
• Provide cross-context behavioral or targeted advertising
• Prevent fraud or other unauthorized use of our Services
• Investigate conduct that violates our Terms of Service
• Conduct surveys or polls
• Comply with our legal or other statutory or regulatory obligations
• Conduct research on de-identified data
• Engage in structured commercial activities involving de-identified data, including the sale or other transaction which allow access to such data, under legally permissible circumstances which preserve the de-identified nature of the data

What is Nurture research?

The purpose of Nurture’s research is to investigate how genetic variants influence the onset of disease, and the symptoms that individuals may manifest, as well as the impact of early identification on treatment and outcomes. Nurture research includes activities performed by Nurture, both independently and through partnering with third parties, and is overseen by what is known as an Institutional Review Board, where necessary. Some of the third parties we may partner with to conduct research include, but are not limited to, non-profit foundations, academic institutions, or pharmaceutical companies. The research that we provide is fundamental to our purpose. Research will be conducted using de-identified data. If you do not wish your de-identified data to be used for research, then you should not use our Services.

How we protect your information in research?

Research is conducted with de-identified Information. De-identified data has been stripped of identifying data to the extent that a person can no longer reasonably be identified. You can read more about protections for your data in our Consent.

Who we share with:

Our Service providers: We contract with certain third-parties in order to provide our Services to you. When we do, we include contractual terms with these third-parties to ensure that your Personal Information is kept secure and confidential. Some of the reasons we may contract with these third-parties include but are not limited to: fulfilling your order; processing or analyzing your Sample Information; providing you with customer support; cloud storage, IT and security; or marketing.

Transactions and Affiliates: If Nurture becomes involved in a merger, acquisition, reorganization, or other transaction, your Personal Information may be accessed, sold, or otherwise transferred in connection with that transaction. We may also disclose Personal Information about you to our corporate affiliates to help operate our services and our affiliates’ services.

Your sharing choices: You may direct us to share your Personal Information with friends, family members, doctors or other healthcare professionals, and/or any other individuals or entities who may or may not be using our Services. If you share your Personal Information with a third party, they may use your Personal Information differently than we do under this Privacy Statement. Please make such choices carefully and review the privacy policies of all other third parties involved.

Third parties related to law, harm, or other public interest: Nurture will not provide information to law enforcement unless required by law and will exhaust any available legal remedies to protect your privacy. If we are nonetheless compelled to disclose your Personal Information to law enforcement, we will seek to provide you with prior notice unless we are prohibited from doing so by law. Nurture will preserve and disclose information if required by law or if we have good faith belief that doing so is necessary to: (1) comply with a legal or regulatory process; (2) enforce our Terms of Service or other policies; (3) respond to a claim that a third-party’s rights have been violated; or (4) protect the rights, property, or safety of Nurture, including our employees, contractors, other personnel, users, and the public. This Privacy Statement is not intended to limit any legal defense or objection you may have to a third party’s request to disclose your Personal Information.

Who we do not share with:

• Publicly-available databases
• Insurance companies or employers
• Law enforcement, absent a valid court order, subpoena, or search warrant

Security

Nurture implements specific physical, technical, and administrative measures in order to prevent unauthorized access or disclosure of your Personal Information. We perform regular reviews and assessments for the purpose of keeping our security policies and procedures up-to-date and ensuring the integrity of our systems. Despite these measures, you must also take responsibility in protecting your Personal Information. This means keeping your password and other authentication information secure and notifying us if an unauthorized person uses your login credentials. Nurture employees, contractors, and other personnel are not able to view your password and we encourage you not to share your password with us or anyone else.

Federal and State Information

Residents of California and other states may have other specific privacy rights.

If you are a California resident, you have certain additional rights related to information that we collect about you. Nurture Genomics has collected the following categories of personal data from consumers within the last twelve (12) months:

• Contact Information (name, email and postal address)
• Online Identifiers (IP address, cookie IDs)
• Demographic Information (age, race, gender)
• Internet Activity Information
• Audio Information (voicemail and other call recordings)
• Genetic information
• Medical Information

Your California Rights

• Right to Notice. Before or at the time we collect personal data from you, you have the right to receive notice of the personal data to be collected and the purposes for which we use it. This Notice is intended to satisfy this requirement.
• Right to Know. You have the right to request that we provide you with the following
  • The categories of personal data we have collected about you;
  • The categories of sources from which we have collected personal data about you;
  • The business or commercial purpose for collecting your personal data;
  • The categories of third parties with whom we share personal data;
  • The specific pieces of personal data we have collected about you; and
  • The categories of personal data that we have disclosed about you for a business purpose.
• Right Not to Be Subject to Discrimination. You have the right to be free from discrimination or retaliation for exercising any of your rights under the California Consumer Protection Act (CCPA), including the rights listed above.

Please note that Nurture Genomics may not be required to fulfill your requests in certain circumstances. These include instances where we must retain or restrict access to personal data in order to preserve scientific integrity, as your personal data must be managed in specific ways in order for the information to be reliable and accurate and to meet regulatory obligations of Nurture Genomics and its affiliates.

Additionally, Nurture Genomics is not required to provide information in response to a request to know for a particular consumer more than twice in any given twelve-month period.

When you submit a request to exercise your right of access, your right to deletion, or your right to know, we are required to verify that you are who you say you are. We may request that you provide additional personal data for the verification process.

To exercise the rights described above, to file a concern or complaint, or to opt-out of particular programs, please contact support@nurturegenomics.com or call 888-343-1632.

Federal and certain state laws (including the federal Genetic Information Non-discrimination Act) may provide protection from discrimination by an employer or health insurance provider based on your genetics. Contact us at support@nurturegenomics.com if you wish to learn more about these protections.

Special Notice Regarding International Transfer of Personal Data

Nurture Genomics is a United States corporation based in Cambridge, Massachusetts. Nurture Genomics uses web servers and stores data in the United States [or in other countries]. We may transfer your personal data to our service providers and others located in any of these countries for the purposes described in this Statement. Different countries have different privacy laws and requirements, and some provide less legal protection for your personal data than others. Please know, however, that no matter where your personal data is collected or processed, if it was collected through an Nurture Genomics Website, we will ensure that it is protected by the terms of this Policy and any privacy notices or click-through agreements that apply to you. By using this site, you are consenting to the collection, use, and transfer of your personal data in or to the United States or any other country in the world.

Children

The Nurture Genomics Website is not directed to children under the age of thirteen (13), and we request that these individuals not provide personal data through the Nurture Genomic Website. The Nurture Genomic Website, its content, and its services are intended for individuals over the age of 13. The Nurture Genomic Website is not directed to, nor do we knowingly collect information from, children under the age of 13. If we actually know that a user under the age of 13 has volunteered personal data on the Nurture Genomic Website we will delete such information from our records. If you become aware that your child or any child under your care has provided us with personal data, please contact us at the contact information listed below.

Retention of Personal Information

Nurture will retain your Personal Information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, enforce agreements, or for other legitimate and lawful business purposes.

Nurture and our contracted laboratory partners will retain your Genetic Information, date of birth, and sex as required by the federal Clinical Laboratory Improvement Amendments of 1988 (CLIA) and any required accreditation requirements. Nurture will also retain limited information related to your use of our Services as required by law, our contractual obligations, or as necessary to establish, exercise or defend legal claims and for audit and compliance purposes.

Changes to this Privacy Statement

We may make changes to this Privacy Statement from time to time. If we make material changes to how we treat your personal information, we will notify you by emailing the address specified in your account and/or through a notice on our Website.

The date this Privacy Statement was last revised is communicated at the top of this Privacy Statement. You are responsible for ensuring we have an up-to-date active and deliverable email address, and for periodically visiting our Website and this Privacy Statement to check for any changes.

Contact Information

If you have questions about this Privacy Statement, or have a complaint or inquiry, please email us at support@nurturegenomics.com or call us at 888-343-1632.