Last Modified: November 30, 2020
- What Information Do We Collect?
- How Do We Use Your Information?
- When Do We Share Your Information?
- What Choices Do You Have About How We Use and Share Your Information?
- How Do You Access, Correct or Remove Your Information?
- How Do We Keep Your Information Secure?
- Information for California Residents
- Questions or Comments
Your privacy is a top priority to Helix.
What Information Do We Collect?
We collect several types of information from and about users of our Services. When you contact us, create a Helix account, access or utilize our Services, make a purchase, or register to receive alerts or other information, we may collect personal information that you provide to us. We may also collect information from you, our DNA Product Partners, our Research Partners, or our service providers in connection with our website, products, Services, and research initiatives in ways that we describe at the time of collection or otherwise with your consent.
Account and Personal Demographic Information and Identifiers
You must provide certain information when you create an account or make a purchase on the Helix Platform in order to receive our Services (“Account Information”). This information includes:
- identifiers such as your name, email address, username and password, shipping address, and phone number;
- commercial information such as credit card or other payment information, and information about the products you searched for other otherwise expressed an interest in;
- demographic information such as date of birth and biological sex (for quality control when sequencing); and
- records and copies of any correspondence with you and details of any transactions you carry out through our Services.
Helix or our Partners may ask you to provide data about yourself (your “Self-Reported Information”), including identifiers, demographic information, personal and family medical history, descriptions of physical features such as eye color or behavioral information such as exercise habits, communication preferences, or self-declared ethnicity.
- Preferences or Inferences. Helix may also draw preferences or inferences from personal information, such as information used to offer you products or opportunities to participate in research studies in which you may be interested.
You may provide us with one or more saliva samples, using our Helix DNA Kit, to allow us to isolate DNA and perform Genomic Analysis on that DNA. You may also provide us with your Uploaded Data (as we describe in our Data Upload Consent) when Helix makes that feature available from time to time. In connection with our Services, Helix performs Genomic Analysis on your DNA and/or your Uploaded Data to produce your Genetic Information and provide you with insights.
Computer, Device and Browsing Information
As you interact with our Services online (including the Site and Helix Platform), we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and usage patterns, which can include identifiers, internet or other electronic network activity information, or preferences. This data may include:
- Details of your visits to our Services, which could include:
- the resources that you access and use on the Services;
- the external sites that referred you to our Services; and
- the external sites that you visit by clicking on a link on Helix.com.
- Information about your computer or device and internet connection, which could include:
- your IP address or other device ID;
- your operating system; and
- your browser or device type.
The information we collect helps us to improve our Services. It also helps us to deliver better and more personalized features to you by enabling us to recognize you when you return to our Services, by storing information about your preferences, and customizing our Services according to your individual interests.
If you have purchased a product as a gift for someone else, we may collect identifiers, commercial information, or computer, device, and browsing information about you in connection with your purchase. Your gift recipient must create their own account. Helix will not share any personal information of the gift recipient with you.
Our Services are not intended for anyone under 18 years of age. We do not knowingly collect personal information from or on behalf of someone under 18. If you are under 18, do not register on our website or provide any information about yourself to us. If we learn we have collected or received personal information from or on behalf of someone under 18, we will make commercially reasonable efforts to remove the information and/or user account and not make future use of that information to contact a minor. We do not sell the personal information of minors. If you believe we might have any information from or about someone under 18, please contact us.
How Do We Use Your Information?
Helix will use information that we collect about you for the following purposes:
To present, provide, and improve our Services
We primarily use your identifiers, demographic, commercial, internet or other electronic network activity information and preferences to present and provide our Services to you. This includes the following:
- providing you appropriate search results and personalized content;
- processing your purchases;
- verifying your identity;
- recognizing you when you return to our Services;
- providing you notices about your account;
- notifying you about updates or changes to our Services or any DNA Product Partner or other third party services we offer or provide through the Helix Platform; and
- providing you with information or services that you otherwise request from us.
To improve our Services or to develop and provide new products and services, we may use your Self-Reported Information, identifiers, demographic information, commercial information, and internet or other electronic network activity information and preferences as follows:
- to track your usage of our Services;
- to administer a survey;
- to perform quality control and quality improvement activities;
- to conduct data analysis about users of our Services, our audience size, and usage trends;
- to conduct marketing campaigns and targeted online advertising; and
- to monitor the success of our marketing activities.
To improve our Services or to develop and provide new products and services, we may also use your biological sample and genetic information, stripped of direct identifiers, as follows:
- to perform quality control and quality improvement activities;
- to conduct aggregated data analysis about users of our Services; and
- to improve and optimize our genomic sequencing, lab, processes, and Services.
With your consent for DNA Products or Research Programs
With your consent, we do the following (as applicable to you):
- collect and process your saliva sample(s) to isolate DNA;
- sequence your DNA;
- store your resulting Genetic Information;
- store any saliva sample and DNA that are left over after sequencing;
- use your relevant Genetic Information and Self-Reported Information to fulfill your purchase of or access to Helix Insights;
- share your relevant Account Information, Genetic Information and Self-Reported Information with a DNA Product Partner to fulfill your purchase of or access to their DNA Product;
- share your relevant Account Information, Genetic Information and Self-Reported Information with a Research Partner to facilitate your participation in their Research Program; and
- consistent with standard clinical laboratory practices, share your saliva sample and/or DNA with a DNA Product Partner or a Research Partner when necessary to enable the partner to validate the test finding (known as confirmatory testing) before returning any results that may impact your health.
In the following three subsections, we describe how we use your saliva sample and DNA, Genetic Information and Self-Reported Information in particular:
You allow Helix to isolate DNA from any saliva sample(s) you submit and to perform genomic sequencing on the DNA. If any of your saliva sample(s) or DNA are left over after sequencing is completed, we may store it and use it for quality control, process improvements, and optimization in our lab, including occasionally updating your Genetic Information to reflect quality improvements and advances in our genomic sequencing. This may mean that we store your DNA indefinitely. If you have specifically consented for Helix to use or share your saliva sample or DNA with a Research Partner in connection with a Research Program, then we may do so in accordance with the applicable research consent.
When you use a Helix DNA Kit to submit a saliva sample, Helix isolates DNA from your saliva sample. Helix then performs Genomic Analysis on your DNA to generate, analyze, and store your Genetic Information. When you provide your Uploaded Data, Helix performs Genomic Analysis on your Uploaded Data to generate, analyze, and store your Genetic Information. When you choose to access a DNA Product, including any Helix Insights, certain portions of your Genetic Information will be used to produce insights for that DNA Product. You can find more details about what portions a DNA Product uses in its Product Consent. In some cases, Helix may provide or facilitate some interpretations of your Genetic Information on behalf of DNA Product Partners that can be accessed in their DNA Products. Helix may also provide or facilitate interpretations of your Genetic Information on behalf of Research Partners that you have consented to for a Research Program. You can find more details about what is provided to a Research Partner in the applicable research consent.
Many traits are also influenced by non-genetic factors, as discussed in our Terms of Service and Platform Consent. Your Self-Reported Information may be combined with your Genetic Information to improve interpretations of your Genetic Information, including Helix Insights. Some DNA Products may require this information for purposes of interpreting your Genetic Information, but it is up to you whether to purchase these DNA Products and provide this information. If you do not provide this information, you may not be able to purchase certain DNA Products. If you provide Self-Reported Information to Helix, we may share this information with certain DNA Product Partners with your permission to facilitate their DNA Products and related services.
With your consent for research
With your consent (via our Research Consent), we may also use your Genetic Information and Self-Reported Information for Helix’s research, called the Helix DNA Discovery Project, as described in our Research Consent. Upon registering your Helix DNA Kit, or in your Helix account settings, you can choose to participate in the Helix DNA Discovery Project by providing your Research Consent. If you no longer wish to participate in the Helix DNA Discovery Project, you may withdraw your consent at any time by changing your account settings. Withdrawing your consent will not remove your information from ongoing or completed research studies. However, studies that start more than 30 days after you withdraw your consent will not have access to your Genetic Information and Self-Reported Information.
We do not share your Genetic Information or Self-Reported Information with third parties for research without your consent. However, we may inform you of third party research opportunities for which you may be eligible, or invite you to participate in Helix’s research apart from the Helix DNA Discovery Project, based on your Genetic Information or Self-Reported Information. These research opportunities will be completely voluntary. Whether you take part in these research efforts will not impact your experience with DNA Products you have received or your ability to purchase or access any DNA Products going forward.
If you choose not to provide your Research Consent, Helix may still use and publish findings based in part on your Genetic Information and Self-Reported Information in an “Aggregated” form for research, promotional, or other purposes.
Information that is “Aggregated” means that it is summary-level and derived from data that has been de-identified and combined with that of other users prior to analysis, and cannot reasonably permit someone to identify you individually.
Helix may also use Aggregated Genetic Information for quality, regulatory, and internal business purposes, such as to improve our products, data quality, and laboratory processes.
How Do You Access, Correct or Remove Your Information?
You may contact Customer Success to request access to, correct, or remove any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Information that has already been de-identified and/or aggregated (including Aggregated Genetic Information) may not be retrievable or traced back for correction or removal from any database.
You may also close your Helix Account through your account settings. If you close your Helix Account, you will no longer have access through the Site or Services to your Genetic Information. Closing your account will not remove your information from ongoing or completed research studies. However, studies that start more than 30 days after you close your account will not have access to your information. After closure of your account, you will not be able to purchase any DNA Products from the Helix Platform without creating a new account and providing a new saliva sample or Uploaded Data.
After you close your Helix Account, we retain some Account Information in your account related to your purchase history. This enables us to provide you with ongoing support regarding your prior purchases, and is also necessary for accounting, audit, and compliance purposes. We may also retain limited backup copies and archival files of your information to satisfy our state and federal legal obligations or regulatory requirements, including those set by the Clinical Laboratory Improvement Amendments (CLIA). However, going forward, you will be unsubscribed from all marketing emails, and we will not share your information with any DNA Product Partner or service provider (except in connection with a Research Program in which you continue to be enrolled). If you have given one of our Research Partners consent for ongoing access to your data, those Research Partners will continue to have access to your data unless you separately withdraw from their Research Program as well.
If you choose to stop sharing your information with DNA Product Partners by closing your Helix Account, Helix will inform the DNA Product Partner, but cannot guarantee that the DNA Product Partner will remove, de-identify or delete your information. You can request such removal, de-identification, or deletion directly from the DNA Product Partner.
You may request that your data be deleted by contacting Customer Success. In general, we fulfill requests for removal of information within 45 days of receiving and verifying the request, unless you have given one of our Research Partners consent for ongoing access to your data. We will continue to retain your data for those Research Partners to access unless you separately withdraw from their Research Program. We will then generally fulfill your request for removal of information within 45 days of being informed by the Research Partner of your withdrawal. In some cases, we may need to request an additional 45 days to respond to your request. We will notify you in writing if we require this additional time.
If you delete your Helix data, you will no longer have access through the Site or Services to your Genetic Information. Deleting your data will not remove your information from ongoing or completed research studies. However, studies that start more than 45 days after you request that your data be deleted will not have access to your information. After deletion of your data you will not be able to purchase any DNA Products from the Helix Platform without creating a new account and providing a new saliva sample or Uploaded Data.
After you delete your data, we retain some Account Information related to your purchase history. This enables us to provide you with ongoing support regarding your prior purchases, and is also necessary for accounting, audit, and compliance purposes. We may also retain limited backup copies and archival files of your information to satisfy our state and federal legal obligations or regulatory requirements, including those set by the Clinical Laboratory Improvement Amendments (CLIA) and the College of American Pathologists (CAP) accreditation requirements. Going forward we will not share your information with any DNA Product Partner or third party.
You may request that your saliva sample, if any remains after sequencing, be destroyed by contacting Customer Success.
How Do We Keep Your Information Secure?
We limit access to your information to Helix’s employees and contractors who we believe need access to it to provide Services to you or to do their jobs. In addition, we put in place industry standard physical, technical, and procedural safeguards designed to secure your Account Information, Self-Reported Information, Genetic Information, saliva sample, DNA, and any other personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. You can find additional information about our security practices on our Privacy & Policy Highlights page.
Information for California Residents
California Consumer Rights
If you are a California resident, California law permits you to request information regarding the:
- Categories of Personal Information (as defined by applicable California law) collected, sold or disclosed by us;
- The business or commercial purpose(s) for which categories of Personal Information collected by us are used;
- Sources of information from which we collect Personal Information; and
- Specific pieces of Personal Information we have collected about you.
Additionally, if you are a California resident, you may:
- Request that we disclose information about the personal information that we have collected about you in the 12 months preceding your request (including the categories of personal information collected, the source of that information, the business or commercial purpose of that collection, the categories of third parties with whom that information is shared, and the specific pieces of personal information collected about you);
- Receive requested information in a readily-usable format if provided electronically;
- Request that we delete any personal information about you that we have collected (although we may be entitled to retain some information for certain purposes such as to comply with other regulatory requirements); and
- Opt-out of “sales” of personal information to third parties, if applicable.
Helix will not discriminate against you for exercising any of your privacy rights under the CCPA.
Requests related to your privacy rights under California law can be submitted using the following links:
Categories and Sources of Personal Information
The categories of Personal Information Helix has collected about consumers in the preceding 12 months and the categories of sources from which Personal Information is collected are described in the “What Information Do We Collect?” section of this policy.
Business Purpose for Collecting and Disclosing Personal Information
Helix’s business purpose(s) for collecting and disclosing Personal Information are described in the “How Do We Use Your Information?” and the “When Do We Share Your Information?” sections of this policy.
Sale of Personal Information
In the past 12 months, we have not sold personal information to third parties. We do not sell or share the personal information we collect with unaffiliated third parties for their own marketing purposes.
If you have additional questions or requests related to your rights under the CCPA, please contact Helix’s Privacy Officer at firstname.lastname@example.org.
Questions or Comments
Helix OpCo, LLC
Attn: Privacy Officer
101 S Ellsworth, Suite 350
San Mateo, CA 94401