TRANSLATIONAL SOFTWARE INCORPORATED

 

PRIVACY POLICY

We Respect Your Privacy

We recognize the importance of privacy and respect your desire to use our Services in a private and secure manner.

This Privacy Statement is intended to make you aware of how we handle your Personal Information. We are committed to providing you a secure, user-controlled environment for the use of our Services. At the same time, you share responsibility for maintaining privacy and security - for example, by keeping your password secure.

We encourage you to familiarize yourself with our Privacy Statement. Our Terms of Service explain that, by using our website and accessing services of third party vendors, you are allowing us to process your personal information according to the provisions set forth in those documents and this Privacy Statement.

Definitions

  • "TSI" means Translational Software Incorporated, a Washington corporation.
  • ”Product Development” means research and development activities performed by TSI on its products. These activities may include, among other things, improving our Services and/or offering new products or services to you; performing quality control activities; conducting data analysis that may lead to and/or include commercialization with a third party.
  •  "Service" or "Services" means TSI's products, software, services, and website as accessed from time to time by the user, regardless if the use is in connection with an account or not.

Which Personal Information We Collect

In the course of your relationship with TSI, we collect several types of Personal Information. Personal Information is information that could be used to identify you, either alone or in combination with other information, or that discloses protected health information about you. We collect such information from you when you purchase our Services, order services from our commercial partners, create a personal account, complete surveys and forms, and/or when you communicate with us or request information from us. Personal Information collected online can be combined with Personal Information collected offline. We collect five primary types of Personal Information through our Service and website.

  1. "Registration Information" is information that we collect from you when you purchase or sign up for our Services. Examples of such information include your name, credit card information, billing and shipping addresses, and contact information, such as email address and telephone number.
  2. "Self-Reported Information" includes information you provide to us, including but not limited to information about your disease conditions (e.g. Type 2 Diabetes), your medications, other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), personal traits (e.g., eye color, age, height, weight, gender), ethnicity, and/or family history (e.g. similar information about family members). We collect this information from you if and when you enter the information into surveys, forms, or features while signed in to your account.
  3. "Genetic Information" consists of your genotype, e.g. the As, Ts, Cs, and Gs at particular locations in your genome. Genetic Information is generated when you purchase genetic testing services and your swab or tissue specimen is analyzed and processed or you otherwise contribute or access your Genetic Information through our Services.
  4. “Protected Health Information” consists of information, including Self-Reported Information and Genetic Information, to which you are entitled to protection under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or other laws.
  5. "Web Usage Information" is information on how you use the TSI website (e.g. browser type, domains, page views) collected through log files.

How We Use Registration Information

We use your Registration Information to authenticate your website visits and usage; to enable your purchases; to communicate with you about information, services, and products that you have requested; and to manage and improve our website, software, and Services. We may also use this information to offer you services and products that may be of interest to you. We give you the opportunity to opt out of optional communications, either through our Service or by contacting our Privacy Administrator at privacy@translationalsoftware.com.

How We Use Self-Reported Information

We use your Self-Reported Information to provide you with TSI Services and enable others to provide you with services, customize the user experience, and enhance our features.  TSI may use your Self-Reported Information for other purposes such as quality control or other internal R&D activities.  TSI is a “Business Associate” regulated, and subject to audit, under HIPPA laws.

How We Use Web Usage Information

Web Usage Information is collected through log files during a visit to the TSI website. Web Usage Information is used to improve our Services and the overall user experience.

When users visit our website, TSI gathers certain information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, browser type, Internet Service Provider, referring/exit pages, operating system, and date/time stampWe use this information, which is not designed to identify individual users, to analyze trends, administer the site, track users' movements around the site, and determine the usage of the site’s features.. We may, in some circumstances, need to review this automatically collected data in combination with specific Registration Information to identify and resolve issues for individual users.

No Cookies or Web Beacons. The TSI website does not use cookies or web beacons.

Sharing of Information by You

You may choose on your own initiative to disclose, through other means not associated with TSI, any part of your Personal Information to friends and/or family members, groups of individuals, third-party service providers, doctors or other health care professionals, and/or other individuals. We recommend that you make such choices carefully.

Personal Information, once released or shared, can be difficult to contain. TSI will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with a third party. It is incumbent upon customers to share Personal Information only with people they know and trust.

Information Disclosure by Us

As a general rule, TSI will not disclose your Personal Information to any third party, except under the following circumstances:

Payment/Reimbursement

·         Our core service providers (e.g. credit card processors) process and/or store the Registration Information in order to provide you with TSI's Services, although these service providers are not allowed to use this information for any secondary purposes.

·         We may use or disclose your Personal Information (both Registration and Protected Health Information) to obtain payment for healthcare services provided by our commercial partners. For example, we may disclose your information to your health plan to receive payment for the services provided to you.

Treatment

·         We may disclose your Protected Health Information, including laboratory test results, to physicians and other healthcare providers involved in your care

·         Your physicians may seek to forward Protected Health Information, under applicable duties of confidentiality, to other providers such as genetic counselors

Law

Under certain circumstances Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. You acknowledge and agree that TSI is free to preserve and disclose any and all Personal Information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process (such as a judicial proceeding, court order, or government inquiry) or obligations that TSI may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the TSI TOS; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of TSI, its employees, its users, its clients, and the public. In such event we will notify you through the contact information you have provided to us in advance, unless doing so would violate the law or a court order.

Personal Representatives

We may disclose Personal Information about you to your authorized personal representative, as defined by applicable law, or to an administrator, executor or other authorized person responsible for your estate.

Minors’ Protected Health Information

As permitted by federal and state law, we may disclose Protected Health Information about minors to their parents or guardians.

Persons Involved in Your Care or Payment for Your Care

We may disclose your Protected Health Information to a person involved in your care or payment for your care, such as a family member or close friend.

Communications About Our Products and Services

We may use your Personal Information to contact you about our products and services which we believe may be of interest to you where you have signed an authorization which permits use of medical information.

Disclosures to Business Associates

We may disclose your Registration Information to other companies or individuals, known as “business associates,” who need your information to provide services to us. For example, we may use another company to perform billing services on our behalf. Our business associates are required to protect the privacy of your Personal Information.

Health Oversight Activities

We may disclose your Protected Health Information to a healthcare oversight agency for activities that are authorized by law, such as audits, investigations, inspections and licensure activities. For example, we may disclose your Protected Health Information to agencies responsible for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.

Consent

You have provided explicit consent for us to do so, for example, to obtain services from our commercial partners.

We may provide aggregate or non-personally identifiable statistics about our customers, sales, product usage or traffic patterns, and related website information, but these statistics will not include any Personal Information.

Your Rights

You have the following rights with respect to your Personal Information. To exercise any of these rights, please contact our Privacy Office using the contact information provided at the end of this Notice.

Access to Protected Health Information. 

You or your authorized or designated personal representative have the right to inspect and copy your Protected Health Information and Registration information maintained by us. We may deny access to certain information for specific reasons, for example, where state law prohibits such patient access. Please note that federal and state laws regulating laboratories generally prohibit disclosure of test results directly to a patient.

Restrictions on Uses and Disclosures. 

You have the right to request restrictions on our use and disclosure of your Protected Health Information. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction. If we do agree to a requested restriction, we will notify you in writing.

Confidential Communications. 

You have the right to request that we communicate with you about your Protected Health Information by alternative means or to an alternative address. Your request must be in writing and must specify the alternative means or location. We will accommodate reasonable requests for confidential communications.

Correct or Update Information. 

If you believe the Protected Health Information (principally Self-Reported Information) we maintain about you contains an error, you may request that we correct or update your information. Your request must be in writing and must explain why the information should be corrected or updated. We may deny your request under certain circumstances. If we deny your request, we will provide you with a written explanation for the denial.  If Registration Information changes, you may correct or update such information.

Linked Websites

TSI provides links to third-party websites operated by organizations not affiliated with TSI. TSI does not disclose your Personal Information to organizations operating linked third-party websites. TSI does not review or endorse, and is not responsible for, the privacy practices of these organizations. We encourage you to read the privacy statements of each and every website that you visit. This Privacy Statement applies solely to information collected by TSI.

Account Closure

If you no longer wish to participate in our Services, you may close your account by sending a request to Customer Support at support@translationalsoftware.com. When closing an account, we remove all Personal Information within your account (or profile) within thirty (30) days of our receipt of your request; provided, that we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) for accounting and compliance purposes.

Children's Privacy

TSI is committed to protecting the privacy of children as well as adults. Neither TSI nor any of its Services are designed or intended to attract children under the age of 13.  A parent or guardian, however, may collect a saliva sample from, create an account for, and provide Self-Reported Information on behalf of his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to TSI about his or her child is kept secure and that the information submitted is accurate.

Security

TSI takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, TSI uses a range of reasonable physical, technical, and administrative measures to safeguard your Personal Information, in stored and transmitted forms, in accordance with current technological and industry standards. In particular, all connections to and from our website are encrypted using Secure Socket Layer (SSL) technology.

Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify TSI of any unauthorized use of your password. TSI cannot secure Personal Information that you release on your own or that you request us to release.

Business Transitions

In the event that TSI goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

Changes to This Privacy Statement

This Privacy Statement was last updated in January, 2011. Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our customers' account login pages for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes.

Contact Information

If you have questions about this statement, please email TSI's Privacy Administrator at privacy@translationalsoftware.com.