Effective Date: October 3, 2018

Introduction and Scope

Gene Codes Corporation (“Gene Codes,” “we,” “us,” “our”) takes the protection of personal data very seriously. This Privacy Notice (the “Notice”) addresses data subjects whose personally identifiable information data (“PII”) we may receive from our customers and prospective customers through our internal sales and marketing and product support systems, which consist of:

• our website located at https://www.genecodes.com;
• our license server;
• our customer relationship management software;
• our email applications and email marketing software;
• our internal accounting software;
• our payment processing software; and
• our teleconferencing software (collectively, the “Systems”).

This Notice does not apply to PII stored by our customers in our on-premises software products CodeLinker or Sequencher. Gene Codes does not have access to PII collected by users of these applications.

Categories of PII

We may process the following types of PII in our Systems:

• biographical information, such as first names and last names;
• contact information, such as email addresses and mailing addresses;
• computer usernames, host names, and machine hardware profiles, which are tied to software licenses; and
• payment information.

Controllership

In the context of this Notice, CLIENT Gene Codes acts as a data controller for the data we process.

How We Receive PII

We may receive your PII from:
 

• direct contact with you, such as when you contact us directly by email or web form, when we meet you at trade shows, or when you call us by phone;
• purchased lists of prospective customers;
• customer referrals;
• distributors of Gene Codes products; and
• our Sequencher evaluation form.

If we receive your PII from a third party, we will notify you, where required by applicable laws, without undue delay.

Basis of Processing

Within the scope of this Notice, we process PII on the basis of our legitimate interests, such as our legitimate business interest in marketing our products to potential customers, and on the basis of the performance of a contract with you, such as when you sign the End User License Agreement for one of our software products.

Purpose of Processing

We process PII for the following purposes:

• customer relationship management;
• to conduct marketing by phone (for existing customers and non-customers), email, and postal mail;
• to manage customer license data;
• to validate customer licenses;
• payment processing;
• creating and sending invoices;

• to provide technical support and troubleshooting services to users of our software products;
• to provide customer training;
• to respond to product licensing issues; and
• to perform and provide software demonstrations.

Data Retention

PII processed by us in the context of this Notice is retained for as long as is necessary for the purposes of processing to be satisfied. You may at any time send a request to us to ask to delete your PII, subject to the limitations described in this Notice.

Cookies

A “cookie” is a small file stored on your device that contains information about your device. We may use cookies to collect website analytics data with Google Analytics. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. Note, if you reject certain cookies, you may not be able to access all of our Apps features. For more information, please visit https://www.aboutcookies.org/.

Sharing PII with Third Parties

We share PII with our service providers, who process PII on behalf of CLIENTGene Codes. Such third parties include those:

• Providing web hosting services;
• Providing email and teleconferencing software as a service;
• Providing payment processing services;
• Providing customer relationship management (CRM) software as a service;
• Providing email marketing automation; and
• Providing cloud-based file storage and sharing services.

Our service providers may be located outside of the United States; however, we will either obtain your explicit consent to transfer your PII to such third parties, or we will require that those third parties maintain at least the same level of confidentiality that we maintain for such PII. Gene Codes remains liable for the protection of your PII that we transfer to our service providers, except to the extent that we are not responsible for the event giving rise to any unauthorized or improper processing.

Other Disclosure of Your PII

We may disclose your PII (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.

We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about individuals whose PII we have collected as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.

If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.

Data Integrity & Security

Gene Codes has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect PII from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction. 

Access & Review

If you are a data subject about whom we store PII, you may have a right to request access to, and the opportunity to update, correct, port or delete such PII. Under certain circumstances, you may have a right to restrict or object to the processing of your PII. To submit such requests or raise any other questions, please reach out to us by using the contact information provided in the “Contact Us” section below.

Privacy of Children

We do not knowingly collect PII from anyone under 16. In the event that we learn that we process PII from a child under age 16, we will delete the information we have stored as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us using the contact information provided in the "Contact Us" section below.

Changes to this Privacy Notice

If we make any material change to this Notice, we will post the revised Notice to this web page and update the “Effective Date” at the beginning of this Notice to reflect the date on which the new version of the Notice became effective.

Contact Us

If you have any questions about this Notice or our processing of your PII, please write to our privacy team by email at gcprivacy [at] genecodes [dot] com or by postal mail at:

Gene Codes Corporation

ATTN: Privacy Team
525 Avis Drive, Suite 4
Ann Arbor, MI 48108
USA

Please allow up to four weeks for us to reply.

European Union (EU) Representative

VeraSafe has been appointed as Gene Codes's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. If you are in the European Economic Area, VeraSafe can be contacted, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using the following hyperlink or via telephone at: +420 228 881 031

VeraSafe using this contact form:https://verasafe.com/public-resources/contact-data-protection-representative

Alternatively, VeraSafe can be contacted at:

Supervisory Authority Oversight

If you are a data subject whose PII we process, you may also have the right to lodge a complaint with a data protection regulator in one or more EU member states.