EFFECTIVE DATE: JANUARY 23, 2023
Traitwell Collection and Use of Information.
Traitwell collects personal information from or about you in the following manner:
- Information we receive when you use our Services: We collect web-behavior information via cookies and other similar tracking technologies when you use and access our Services, such as our website, apps, products, and other services.
- Information you share with us: We collect and process your information when you place an order, make a donation, submit your genetic information, create an account, or register your Traitwell kit.
- Information from our DNA testing services: With your consent, we extract your DNA from your saliva sample and analyze it to produce your Genomic Information (the As, Ts, Cs, and Gs at particular locations in your genome) in order to provide you with Traitwell reports.
When you register on Traitwell, we collect your name and email address to process your registration. Everybody who registers with the Site must provide a valid email address for the principal contact. It provides log-in verification and allows Traitwell to contact them if necessary. It also provides a mechanism to verify your identity if you want to contact Traitwell. You agree to keep your log-in information secure, and to keep your email address up to date.
Traitwell will only collect your personal information if you provide it to us voluntarily. If you are located outside the United States, you consent to the storage, processing, and transfer of your personal information outside your country.
In addition, we automatically collect certain information regarding visitors to our Site, including IP address, information about your equipment, browsing actions, and usage patterns. The information we collect automatically is statistical data and does not include personal information. We use this information for internal purposes, such Site improvements.
RAW GENETIC DATA PROVIDED TO TRAITWELL
When you upload raw genetic data to Traitwell, you agree that the raw genetic data is one of the following:
- Your own DNA;
- DNA of a person for whom you are a legal guardian;
- DNA of a person who has granted you specific authorization to upload their DNA to Traitwell;
- DNA of a person known by you to be deceased; or
- DNA obtained from an artifact (if and only if: (1) you have a reasonable belief that the Raw genetic data is DNA from a previous owner or user of the artifact rather than from a living individual; and (2) that previous owner or user of the artifact is known to you to be deceased).
By registering for Traitwell and using the Site, you agree that you will not upload raw genetic data that does not satisfy one of these categories. If you have previously uploaded raw genetic data that does not satisfy one of these categories, you hereby agree that you will remove it immediately.
Traitwell will not be responsible for any raw genetic data provided to Traitwell in violation of this Policy. Violators of this Policy may have their raw genetic data or other personal information deleted without warning, their access will be blocked, and/or other remedial steps may be taken, including any legal action allowed under law.
HOW TRAITWELL USES YOUR INFORMATION
We process your personal information in order to provide our services, which includes processing payments, shipping kits to customers, creating customer accounts and authenticating logins, analyzing saliva samples and DNA, and delivering results.
We use your personal and genetic data in our own internal research to develop or improve Traitwell apps.
DNA data uploaded to Traitwell.Com (“raw genetic data”) remains the property of the person who uploaded it. By default, your raw genetic data and analysis results are not available to any user of the Site – except you. Traitwell does not sell or share your personal or genetic data with anyone without your consent.
There may be options where you may join a “sharing pool” which has the potential for disclosing additional information about you or your data. If you choose to join a sharing pool, you should carefully read the conditions and disclaimers associated with that sharing pool. By joining the sharing pool, you are agreeing to abide by those conditions and disclaimers.
We retain personal information about you for as long as you have an open account with us or as otherwise necessary to provide you with Traitwell services. You can delete your account at any time. Deleting your account means permanently deleting all of your data in your Traitwell account and is irreversible
HOW TO ACCESS YOUR COLLECTED INFORMATION
You may update or correct your personal and/or genetic information at any time by logging in to your account. Traitwell does not sell or share your personal or genetic data with anyone without your consent.
Your Personal Information may be shared in the following ways:
- With our service providers, as necessary for them to provide their services to us.
- With qualified research collaborators, but only if you provide your explicit consent.
Traitwell will not sell, lease, or rent your individual-level information to a third party for research purposes without your explicit consent. At times we may ask for that consent.
We will not share your data with any public databases.
We will not provide any person’s data (genetic or non-genetic) to an insurance company or employer.
We will not use any information to assist with any decision to grant or deny any insurance, employment, mortgage, loan, credit, or educational opportunity.
We will not provide information to law enforcement or regulatory authorities unless required by law to comply with a valid court order, subpoena, or search warrant for genetic or Personal Information.
We are a privately-held company in the United States run by Americans using American tech. Your data is private and confidential so we protect it with highly secure, military-grade servers. Although we work to create a secure and reliable Site for you, the confidentiality of any communication, material, or personal information provided to Traitwell via the Site or email cannot be absolutely guaranteed. In the event of a data breach, it is possible that your data could be associated with your identity, which could be used against your interests.
Traitwell implements measures and systems to ensure confidentiality and integrity of Traitwell data. Our team regularly reviews and improves our security practices to help ensure the integrity of our systems and your information. These practices include, but are not limited to, the following areas:
- Industry standard hashing/encryption to secure all of our communications, data transits, and data storage.
- Limitation of access to the sensitive information to authorized personnel based on job function and position. Traitwell utilizes multi-factor authentication and SSO, with PoLP policies, to grant access information. We always ensure the maximum-security measures are in place.
- Transport Layer Security protocol to secure our site.
Traitwell operators will not be held responsible for the loss of raw genetic data, whether as a result of mechanical failure, software malfunction, human error, or any other means.
Accuracy of Results.
The information on this Site is provided “as is” for general information only and without warranties of any kind and is intended for maintaining or encouraging a healthy lifestyle that is unrelated to the diagnosis, cure, mitigation, prevention, or treatment of any specific disease or condition. The materials on this Site are not meant to be used for self-diagnosis or to replace the services of a medical professional. This Site does not offer medical advice or recommendations to individuals and you should not rely on the information posted on the Site as a substitute for consultations with qualified health care professionals who are familiar with individual medical conditions and needs.
Traitwell does not advocate that you attempt to treat yourself, your family or someone you know without proper medical supervision. Traitwell encourages you to seek the guidance of your healthcare provider if you feel that you, your family or someone that you know suffers from any of the conditions described on this Site.
While Traitwell endeavors to keep the materials on this Site current, genomic information changes rapidly and thus the materials on this Site should not be relied upon to be fully comprehensive or error free. Traitwell does not recommend, endorse or make any warranties or representations of any kind with regard to the accuracy, completeness, timeliness, quality, efficacy, or non-infringement of any of the programs, materials, products or other information provided on this Site or by the companies or organizations linked or referred to on the Site. Furthermore, changes in software, genomic research results, and analysis tools could change results from those previously provided.
Other Risks and Considerations.
There may be some consequences of using our services that you might not have considered.
You may discover things about yourself and/or your family members that may be upsetting or cause anxiety and that you may not have the ability to control or change.
Termination of Service.
If you wish to have your raw genetic data or personal information removed, you can do so by using the account deletion link within your Traitwell account.
Traitwell administrators reserve the right to remove any raw genetic data or personal information from the database, for any reason, at any time, either with or without notice. Any or all services at Traitwell.com may be terminated at any time, without notice, for any reason, at the sole discretion of the Traitwell administrators.
Limitation of Liability.
Traitwell shall have no liability to you under this Policy, it being acknowledged and agreed that the Site is provided for your convenience. If the foregoing limitation of liability is found to be unenforceable, Traitwell's liability to you for any cause of action arising from the Site or under this Policy will be limited to any amount paid by you to Traitwell for the Site during the twelve (12) months preceding such cause of action. Notwithstanding anything to the contrary contained herein, this Policy shall not limit or exclude either party's liability for gross negligence or intentional misconduct of a party or its agents or employees, or for death or personal injury. The parties agree that the limitations on and exclusions of liability in this Policy were freely negotiated and are an integral part of the bargain, in that the Site would not have been available for the same price and under the same terms and conditions had such limitations on and exclusions of liability not been included in this Policy. Some states or jurisdictions do not allow the exclusion of certain warranties, so some of the above limitations may not apply to you. Further, some jurisdictions prohibit the exclusion or limitation of liability for consequential or incidental damages, so the above limitations may not apply to you.
You agree to indemnify, defend, and hold Traitwell and any of its affiliates, any of its successors and assignees, and any of its respective officers, directors, employees, volunteers, contractors, consultants, agents, representatives, licensors, advertisers, suppliers, and service providers, harmless from any liability, loss, claim, and expense, including reasonable attorneys' fees, related to your violation of this Policy or use or misuse of the Site. We reserve the right, at our own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will cooperate with us in asserting any available defenses.
Updates to This Policy.