Privacy Policy

# Privacy policy

Last revised 2024-03-01

Your privacy is important to us, so we have created the following Privacy Policy (“Policy”) to let you know what information we collect when you visit our site, https://sequenceserver.com and its subdomains (“Site”), why we collect it and how we use it.

The terms “You,” “Your,” “Yours” and “User” refer to the person or entity using our Site. When this Policy mentions “We”, “Us,” and “Our” it refers to Pragmatic Genomics Limited and its subsidiaries and affiliates.

In this Policy, provisions governing the collection, storage and/or use of certain types of data are set out. When reviewing this Policy please note that personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

This Privacy Policy is governed by our Terms and Conditions. For any questions regarding this Policy or any requests regarding the processing of personal data, please contact us using the contact details below.

1. INFORMATION WE COLLECT FROM YOU##

We collect the information You provide to us and this information is necessary for the adequate performance of the contractual arrangement which is in place between You and us and allow us to comply with our legal obligations.

• Account Signup Information. When You create the account, we ask You to provide the signup information, such as Email, Name, Surname, Phone, Address.
• Payment Information. To order and use features of Site, we may require you to provide certain financial information in order to facilitate the processing of payments. We collect your Billing address, Credit or debit card type, Name and surname, Credit or debit card number, Credit or debit card expiration date.
• Login information. We collect Login information if You are logging to our account with Authentication Data.
• Other Personal Information Provided by You. We may collect other data provided by You from surveys, feedback, financial information (purchase history), DNA, RNA or protein sequences used for databases, DNA, RNA or protein sequences used as queries and other similar data.

2. INFORMATION WE COLLECT AUTOMATICALLY##

When you use our Site or contact us directly, we may collect information, including your personal information, about the way you act in our Site, the services You use and how You use them. This information is necessary for the adequate performance of the contract between You and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Site.

• Log data and Device information. We automatically collect log data and device information when you access and use the Site, even if you have not created an Account or logged in. That information includes, among other things: Internet protocol (IP) addresses, Operating system, Date/time stamp, Referring/exit pages, Internet service provider (ISP).
• Tracking technologies and Cookies. We keep track of usage using web browser cookies, IP addresses and customer identifiers (e.g., organization name, e-mail addresses). We also automatically collect information about device’s operating system.
• Geo-location data. We collect information about your approximate location as determined by data such as your IP address to offer you an improved user experience. Such data may be collected only when you access the Site using your device.
• Usage information. We use a tools to collect information about your interactions with the Site (what pages you visit, such as the pages or content you view, your searches, your uploads, and other actions on the Site. As part of the use of a tool called “Google Analytics”, Google, Inc. plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this Site). For more information, please visit Google. Similarly, we use a tool called “HubSpot” to collect information about your interactions with the Site. For more information, please visit HubSpot. Similarly, we may use “visit tracking” tools from Facebook and LinkedIn to collect information about your interactions with the Site. For more information, please visit Facebook and Linked In.
• Publicly available personal Information.
• Files generated as part of analyses (intermediate and final files, involving queries and databases)

We may also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. THE WAY WE USE YOUR INFORMATION##

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the contact details below if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose of Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

4. DIRECT MARKETING##

We may use your provided contact details for direct marketing. These direct marketing offers, depending on your preferences, may be personalized taking into account any other information which you have provided to us (e.g., location, social media profile information, etc.) or we have collected or generated from other sources as described below. If you wish to withdraw the consent for direct marketing, and refuse to receive information from us, you may exercise such option at any time you wish by using the contact details below. You are free to opt out of our newsletters at any time. You can do this by clicking on a link for that purpose at the bottom of our e-mail with the newsletters.

5. HOW WE MAY SHARE YOUR INFORMATION##

We may share your information with third parties that we use to provide and support our Services:

• Invoicing and Billing company
• Stripe Analytics
• Web analytics: Google Analytics, Hubspot, Facebook, Linkedin.
• Other - Amazon AWS cloud computing services
• Authentication: WorkOS, Authress, PropelAuth.

We may also disclose your information to third parties:

• where required by law or regulatory requirement, court order or other judicial authorization;
• in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements;
• in connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business;
• to protect or defend our rights, interests or property, or that of third parties;
• to investigate any wrongdoing in connection with our products and services;
• and to protect the vital interests of an individual.

6. COOKIES##

Cookies are small text files stored by your browser on your computer when you visit our Site. We use cookies to improve our Site and make it easier to use. Cookies permit us to recognize users and avoid repetitive requests for the same information. Please check our Cookie Policy to find more information about cookies we use. You may find more information about how to delete cookies, as well as the other useful information related to the use of the cookies, on the website http://www.allaboutcookies.org/.

7. PERSONAL SENSITIVE INFORMATION##

We do not collect sensitive information such as political opinions, religious or philosophical beliefs, racial or ethnic origin, personal genetic data, biometric data, health data or data related to sexual orientation. Please do not send, upload, or provide us any sensitive data and please contact us using the contact details below if you believe that we might have such information. We have a right to delete any information we believe it might contain sensitive data.

8. PAYMENT INFORMATION##

To order and use our services we may require you to provide certain financial information to facilitate the processing of payments. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. All payment data is stored by Stripe. You may find their privacy policy link(s) here: https://stripe.com/gb/privacy.

9. THIRD PARTY LINKS##

Our Site may have links to other websites. Please review their privacy policies to learn more about how they collect and use your personal data, because we do not control their policies and personal data processing practices.

10. RETENTION##

We retain your personal information to provide services to you and as otherwise necessary to comply with our legal obligation, resolve disputes, and enforce our agreements. We will retain your personal information as long as we need it to provide services to you, unless we are otherwise required by law or regulations to retain your personal information longer.

11. SECURITY##

We have implemented security measures designed to protect the personal information you share with us, including physical, electronic and procedural measures. Among other things, we regularly monitor our systems for possible vulnerabilities and attacks, and have engineered our systems to reduce the likelihood of such attacks. Regardless of the measures and efforts taken by us, the transmission of information via internet, email or text message is not completely secure. We do not guarantee the absolute protection and security of your personal information or any other User Content you upload, publish or otherwise share with us or anyone else. We therefore encourage you to avoid providing us or anyone with any sensitive information of which you believe its disclosure could cause you substantial or irreparable harm. If you have any questions regarding the security of our Site or Services, you are welcome to contact us using the contact details provided below.

12. YOUR RIGHTS##

You are entitled to a range of rights regarding the protection of your personal information. Those rights are:

The right to access the information we have about you. If you wish to access your personal information that we collect, you can do so at any time by contacting us using the contact details provided below.

The right to rectify inaccurate information about you. You can correct, update or request deletion of your personal information by contacting us using the contact details provided below.

The right to object the processing. When we rely on your consent to process your personal information, you may withdraw consent at any time by contacting us using the contact details provided below. This will not affect the lawfulness of processing prior to the withdrawal of your consent.

The right to lodge a complaint. You can raise questions or complaints to the national Data Protection Agency in your country of residence in the event where your rights may have been infringed. However, we recommend attempting to reach a peaceful resolution of the possible dispute by contacting us first.

The right to erase any data concerning you. You may demand erasure of data without undue delay for legitimate reasons, e.g., where data is no longer necessary for the purposes it was collected, or where the data has been unlawfully processed. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

13. APPLICATION OF POLICY#

This Policy applies only to the services offered by our Company. Our Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include our services or other sites linked from our Site or Services.

14. AMENDMENTS##

Our Policy may change from time to time. We will post any Policy changes on our Site and, if the changes are significant, we may consider providing a more explicit notice (including, for certain services, email notification of Policy changes).

15. ACCEPTANCE OF THIS POLICY

We assume that all Users of this Site, our SequenceServer software and our SequenceServer Cloud service have carefully read this document and agree to its contents. If someone does not agree with this Policy, they should refrain from using our Site. We reserve the right to change our Policy at any time and inform by using the way as indicated in clause 14. Continued use of this Site implies acceptance of the revised Policy.

16. DISCLOSURE

You agree that Pragmatic Genomics Ltd may disclose the fact that you are a user or paying customer of SequenceServer or SequenceServer Cloud. In relation thereto, you agree that Pragmatic Genomics Ltd may use your company name and/or company logo to identify you as a customer of Pragmatic Genomics Ltd on the SequenceServer or Pragmatic Genomics web sites, and as part of a general list of Pragmatic Genomics Ltd customers for use and reference in Pragmatic Genomics Ltd promotional and marketing material. Pragmatic Genomics Ltd will cease using your name and logo upon written request.

17. FURTHER INFORMATION##

If you have any further questions regarding the data we collect, or how we use it, then please feel free to contact us at the details as indicated above.