Data Privacy & Protection Policy

GeneClinicX Program Participant Data Privacy & Protection

Version 2021.1

GeneClinicX & GenePath Diagnostics are committed to protecting your data and personal information. The privacy and the security of your data are of utmost importance to us. The following frequently asked questions (FAQs) will help you better understand our policies in this regard.

What information does GeneClinicX/GenePath Diagnostics typically collect from me (a Participant)?

We collect personal details such as your full name, gender, date of birth / age, contact information (telephone numbers, email address, shipping and billing address), medical history, names of treating doctors, answers to surveys, lifestyle and dietary pattern, anthropometry parameters, allergy details, medications being consumed or prescribed, digital data generated by wearable sensors like Fitbit/ Apple Watch, and continuous glucose monitoring devices, and other medically relevant information which you may have provided to us through our website, over the phone, via email or any other electronic means, or in person at our Clinic. As a part of understanding your relevant family history details, we may collect such details regarding your spouse, parents, children, and siblings, as required. If you visit our website, we may capture additional information such as your IP address, the gateway through which you reached our site, etc. GeneClinicX / GenePath Diagnostics does not store or have access to your payment information. We use a third-party payment processor (i.e., “Razorpay”) to process all online payments, who may collect additional information in order to complete the transaction. If you choose to get any genetic testing through GeneClinicX / GenePath Diagnostics, the results generated from these genetic tests are also collected. The record keeping may be in the form of paper records and/or electronic or digital formats on our computer systems and servers. This information is protected with appropriate authorized access control systems.

The GeneClinicX app is designed with the primary purpose benefitting our Participants’ health and fitness via a user interface allowing Participants to directly journal, report, monitor, and/or analyze their physical activity, sleep, mental well-being, nutrition, health measurements, physical descriptions, and/or other health or wellness-related descriptions and measurements.

Additionally, the app enables Participants to sync their physical activity, sleep, mental well-being, nutrition, health measurements, physical descriptions, and/or other health or wellness-related descriptions and measurements from their wearable device.

Specifically, the GeneClinicX app captures the following information from your wearable, your food and other activity logging, your use of a Continuous Glucose Monitor, and your responses to the GeneClinicX Health Assessment Survey:

Sleep: Sessions, Stages of sleep, Activity: Steps, Distance, Exercise, Elevation Gained, Floors Climbed, Calories: BMR, Active and Total Calories Burned, Heart and Respiratory: Heart Rate (HR), Resting HR, Variability (Rmssd), Vo2 Max, Respiratory Rate, Blood Pressure, Diet: Hydration, Nutrition, Body Measurements: Weight, Body Fat, Body Mass, Lean Body Mass, Bone Mass

Regarding this data, please note the following:

The GeneClinicX app meets the privacy requirements of Google Health Connect and Apple Health.
GeneClinicX only requests access to Google Health Connect and Apple Health permissions that are critical to implementing our service's functionality, features, and services.
We only transfer data to third parties to improve appropriate app use cases or features, and only with your consent.
We do not use, sell, or transfer your data for any other purposes, including to third parties such as advertising platforms, data brokers, or any information resellers.
The GeneClinicX app also meets the secure data handling requirements outlined by both Google Health Connect and Apple Health.
You may delete your GeneClinicX account at any time. To do this, from the Home page, click on your Profile, then select the Profile Settings tab and click on Delete Account. Once deleted, your profile and personal data will no longer be viewable in the app.

Why does GeneClinicX/GenePath Diagnostics need this information?

The personal information that we collect from you allows us to reach you to schedule appointments, to send you testing kits, to send you your test results, and to process your payments. Your personal, medical and family information is also required to interpret your testing results in a clinically relevant manner in order to provide you with personalized and actionable guidance for lifestyle behavior changes and/or medical management pertaining to the specific GeneClinicX program(s) you have chosen. We may also refer you to clinical domain experts (Cardiologists/ Physicians/ Geneticist/ Nutritionists etc.) if considered appropriate based on your personal/ family history and investigation results. Unless you explicitly refuse, your data which is generated from these services may be used to improve the quality of the services we offer, our technical analysis, for teaching/ training purposes, for scientific presentations or publications, and for submission to publicly available databases. This, however, will never be done in an identifiable manner, i.e., no one will be able to identify it as data belonging to you. If you have provided your blood sample for any biochemical/ molecular tests as a part of any program offered by GeneClinicX, your leftover sample(s) may be used for laboratory quality purposes in an anonymized manner.

If you do not want us to use your blood or personal health information in this manner you will be given the option to refuse such permission at the time of enrolment in all our programs, and the clinical services GeneClinicX provides to you will not be affected in any way.

How do you ensure the security and integrity of my personal and private data?

GeneClinicX/GenePath Diagnostics has established systems to maintain confidentiality of your data and to limit access to personal information only to authorized individuals. While we are committed to protect all our data in a secure manner and prevent any unauthorized access, please be aware that information technology systems are not always 100% secure. GeneClinicX/GenePath Diagnostics is not liable for any inadvertent loss of your data or for any information breaches.

What is your data protection and privacy policy related to sample storage and genetic information?

If you choose to undergo blood testing or other laboratory investigations with GeneClinicX/GenePath Diagnostics, our clinical diagnostics division, GenePath Diagnostics will process your sample and generate reports. Personal identifiable information will remain linked to your sample for a period of one week for non-molecular tests and for 6 months for all molecular tests after we receive it. Unless you indicate otherwise on the consent form at the time your sample(s) are collected, after the above time intervals have elapsed, all personal information will be stripped from the samples i.e. the information will be delinked. Anonymized samples may be stored and used for quality control purposes and laboratory and assay improvement processes. If you do not want your sample to be used in this manner, please indicate this on the consent form at the time of sample collection, and we will discard your blood/ saliva/ DNA sample after 6 months. Please note that once the samples have been delinked, we will no longer be able to locate your sample and carry out any additional investigations or destroy it.

What am I consenting to by registering for a GeneClinicX program or using your website?

By registering on our website or choosing one of the services offered by us, you acknowledge that you have provided us all requested information of your free will after understanding how it may be used. You also acknowledge that you have understood the data protection and privacy policy as explained in this document. Furthermore, you agree to the collection, storage, processing, sharing and future use of your information if carried out per this document. While processing the information or sample, it is assumed that the information provided by you is accurate to the best of your knowledge. Any use of your personal information in an unidentifiable manner for purposes other than described will not entitle you to any benefit, monetary or otherwise, and nor entitle you to any rights over the results and outcomes. You will have no right to claim any ownership of the data, research, publications, patents or any intellectual property resulting from the anonymized personal information.

In the case of online consultations, you acknowledge that we have your consent for tele-medicine. Please note that your call may be recorded for future teaching and training purposes. GeneClinicX’s health care professionals will use their professional judgement on the sufficiency of a tele-consultation and shall exercise proper discretion and not compromise on the quality of care. Under no circumstances shall GeneClinicX/GenePath Diagnostics be responsible or liable for any recommendations made or information exchanged with our partners and the Participant. GeneClinicX/GenePath Diagnostics shall not be liable for misdiagnosis, incorrect prescriptions, incorrect advice or recommendations. We will not be liable for the consequences of incorrect information provided by you.

Please note that we may choose to modify this document and our privacy policy from time to time to better serve you. Our website will reflect the latest privacy policy, version number and date of implementation.

Should you have any questions, please reach out to us at info@geneclinicx.com