Dirty Genes LLC
June 18, 2020
- the types of information we collect through our Services;
- how we use and protect that information;
- the types of information we may share with others and under what circumstances; and
- the choices you have regarding our collection, use, and sharing practices.
We also include a specific disclosure about our use of third party cookies and other tracking technologies in our Cookie Notice below. We use these technologies to deliver our Services, gather data for our internal analytics, and for advertising.
This Policy applies to Dirty Genes and our websites, such as StrateGene, mobile applications, emails we send, as well as the information we collect when you interact with us through social media or other websites and online services. It also applies anywhere it is linked. It does not apply to non-Dirty Genes websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.
For questions about our privacy practices, contact us at:
Dirty Genes LLC
3140 Mercer Avenue
Bellingham, WA 98225
Specific Notice For Genetic Information
If you sign up to use our Genetic Testing Services, including the purchasing or registering of your StrateGene Kit, please see our Genetic Testing Privacy Notice below for information about the processing of your personal information including your saliva sample and genetic Information.
Information We Collect
Information You Give Us:
- Information you provide by filling in forms on our websites or in our mobile application. This includes:
- Contact and demographic information when registering to use our Services
- Email address information when subscribing to our email bulletins
- Details of transactions and appointment bookings you carry out through our site and of the fulfillment of your orders.
- Information you provide if you interact with us via social media, including any posts, pictures, videos and messages which you submit to us either via our social media sites (including by use of hashtags associated with us) or our site.
- Information you provide if you complete a survey administered by us or a service provider acting on our behalf.
- Genetic Information, if you use our Genetic Testing Services, as detailed below in our Genetic Testing Privacy Notice.
- If you contact us, we may keep a record of that correspondence and any contact information provided.
Information We Collect Automatically:
- Details of your visits to our site and information generated in the course of the use our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site
- Details regarding the device you use to access our website or digital services, including where available your IP address, operating system and browser type
- Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence
- Information that you make available to us on a social media platform (such as by clicking on a social media icon linked from our Services or choosing to log in through a social media account), including your account ID or username and other information included in your posts
Information is collected for the following purposes:
- To provide you with our products and the Services, including to:
- Process information at your request to take steps to enter into a contract for sale or for services
- Process payments through our payment processor
- Make deliveries
- Maintain business and service continuity
- Send service communications and contact you via chatrooms provided on our site
- To enable additional features or interact with us outside our website or mobile application (such as via email), including to send you direct marketing communications if you consented to us doing so.
- To provide you with the best service and improve and grow our business, including to:
- Provide you with a personalized service
- Improve our products and services
- Keep our site and systems safe and secure
- Understand our customer base and purchasing trends
- Tailor advertising to you
- Create custom audiences on social media sites
- Understand the effectiveness of our marketing
- To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, including to:
- Defend against or exercise legal claims
- Investigate complaints or potential legal violations
- Assist law enforcement when their requests are lawful
- Comply with legal requirements regarding the provision of products and services
We may disclose information to the following parties:
- Service providers, such as:
- Distribution companies, fulfillment companies and other similar sub-contractors
- Payment processors
- Marketing automation partners
- Website, software, or data storage companies
- Analytics and search engine providers that assist us in the improvement and optimization of our site
- Customer survey providers in order to receive feedback and improve our services
- Third parties involved in advertising, such as:
- Third-parties who assist us in serving advertising regarding the Services when you leave the Services
- Third-parties who serve advertising that may be of interest to you on our Services
- Social Media Platforms:
- To enable you to use social media to enhance your interaction with our Services, such as to “Like” or “Share” content.
- For advertising purposes, as described above
- Note: Your interaction with social media platforms typically allows to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, social media platforms may recognize you through their cookies even when you do not interact with their applications. Please visit their respective privacy policies to better understand their data collection practices and controls they make available to you.
- When required by law: We may share your information when required by law or to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities; or to protect Dirty Genes LLC, employees, you, or others.
Additional Information about our About our Data Collection and Sharing Practices
- Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies and analytics providers. These third parties will not be able to relate this data to identifiable individuals.
- Combination of Information: We may combine information from the Services with other information we obtain from our business records, our affiliates, or from third party sources.
- Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
- Cross-border Transfer of Data: If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.
Your Options and Rights:
- Information Stored on Your Account Profile: Please visit the “My Account” page to update your information.
- Our Email Bulletins: If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email bulletin, or email us at and we will promptly remove you from all correspondence.
- Deletion of your account: If you no longer wish to participate in the Services, including the Genetic Testing Services, you may delete your StrateGene account. Once you delete your account, we will delete all of the information associated with your account, including Personal Information associated with the Genetic Testing Services. You can submit requests to have your account deleted to [email protected] Once you submit your request, we will send an email with a code to the email address linked to your account. You will enter this code into the confirmation code box on the Delete My Account screen in order to confirm deletion of your account. Once you confirm your request to delete your account and data, (1) your account will no longer be accessible while we process your request and (2) this deletion process cannot be undone, cancelled, withdrawn, or reversed. When your account is deleted, all information associated with your account is permanently deleted, subject to the following limitations:
- When required by law. Dirty Genes LLC will also retain limited information related to your account and account deletion request, including but not limited to, your email address, account deletion request identifier, and record of legal agreements for a limited period of time as required by our contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.
- Genetic Testing Services. There may be some additional limitations to the deletion process if you participate in the Genetic Testing Services, as detailed more in our Genetic Testing Privacy Notice.
How We Secure the Information We Collect From or About You
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
Your California Privacy Rights
Consumer: natural persons who reside in California, including (1) individuals who are in California for other than a temporary and transitory purpose; and (2) individuals who are domiciled in California, but are outside the state for a temporary or transitory purpose.
CCPA: the California Consumer Privacy Act of 2018, effective as of January 1, 2020
Personal information: as defined in the CCPA, and includes information that can be used to identify you, either alone or in combination with other information, and any other information that could reasonably be linked with a particular consumer or device.
Right to Access
As a consumer you have the right to know the following:
- Categories of personal information we collect about you.
- Categories of sources from which personal information is collected.
- Business or commercial purpose for collecting personal information
- The categories of third parties with whom the business shares personal information.
- Request the specific pieces of personal information the business collected about you in a readily usable format.
- If a business sells personal information or discloses it for business purposes
Your access rights under the CCPA are not absolute. Specifically, the CCPA limits the information you can request to personal information collected in the 12-month period preceding our receipt of the request. Additionally, under the CCPA, Dirty Genes LLC is not obligated to respond to requests for access to personal information more than twice in a twelve-month period. Dirty Genes LLC may, in its sole discretion, choose to provide personal information in response to a consumer’s access request that relate to a time period greater than the preceding 12 months or respond to a consumer request more frequently than required by law; choosing to do so, however, does not constitute an obligation to do so.
Right to Request Deletion
Consumers also have the right to request deletion of personal information, but only where that information was collected from the consumer. Your personal information may not be deleted if the information is necessary to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- Comply with a legal obligation.
Only you or someone legally authorized to act on your behalf may make a verifiable consumer request related to your personal information. Your request must provide sufficient information that allows us to verify you are the person about whom we collected personal information or an authorized representative. Your request must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Dirty Genes LLC will deliver the required data to the consumer in an electronic readable format within 45 days of receipt of the verifiable consumer request. This information will be provided free of charge to the consumer.
Right to Opt Out
As a consumer you have the right to opt-out of having your personal information sold. Dirty Genes LLC does not sell personal information to 3rd parties.
Right to Equal Services and Non-Discrimination
The CCPA prohibits businesses from discriminating against consumers by denying goods or services, charging a different price or rate for goods or services, providing a different level or quality of goods or services, or suggesting that they will do any of these things based upon a consumer’s exercise of any CCPA rights.
The right to equal services and prices does not place any restrictions on a business’ ability to collect information or deny service if a consumer does not want to participate in collection; it only applies where the consumer exercises specific CCPA rights, such as opting out of downstream sale of the data.
Exercising Consumer Rights
To request a summary of your personal information or to request deletion of your personal information please contact us at [email protected]
Information We Collect
Category – Identifiers
Examples: Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name
Category – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Examples: Registration information such as name, address and contact information. Some information included in this category may overlap with other categories
Category – Protected classification characteristics
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category – Commercial information
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Category – Geolocation data
Examples: Web-Behavior Information that includes the identification or estimation of physical location or movement.
Category – Internet or Other Electronic Network Activity Information
Examples: Browsing history, search history, and information regarding consumer’s interaction with an internet site.
Changes to This Policy
We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes
Genetic Testing Privacy Notice
Last Updated: 12/31/2019
This Genetic Testing Privacy Notice explains how Dirty Genes LLC, the provider of StrateGene, collects, uses, and shares information when you interact with our Genetic Testing Services. The “Genetic Testing Services” includes (1) the collection and analysis of your saliva and DNA Sample, (2) storage and frequent re-analysis of your Genetic Information, as defined below, derived from your saliva and DNA sample, (3) and access to your Genetic Information and the analysis that results from analyzing your Genetic Information made available to you through the StrateGene Reports.
This Genetic Testing Privacy Notice applies solely to information collected by Dirty Genes LLC in providing the Genetic Testing Services, as well as emails we send regarding such services. It does not apply to non-Dirty Genes websites or services that may link to the Genetic Testing Services or be linked to or from the Genetic Testing Services; please review the privacy policies on those websites or services directly to understand their privacy practices.
For questions about our genetic testing privacy practices, contact us at: [email protected].
This Genetic Testing Privacy Notice Explains:
- Key Definitions
- Information We Collect
- How and Why We Use Your Personal Information
- How We May Share Your Personal Information
- Your Choices and How to Withdraw Consent
- Aggregated and Anonymized Information. Any information that has been stripped of any identifiable information, including your name and contact information and aggregated with information of others or anonymized so that you cannot reasonably be identified as an individual.
- Personal Information. The information that can be used to identify you, either alone or in combination with other information. Personal Information includes the following types of information:
- Customer Service Information. This is information you provide when you contact customer service regarding your use of the Genetic Testing Services, including your Personal Information.
- DNA Sample. The DNA extracted from processing your Saliva Sample.
- Genetic Information. The information regarding your genotypes, derived from analyzing your DNA Sample using either genotyping by Dirty Genes LLC or our third party laboratory. Genetic Information includes any third party testing results that you provide to us as part of the Genetic Testing Services. Genetic Information is broader than the results derived from your genetic test and includes a range of DNA markers such as those associated with your health or other conditions.
- Registration Information. The information you provide about yourself when you register to use our Genetic Testing Services (e.g., name, date of birth, gender, email address, personal traits (e.g., your height and weight), and user ID and password), or purchase our Genetic Testing Services (e.g., shipping address and contact information such as email).
- Saliva Sample. The sample of your saliva that you voluntarily provide to us.
- Self-Disclosed Information. The information you may provide to us through surveys, forms, features, and applications located through our websites, including StrateGene.me, which may include information about your health and conditions, personal traits (e.g., your height), ethnicity, sexual orientation, family history information, or other health-related conditions.
- StrateGene Report Information. The information resulting from an analysis of your Genetic Information, including your single nucleotide polymorphisms, by Dirty Genes LLC or its Service Provider as part of the StrateGene Report service.
Information We Collect
Information you share directly with us
- Registration Information. We may collect Personal Information, such as your name, date of birth, gender, and email address when you purchase the Genetic Testing Services or create an account and register your kit.
- Self-Disclosed Information. You may choose to provide us with this additional information about yourself through surveys or other forms we may offer or our website, including any website features. Please make sure you have permission to disclose any information about a family member before providing us with their information.
- Customer Service Information. We may collect Personal Information as necessary for us to provide you with support and manage the requests we receive during your use of the Genetic Testing Services.
- Saliva Sample and biobanking. When you register your kit, you are asked to review our StrateGene Biobanking Consent which provides notice of and obtains consent for the storage and re-analysis of your DNA Sample. By consenting to our StrateGene Biobanking Consent Form, you are consenting to our extended storage service (“Biobanking”) where we store your DNA Sample for re-analysis and other purposes you authorize. If you do not consent to our StrateGene Biobanking Consent, your DNA Sample will be destroyed after the laboratory completes its services, subject to the laboratory’s legal and regulatory requirements. Once your DNA Sample has been processed, you can request that your Biobanking preferences be updated and stored samples be destroyed by contacting StrateGene at [email protected]
- Genetic Information. We collect your Genetic Information through the process of collecting and analyzing your Saliva and DNA Sample or when you provide us with your Genetic Information that was generated from a third party service for analysis by us or our third party laboratory.
How and Why We Use Your Personal Information
We generally use your Personal Information in the following ways:
- To provide, analyze, and improve our Genetic Testing Services. To use our Genetic Testing Services, you must create an online account, purchase and register a StrateGene testing kit (or register a kit you received as a gift), and ship your saliva sample to our third party laboratory. Our third party laboratory will analyze your saliva sample to extract your DNA, and use genotyping to generate your Genetic Information. Dirty Genes LLC or our third party analytics provider will then analyze and store your Genetic Information which will also be used to generate your StrateGene Report (depending on the services selected). Your Genetic Information and StrateGene Report will be available to you on secure.StrateGene.me. Further, we may use your information to open your account; communicate with you; and provide new features to our Genetic Testing Services.
- To analyze, process, and deliver your testing results. Once your Genetic Information is generated, your Genetic Information will then be further analyzed by us or our third party analytics provider to generate your StrateGene Report or other Genetic Testing Services you purchase. Depending on the Genetic Testing Services you purchase, we or our third party analytics provider may re-analyze your Genetic Information to provide you with additional reports or updates.
- For StrateGene Research with your consent. You may choose to participate in StrateGene Research by consenting to our StrateGene Research Consent or other consent documents as applicable (collectively, “Consent Form(s)”), which is available in your customer profile page after you create an account and register your kit. “StrateGene Research” refers to research conducted by Dirty Genes LLC (1) aimed at publication in peer-reviewed journals; (2) funded by the federal government; or (3) otherwise conducted or sponsored by, or conducted on behalf of, or in collaboration with third parties, such as non-profit, public, or private commercial entities (e.g., such as academic entities, clinics of health professionals or entities that promote health and well-being).
StrateGene Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of nutritional supplements, medications, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. StrateGene Research uses Aggregated and Anonymized Information, Genetic Information, and/or Self-Disclosed Information as specified in the appropriate Consent Form(s), as explained in greater detail below.
Your Aggregated and Anonymized Information, or de-identified Genetic Information or Self-Disclosed Information, may be used for StrateGene Research only if you have consented to this use by completing the Consent Form(s). If you have completed the applicable Consent Form(s):
- Your Genetic Information and/or Self-Reported Information will be used for research purposes, but it will be de-identified and will not be linked to your Registration Information.
- Dirty Genes LLC may use individual-level Genetic Information and Self-Reported Information internally at Dirty Genes for research purposes.
- Dirty Genes LLC may share summary statistics, which do not identify any particular individual or otherwise contain identifiable individual-level information, with our qualified research collaborators.
- To recruit you for Research. If you use our Genetic Testing Services, we may also use your Personal Information including your Genetic and Self-Disclosed Information to determine whether you would be suitable to take part in StrateGene Research that we, our partners, or other third parties are conducting. For research projects that require additional Self-Disclosed Information from you, we may inform you of the research project via email and provide you with information on how you can sign up to participate. If you do not wish to receive these emails, please contact us via email at [email protected]
- To provide you with marketing communications. We may send you email marketing communications about Dirty Genes LLC’s Genetic Testing Services or otherwise communicate with you for marketing purposes as permitted by law.
- Quality assurance and internal analysis. We may use your Personal Information, including Genetic Information to improve existing DNA-related procedures or services that we offer, develop new products or services, and perform quality control activities.
How We May Share Your Personal Information
- Service Providers. We may share information with third party service providers as necessary for them to help us provide, analyze, and improve our Genetic Testing Services and help us perform our contract with you. When you register to use our Genetic Testing Services, you consent to our sharing of your Personal Information, including your Genetic Information, in the following additional ways:
- To analyze and improve our Genetic Testing Services. We may work with third party service providers who provide analytics or similar services to improve and provide new products or services by conducting internal research on identified and de-identified Genetic and/or Self-Disclosed Information; and performing quality control activities.
- Processing of Genetic Information. When you mail your Saliva Sample directly to our third party laboratory, our third party laboratory will only receive your gender and the Saliva Samples will be identified only by the barcode on the sample kit]. Before processing your Saliva Sample, any “sender information” received in a sample kit’s packaging will be discarded by personnel that do not perform testing. After processing your information, our third party laboratory will securely send the resulting Genetic Information to Dirty Genes LLC identified by your unique barcode. The third party laboratory will destroy your Saliva Sample after the laboratory completes its work, subject to the laboratory’s legal and regulatory requirements. Your DNA Sample will also be destroyed, unless you consent to Biobanking and additional analyses.
- Aggregate and Anonymized Information or De-identified Genetic or Self-Disclosed Information. We may share Aggregated and Anonymized Information or de-identified Genetic Information or Self-Disclosed Information with our research partners and third parties as authorized by you when you consent participating in StrateGene Research. Certain identifying information, such as your name, will always be removed before making any research public.
- With government databases. If we partner with, or our research is funded by, certain U.S. agencies like the National Institutes of Health, we may be required to share certain Personal Information to a national database that will be accessible by other researchers. If contribution is required, we will only provide Genetic Information that has had identifying information removed in accordance with U.S. federal regulations. Your information may also be shared with others who review the quality and safety of the research (for example, the U.S. Food and Drug Administration).
Dirty Genes LLC will ask for your explicit consent to share identifiable Genetic Information and Self-Disclosed Information with any third party, other than our Service Provider as necessary for us to provide our Genetic Testing Services.
Your Choices and How to Withdraw Consent from the Genetic Testing Services
- Withdrawal from the Genetic Testing Services and Deletion of Account. You may withdraw from the Genetic Testing Services by deleting your account, or if you are a user with a multi-profile account, by deleting the profile.
Risks Associated with the Raw Data Files
If you participate in the Genetic Testing Services, you will have access the information containing the analysis of your DNA. In other words, your A’s, C’s, G’s and T’s in the evaluated DNA positions. We call this “raw data,” because this type of file needs to be processed in order to extract meaningful information. Raw data files are usually in a human readable format, such as text format, where each row represents:
- a DNA position (also called DNA marker) with the information about the marker name, that typically is a standard name used by researchers to identify a specific site;
- the exact genomic location in human genome; and
- your genotype, that is, the specific variants (A, C, G or T) for that marker.
Due to the nature of raw data files and the necessity of a specialized process to distill information from these files, interpretation of raw data files can be challenging. If you download your raw data, the raw data are only for research or education and are not suitable for medical purposes, including for diagnosing a disease. Further, the raw data may also contain false positive results that could affect further analysis with this data.
By using www.StrateGene.me, you are agreeing that we can use the cookies described in this Cookie Notice.
What are cookies?
- Site Operations: Enabling features that are necessary for providing you the services on our website, such as [identifying you as being signed in, tracking content views so that we can pay the content owners, remembering your preferences, and the number of times you have been shown an advertisement]
- Analytics: Allowing us to understand how our services are being used, track website performance and make improvements
- Personalized Advertising: Delivering tailored advertising based on your preferences or interests across services and devices and measuring the effectiveness of ads
- Social Media: Enabling the sharing of content from our services through social networking and other websites
What types of cookies does Dirty Genes LLC use?
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Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed.
You may be able to opt out of or block tracking by interacting directly with the third-parties who conduct tracking through our Services. Please see below for more information.
You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.
Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.
Your browser or device may include “Do Not Track” functionality. At this time, Dirty Genes LLC does not respond to browser “Do Not Track” signals.