We collect and handle information to provide, analyze and improve our Services, marketing and advertising purposes within the laws and regulations, to protect with laws and regulations we are subject to, and, when you consent, for research purposes.
We will not sell, lease, or rent your individual-level information to any third-party or to a thirdparty for research purposes without your explicit consent.
We understand and respect the sensitive nature of the information you may provide and strive to be transparent in our collection, use and disclosure of this information, and to protect it following laws and regulations we are subject to, as well as best practices.
a) Account Information: personal information about yourself when purchasing, using or registering for our services.
b) Aggregate Information: information that has been jointly analyzed or evaluated with that of others, such that no specific individual may be reasonably identified.
c) De-Identified Information: information that has been stripped of Account Information and other identifying data such that you cannot be reasonably identified.
d) Genetic Information: information regarding your genotype, generated through the processing of your biological sample by Código 46 or its contractors, or contributed to Código 46.
e) Self-Reported Information: all information about yourself including demographic data, medical history, family history, personal traits, health-related information, habits, and other information you provide through forms, surveys, or features to Código 46.
f) Services: access to Código 46’s site and app as well as genomic analysis (Código collects, analyses and stores the data that make up the DNA code of your genes), and Código 46 account that provides you access to a software platform that allows you to manage your Genetic Information, DNA products, and other settings.
g) Web Behavior Information: information on how you use Código 46’s website (browser type, domains, page views) collected through different technologies that might include cookies. The information we collect helps us to improve our Services.
2) What Information Do We Collect?
a) Personal and Account Information
i) Account: Name, address, phone number, user ID, password you create for the account, credit card or other payment information, Federal Taxpayers Registry and email. These are to create your account, being able to send and access your report, provide our Services and quality control of your data. Your account information also includes records of any correspondence with you and details of your transactions. These will only and exclusively be used for the following purposes: Information and Providing Services, Medical Analysis, Statistical Analysis, Updating of the database, Any purpose that is analogous or compatible with the previous ones.
ii) Self-Reported Information: Data about yourself including demographic data such as age, sex, personal and family medical history, physical features, behavioral information such as exercise habits, or ethnicity.
b) Genetic Information. You may provide us with a biological sample, using our DNA Kit, to allow us to generate Genetic Information for you. In connection with our Services, Código 46, processes and stores this Genetic Information.
c) Sample and Bio-Banking. To use our Services, you must ship your sample to our laboratory using our DNA Kit. Once received, it will be identified with its barcode along with gender and date of birth. Unless you choose to store your sample with Código 46, your saliva
samples and DNA are destroyed 3 months after the laboratory completes its work, unless legal and regulatory requirements require us to maintain physical samples.
d) Computer, Device and Browsing Information. As you interact with our Services online, we may use automatic data collection technologies to collect certain information about your browsing actions, equipment and usage patterns to provide better Services.
e) Gifts. If you purchase a product as a gift for someone else, your gift recipient must fill their own Personal Information, Account Information and Consent Form. We will not share any personal information of the gift recipient with you.
f) Customer Service. When you contact our Customer Center or correspond with us about our Services, we collect information to track and respond to this inquiry, analyze and improve our Services.
g) Other. We are always working to enhance our Services that may result in collection of new types of information. We will update our Privacy Notice as needed.
3) How we use and share information?
a) To provide and improve our Services. We use the information described above to operate, provide, analyze, and improve our Services. These activities include using your information to:
i) Provide you appropriate search results and personalized content
ii) Open your account, enable and process your purchases, communicate with you and implement your requests
iii) Host our website, run our application(s), authenticate your visits and verify your identity
iv) Providing you notices about your account
v) Notifying about updates or changes to our Services
vi) Conduct analytics to improve and enhance our Services
vii) Offer new products or services to you
viii) Implement online marketing campaigns and targeted advertising and to measure their effectiveness
ix) Performing quality control activities
x) Conduct surveys or polls, and obtain testimonials
xi) Process and deliver your genetic reports and results
xii) Perform research and development activities which may include conducting data analysis and research in order to develop new or improve existing products and services.
You may be able to opt-in, opt-out or otherwise adjust your preferences of having your information used for certain of these activities. See below.
b) Using information with your consent. You have the option to participate in Código 46 Research by providing your consent. Código 46 Research refers to research aimed at publications and other research funded by the government such as CONACYT conducted by Código 46. Código 46 Research may be sponsored by, conducted on behalf of or in collaboration with third-parties. We may study a specific group or population, identify potential areas or targets for therapeutics, conduct or support drug development, 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. Código 46 Research uses your aggregate or individual level Genetic Information and SelfReported Information.
i) Consent Process. Your Genetic and Self-Reported Information may be used for Código 46 Research only if you have consented to this use by completing your Consent Form.
ii) De-Identified Information for Research. Your information will not be linked to your Account Information and will be De-Identified to maintain anonymity and protect your privacy.
iii) Withdrawing your consent. You may withdraw consent by emailing our Privacy Department at email@example.com and sending the ARCO Rights form and a copy of your identification. You may also mail it our address. Upon receipt, we will destroy any remnants of your sample or DNA that we have in our possession, and we will prevent your information from being used in new Código 46 Research initiatives that begin up to 30 days after receipt of your request. Any research that has already started with your data or published before said date will not be reversed, undone or withdrawn. Please note that our Código 46 Research activities can be terminated without your prior consent. If you withdraw your consent for research your Genetic Information and Self-Reported Information may still be used by us to provide and improve our Services as described in Section 3.a, and shared as Aggregate or DeIdentified Information that does not reasonably identify you as individual (as descried in section 3.d).
iv) If you do NOT consent to Código 46 Research. If you do not complete or sign an Consent Form or any additional consent your information will not be used for Código 46 Research. However, your Genetic Information and Self-Reported Information may still be used by Código 46 to provide and improve our Services as described in Section
3.a, and shared as Aggregate or De-Identified Information that does not reasonably identify you as individual (as descried in section 3.d).
c) Recruiting for External Research. Healthcare organizations, academic institutions and other research institutions are always conducting interesting new research. We want to make you aware of these opportunities. We may inform you of any third-party opportunities for which you may be eligible. Código 46 does not share individual level Genetic Information or Self-Reported Information to third-parties without your consent, but we may contact you directly. If you do not wish to receive these alerts, you may indicate so in the Consent Form.
d) Information shared with Third-Parties.
i) General Service Providers. We share information described above with our service providers, as necessary so they may be able to provide their services to us. These are companies that help us provide, analyze and improve our Services. For example, we work with a third-party software platform and contractors to manage, analyze and store your data. Our service providers act on Código 46’s behalf. While we implement procedures and contractual terms to protect the confidentiality and security of your information, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.
ii) Aggregate information. We may share aggregate information with third-parties. This information is stripped of information that may identify you and is mostly used in in a statistical statement. Aggregate Information may include a statement such as “60% of our male users share a particular genetic trait”, without providing data or testing results of any individual. We may provide that type of Aggregate Information to business partners but we will never share your individual Genetic Information or SelfReported Information without your consent with any third-party, other than our service providers as necessary to provide our Services.
iii) Commonly Owned Entities. We may share some or all of your information with other companies under common ownership or control of Código 46 in order to provide a better service and improve our Services.
e) Disclosures Required by Law. We may be required to disclose personal data if required to do so by law or in good faith belief that such preservation or disclosure is reasonably necessary to comply with legal or regulatory process, enforce the Código 46 Terms and Conditions and other policies, respond to claims that any content violates the rights of third-parties or protect the rights, property, or personal safety of Código 46, its employees, its clients and the public.
a) Account and Personal Information. If any of this information changes or you wish to modify or delete it, you may access, correct or update it from your account page. You may do this through the Privacy Department at firstname.lastname@example.org by sending the ARCO Rights form and a copy of your identification. Note that you may not be able to delete information that has been shared with third-parties, but we can work with you to prohibit your data being shared in the future. We will respond to your request within 30 days. All your personal data are subject to the applicable legislation in Mexico, therefore we inform you that you have the right to access, rectify, cancel or oppose the treatment given to your personal data.
b) Marketing. You agree to receive promotional emails about our Services. You may always opt-out of receiving certain messages by contacting email@example.com. You may not opt-out of receiving non-promotional messages regarding your account.
c) Information you share with others. Código 46 gives you the ability to share information with friends and family members, doctors or other health care professionals, and/or others outside of our Services. Your health care professional or center may even be the one that ordered the test directly, and therefore receives the results and shares with you. These third-parties may use your information differently than we do under this Privacy Notice. Código 46 will have no responsibility or liability for any consequences that may result because you have released or shared your information with others. If you are a health care professional or other that manages the information of multiple users, please recognize your responsibility to protect the privacy of each person in your account.
d) Closure of your Account. If you no longer wish to participate in our Services you may close your account by sending a request to firstname.lastname@example.org. When closing your account we remove all Genetic Information from your profile within 30 days, and as stated above information previously consented to be used in Código 46 Research cannot be removed from ongoing or finished studies. We may retain limited Personal Information related to your order history for accounting, audit or compliance purposes.
We take the security and privacy of your data seriously. To prevent unauthorized access or disclosure, maintain data accuracy and ensure appropriate use, Código 46 uses a range of technical, administrative and physical measures to protect your Personal Information. All data Self-Reported and Genetic Information is separated from identifying data and encrypted separately. Connections to and from our website and applications are also encrypted.
Protecting your information is also your responsibility. Be responsible for safeguarding your password, account and other authentication information you use to access our Services. Do not disclose this information to any third-party and notify us immediately of any unauthorized use. Código 46 cannot secure information you share with others or ask us to release. Código 46 cannot be held accountable of samples, kits or information that are in transit and have not arrived to our facility.
Your information collected through and for our Services may be stored and processed in Mexico or any other country in which Código 46, its subsidiaries or service providers maintain facilities. Your information may be subject to the laws of those other jurisdictions.
6) Other Information
a) If Código 46 goes through a business transition such as a purchase, merger or acquisition, your information will likely be among the assets transferred. In this case, your information would remain subject to the premises established in any pre-existing Privacy Notice.
b) Minors. No person under the age of 18 can purchase our Services. A parent or guardian may purchase our Services, collect a biological sample, create an account for, and provide information related to his or her child. The parent or guardian assumes full responsibility for ensuring the information provided about his or her child is kept secure and is accurate.
c) Means of Communication. You may specify by which way you want to receive information, postage or email, because if you do not specify this, Código 46, will freely establish the channel they consider appropriate to send information.
d) Changes to this Privacy Notice. Código 46 may modify this privacy notice. Modifications in a material way will be timely informed through email, telephone, website or any other means of communication that Código 46 determines for that purpose. After 30 days, the changes will become effective.
7) Contact Information.
If you have any questions about this Privacy Notice please email at email@example.com or send a letter to:
Departamento de Privacidad
Código 46 S.A. de C.V.
Paseo de las Camelias 3 Int 10
Tabachines Club de Golf
Cuernavaca, Morelos 62498
*Updated February 13, 2019.