Privacy

OUR PLEDGE

We take the privacy and confidentiality of our customers and visitors seriously. That is why we pledge to respect the privacy of the information we receive from you, to remain transparent and to keep your data safe, within the parameters identified herein. We will also endeavor to provide you with the possibility to decide how your information is shared.

 

1. Overview

This notice discloses the privacy practices for www.sophiagenetics.com and is served by: SOPHiA GENETICS SA which is headquartered at Rue du Centre 172, 1025 Saint-Sulpice, Switzerland and its subsidiaries, including without limitation SOPHiA GENETICS SAS, SOPHiA GENETICS LTD and SOPHiA GENETICS, Inc.

SOPHiA GENETICS’ Privacy Policy (the “Privacy Policy”) explains how information that may be collected from you may be used. This information may be collected in connection with your doing business with SOPHiA GENETICS, including for example, your use of this website (“Site”) or your use of our products or services (“Products”).

In this Privacy Policy the terms “SOPHiA GENETICS”, “we”, ”us”, and “our” refers to SOPHiA GENETICS SA and its affiliates and subsidiaries globally.

 

2. SOPHiA GENETICS is a Global Company Headquartered in Switzerland

Our headquarter is in Switzerland. You acknowledge and consent that any information you provide or we may collect may be used, processed, and transferred to Switzerland and other countries or territories and that those countries or territories may not offer the same level of data protection as the country where you reside.

 

3. What’s Not Covered by This Privacy Policy?

This Policy does not cover the following elements of data:

  1. The receipt, creation, or analysis of genomic or other data derived from people (such

    as through customer’s use of SOPHiA DDM our Software as a Service Products);

  2. Genotyping and sequencing services for research purposes;

  3. The receipt and storage of clinical and administrative data;

  4. The receipt and storage of radiomics images.

Should you provide data not covered by this Privacy Policy to us as part of our offering of Products, such data shall be covered by a distinct contractual relationship, as well as the relevant laws and regulations applicable to you and/or us.

 

4. Information We Collect

We collect various types of information from you, including information you voluntarily provide us, information required to allow us to offer to you the Site or Products and information we get from your use of our Site or Products.

4.1 Information You Provide Us Directly

We may collect information from you, including, but not limited to your username, first and last name, e-mail, password, phone number, and mailing address, when you create an account to log in to our network or at other times. If you provide us feedback or contact us via email, we collect your name and email address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us, such as a resume.

4.2 Information Collected via Technologies

To make our website and related services more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

4.3 Do Not Track

We do not respond to browser-based “do not track” signals. We do not have any third parties that push content to our site.

 

5. How the Information is Collected

Some of this information is collected through your voluntary submission of information. Some of this information is collected through the use of cookies, which may be placed onto your computer. Some of this information is collected through other technologies. The Site or other Products may also use cookies to store user-provided information during your sessions. You can usually set your browser to reject cookies or to alert you before one is placed, if you prefer, but this may mean that you cannot use all features of the Site or the Products.

 

6. Use of your data

We may use the information collected:

  1. To improve the Site, the Products, including any applications, products, services, and

    software available through them;

  2. To improve the customer experience;

  3. For marketing purposes;

  4. To store your interests and preferences in order to customize your use of the Site or

    Products;

  5. To communicate with you (such as for product support and billing issues);

  6. To verify compliance with the terms of use, license, subscription agreement or other

    agreement governing the use of the Site, the Product, or other of our products or

    services;

  7. To authenticate users;

  8. To improve or otherwise modify our Products and/or services;

  9. To compile and analyze trends;

  10. To carry out transactions in connection with you;

  11. We also may aggregate the collected information with information from other

    customers and users of the Site, Products, or other products and services for analysis such as to determine user and performance trends. Generally, any such aggregation will involve de-identified or anonymous data.

 

7. Sharing of Personal Information

As a general rule we do not provide, sell, or lease your personal information to any third parties for their marketing use without your express consent. However, you acknowledge that your personal

information may be provided to third parties in connection with your use of their websites, applications, software, or products.

7.1 Data Storage

We store your account, profile, and member information (including Personal Information) on "cloud" servers operated by us or by third party providers. Our Site and the Products are stored using sufficient technical, physical and administrative security measures, including without limitation the encryption of all stored sequenced data using encryption algorithms.

While we strive to ensure that no data breach you occur, no computer system or transmission of information can ever be completely secure or error-free, and you should not expect that your information will remain private under all circumstances. It is your responsibility to safeguard any passwords, token, ID numbers or similar information associated with your use of the Site or the Products.

7.2 Service Providers

We may rely on various third-party service providers and contractors to provide services that support the Site and our operations, including, without limitation, maintenance of our databases, distribution of emails and newsletters on our behalf, data analysis, payment processing and other services of an administrative nature. Such third-parties may have access to your Personal Information for the purpose of performing the service for which they have been engaged. However, such third-party providers shall remain under confidentiality obligations for as long as they hold personal data from us.

7.3 Compliance with Laws and Law Enforcement

SOPHiA GENETICS cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and other user information when we, in our sole discretion, have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may (either intentionally or unintentionally) be causing injury to or interference with our rights or property, users of our Site, or anyone else who could be harmed by such activities. We may also disclose user information when we believe, in our sole discretion, that such disclosure is required by applicable law. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

7.4 Business Transfers

We reserve the right to transfer any and all information that we collect from Site users, including Personal Information, to a third-party in the event of any corporate reorganization, merger, sale, joint venture, assignment, transfers, or other disposition of all or any portion of SOPHiA GENETICS' business, assets, or stock.

 

8. Changing or deleting your Information

You may access, review, update, correct or delete the Personal Information you provide to us by contacting us. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your account in our system, please contact us at privacy@sophiagenetics.com with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

 

9. Limited use in our email list

We require consent prior to adding you to any emailing list, unless we deem such email communication is required as part of the provision of the Products. If you no longer wish to receive new notices, email newsletters or other future promotional communications from us, you may choose to unsubscribe by clicking on the link at the bottom of any such communication and following the instructions thereto. Alternatively, you may notify us by email at privacy@sophiagenetics.com with the word "remove" in the subject header, and we will remove your name from our email recipient list, within five (5) days’ notice. Opt-out is not possible for necessary service or account maintenance notices or other administrative and transactional notices.

 

10. Google AdWords Remarketing

We use Google AdWords Remarketing to advertise across the Internet. AdWords Remarketing will display relevant ads tailored to you, based on what parts of our sites you have viewed by placing a cookie on your machine. This cookie does not identify you. As an example, it could mean that we advertise to previous visitors who haven’t completed a task on our site such as an incomplete contact form.

If you do not wish to participate in our Google AdWords Remarketing, you can opt out by visiting Google's Ads Preferences Manager.
Y ou can also opt out of any third-party vendor's use of cookies by visiting www.networkadvertising.org/choices.

 

11. Contacting You

We may contact you as described in this Privacy Policy or applicable contract between us and you or your organization, including as necessary in connection with the Site, the Products, and other products and services you use (e.g., to provide you support, updates to the service, billing issues, etc.).

 

12. Retention of Collected Information

We may retain collected information, even after you remove it from the Site or Products, in order for us to comply with law, to enforce any rights in connection with the Site, our Products, or other of our products and services, to use as provided in this Privacy Policy or applicable contract between us and you or your organization, to improve the Site and/or the Products, and to resolve disputes. Collected information may be stored indefinitely.

 

13. Changes to Privacy Policy

This Privacy Policy is effective as of the date of its last revision. We reserve the right to change this Privacy Policy at any time. When we make changes, we will post the changed Privacy Policy at this site and it will become effective immediately. Your continued access to or use of the Site or Product represents your acceptance of such changed Privacy Policy.

 

14. Security of Collected Information

We are committed to protecting the security of the information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect the information from unauthorized or inappropriate access or use. It is your responsibility to protect the confidentiality of your passwords, account information, and any other access features associated with your access or use of the Site or Product as well as adhering to any applicable Terms of Use or other contract between us and you or your organization.

 

15. Minors

The Site and Products are not directed towards persons under the age of 16. We do not knowingly collect personal information from minors under the age of 16 that use the Site or Products. If you become aware that a user under the age of 16 has used the Site, please contact SOPHiA GENETICS at privacy@sophiagenetics.com. If we become aware that a child under 16 has provided us with Personal Data, SOPHiA GENETICS will take the necessary steps to have that Personal Data irrevocably removed.

 

16. Your California Privacy rights (for users located in California)

Under California Civil Code Section 1798.83 (known as the “Shine the Light” law), SOPHiA GENETICS customers who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to our affiliates or to third parties their direct marketing purposes. To make such request, please write to us at the following address: SOPHiA GENETICS SA, Rue du Centre 172, 1025 Saint-Sulpice, Switzerland or you may send us an email at privacy@sophiagenetics.com.

 

17. Canada’s CASL (for consumers located in Canada)

In accordance with Canada’s Anti-Spam Act, we will ask for your specific consent before adding you to our mailing list or sending you email communications. Once you agree to be added to the mailing list, the provisions of this Privacy Policy shall apply, and you will have the possibility to opt-out at any time, as provided in 9. If we send you by mistake an email while you did not agree to be added to our mailing list, please contact us at privacy@sophiagenetics.com so we may correct the situation promptly.

 

18. Privacy Compliance (General Data Protection Regulation)

SOPHiA GENETICS is compliant with the General Data Protection Regulation (“GDPR”) as it becomes effective starting May 25th, 2018. As provided for by GDPR, SOPHiA GENETICS positions remains a data processor (or a subprocessor) of its clients, whom are either Data Controllers or Data Processors. As such, SOPHiA GENETICS is not liable for the provisions of GDPR that pertain to the Data Controllers, unless SOPHiA GENETICS acts in the capacity of a Data Controller.

Data Processor obligations, are indicated in the document entitled GDPR Addendum, which may be requested to SOPHiA GENETICS, as provided for in Section 28 of GDPR.

 

19. Contact Us

If you have questions regarding this Privacy Policy or how your personal information is handled, SOPHiA GENETICS has appointed a Data Protection Officer for the whole SOPHiA GENETICS Group who can be contacted at Office of the Data Protection Officer – SOPHiA GENETICS SA, Rue du Centre 172, 1025 Saint-Sulpice, Switzerland or privacy@sophiagenetics.com.