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Privacy Policy

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Privacy Policy2018-09-11T13:56:39+00:00

Thank you for your interest in Genohm (termed as “Genohm” or “Company”); our Websites at https://www.genohm.com, appstore.genohm.com, and other customer-dedicated websites (“Websites”); our digital platform SLIMS (“SLIMS” or “Product”); our Service, in written or oral forms, such as emails, different technical, administrative and other documents; phone or internet calls and other in person discussions (collectively called “Service”) that we provide to the Customers (“Customers”) of our Product and Services.

Introduction

This Genohm Privacy Policy (“Policy”) describes the information that the company gathers through the Websites, the Product or the Service. It details how we process such information with the steps taken to protect it. By visiting the Websites, by purchasing and using the Product or by using the Service, Customers consent to the Genohm Privacy Policy as detailed here under. By agreeing to enter into a business relationship with Genohm, third parties (“Partners”) servicing the Company consent to the Genohm Privacy Policy as detailed here.

Genohm recognizes its responsibility to protect data provided by any individual, whether a Customer, Partner, Employee, or Visitor.  This Policy explains in general terms how we seek to comply with data privacy laws and regulations, including but not limited to the General Data Protection Regulation in the European Union, the Health Insurance Portability and Accountability Act (HIPAA) in the US, and other data protection legislation that may be implemented globally,

This Policy is a component of every business agreement that Genohm enters into with Customers and Partners and has therefore to be duly approved by them.

Definitions

“Company”: see Genohm.

“Customers”: refers to customers of Genohm that use SLIMS and profit from the Service.

“Customers Data”: means data in a digital format that are stored in SLIMS. These can be Personal Data, reports or documents that may identify an individual.

“Data Subjects”: are individuals that are the subject of Personal Data.

“Genohm”: collectively means Genohm branches located in Gent, Belgium (Genohm BVBA); in Durham, NC, USA (Genohm Inc.); in Lausanne, Switzerland (Genohm SA) and elsewhere as every subsidiary follows the same regulations.

“Partners”: are general third parties that provide support to Genohm in some activities required for its business and integration third parties that have developed products integrated with SLIMS to provide a better user experience.

“Personal Data”: is information that can be used to specifically identify an individual or that is linked to information that identifies a specific individual.

“Policy”: refers to the GENOHM Privacy Policy.

“Product”: see SLIMS.

“Service”: is the support given to our Customers during the functional lifecycle of SLIMS.

“SLIMS”: is the digital platform developed by Genohm.

“Visitors”: refers to who visit our Websites.

“Websites”: refers to https://www.genohm.com, appstore.genohm.com and other customer-dedicated websites.

What Information do we collect

Genohm processes different sorts of information in order to be able to function properly and conduct its business successfully. This information can be collected directly from Customers, from the Websites or processed on SLIMS.

Information provided by the Customer: if you are a Customer or a Visitor and you visit our Websites or use SLIMS and the the Service, you may want or be required to provide us with Personal Data. For example, a Visitor requesting information on SLIMS from the Websites may provide us with Personal Data such as name and email address in order to be contacted by one of our engineers. A Customer will be required to provide us with Personal Data such as name, email, mailing address, mobile phone number and billing information.

Information processed on SLIMS: only a Customer can use SLIMS and process Customer Data on the platform. For example, when logging in on its SLIMS account, the Customer will register, treat or store Customer Data there or it will provide Genohm secure access to a set of Customer Data in the course of providing technical Service. Genohm has no direct relationship with the Data Subjects whose Personal Data is hosted on SLIMS as Customer Data. Each Customer has the responsibility to provide notice to its own Data Subjects, customers and partners about the following: 1) how their Personal Data may be shared with Genohm; and 2) how this Personal Data is processed on SLIMS as part of Customer Data.

Information collected through Cookies or other web technologies: When a Customer or a Visitor logs on our Websites, Genohm may record certain usage information from their device by using cookies or other technologies for statistical, website-improvement goals or marketing purposes. This information is automatically collected and may include web browser versions and device type, the web pages or other content the viewed, the dates and times of the visit. This information is gathered independently if the person visiting the Websites is a Customer or a Visitor. The Websites provide to Visitors the possibility to Opt-out from every single third party Cookie. We collect anonymized information that can’t be used to identify Data Subjects. Cookies are developed by third parties. We do not have access to, or control over, the technologies that these third parties have developed in order to collect information.

Other sources of information: in course of its business, Genohm may receive Personal Data from one of its Partners. The Company will process this information in accordance to this Policy.

Genohm can act as a Controller and a Processor of Data

The terms Controller and Processor of Data are found in the EU General Data Protection Regulation (GDPR) which replaces the Data Protection Directive 95/46/EC. This regulation is intended to strengthen and unify data protection for all individuals across the European Union. The regulation covers entities in the EU or outside that collect and process data from EU residents. The GDPR describes how organizations — such as Genohm — must collect, handle, store and dispose personal information of EU citizens. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the GDPR, Genohm has set up a data protection environment that enables any employee to process personal data, i.e. collect, store, use and dispose personal information fairly and safely and without disclosing it unlawfully.

Depending on the nature of the data processed, Genohm can act as Controller or Processor of data.

A Controller of data determines the purposes and means of the processing of Personal Data. In the case of Genohm, for example the Company acts as a Controller with Personal Data from Customers gathered for business follow-up, or when a Visitor submits his Personal Data in the Websites to get more information on SLIMS. Genohm only processes such Personal Data from Customers for Genohm’s legitimate interests or where we have a Customer’s consent. Alternatively, it gathers from Visitors the minimum information necessary to provide them with what they asked. Anonymized data are used for the improvement of the Websites, to give its Visitors a better user-experience. Finally, we may use Personal Data for communication, business development and marketing activities only when positive consent has clearly been given by the Data Subjects.

A Processor of data processes the data on behalf of the Controller. Customers own, control and direct the use of their Customer Data processed on SLIMS, the digital platform developed by the company. They act as Controllers with their Customer Data and Genohm can only act as Processor when the Company is asked to process these data in order to help them in case of a bug or to provide them with another Service. The business relationship between the Customer and Genohm is governed by a commercial contract which contains specific references to the Genohm Privacy Policy. The contract must clearly indicate and clarify in which situation Genohm acts as the Controller and the Processor of data. Genohm will only act as Processor of Customer Data based on the instructions received by the Customer, i.e. the Controller of data.

The Customer is the Controller of data for any Customer Data processed on SLIMS, as it is installed on Customers’ premises or within a cloud environment, contracted by the Customer. Genohm has no control whatsoever and is not responsible for their content, or about the manner in which such Personal Data is collected and processed. The same applies for the determination of the purposes and means of the processing of such Customer Data.

Nevertheless, Genohm treats Personal Data originating outside of the Company with the same respect and follows the same Data Protection procedures as if they were property of the company.

How do we use this information

Genohm processes the information mentioned here in different ways in order to be able to function properly and conduct its business successfully.

Communication: If a Visitor contacts us via the Contact Form/Get a Demo on our Websites or via the info@genohm.com, jobs@genohm.com email, we may use some Personal Information such as email address or other contact information from the form, to reach out and provide the information requested and to provide further information on our SLIMS platform as well. The same sort of Personal Data may be used to contact a Customer for administrative purposes such as billing, SLIMS Service, to provide information on Product updates and new features, events and workshops organized by the Company. Genohm does not share the Personal Data it has access to with Partners to support their communication plans or other initiatives.

Cookies: Genohm uses Cookies on the Websites to automatically collect information such as remembering a Visitor’s information so that the Visitor will not have to re-enter it during the next visit; to monitor and analyze the effectiveness of the Websites; site usage metrics such as total number of visitors, the pages viewed, timings and other statistical indicators; for marketing purposes.

Genohm Operations: We use administrative information exclusively to provide the best operational experience to our Customers and to provide information that Visitors request.

SLIMS Service: We process Customer Data solely in accordance with the directions provided by the Customer and agreed to in the contract between the two parties.

Statistical analysis: Genohm uses web analysis technologies such as Google Analytics to collect statistical data on the usage of the Websites. We measure and evaluate access and traffic create user navigation reports for the improvement of the Websites. Google operates independently from us and has its own privacy policy. We strongly suggest you review it here: Google Analytics Privacy and Data Sharing. The data is anonymized, we do not use any of this information to identify Visitors and we do not share it or sell it.

Websites improvement: We use the information gathered from Cookies and other web technologies to understand and analyze what are the usage trends and preferences of the Visitors of our Websites. This helps us to improve the Visitor experience and to develop new features.

Marketing purposes: we may use anonymized data for marketing purposes through mandated third parties such as Google.

Disclosure of Information

We do not intentionally disclose Personal Data or Customer Data that was collected on the Websites or directly provided by Customers or Visitors as described here. Disclosure of this information can only be made with your consent.

General Partners: Genohm works with general third parties that provide services in administrative matters, in technical and product development, in communication, marketing and business development. Genohm collects only the necessary Personal Data required for the performance of the contracts running with the General Partners. Some of these General Partners require access to, or process Personal Data or Customer Data in order to be able to provide those services to Genohm. We share with our General Partners the information that is reasonably necessary for them to perform their functions. The contracts between Genohm and these General Partners stipulate the requirements for them to maintain the confidentiality of that Personal Data or Customer Data. The contracts stipulated between Genohm and its Customers detail which Partners have access to which data, for what reason and with which data protection.

Integration Partners: Genohm works with integration third-parties that have developed software solutions that are integrated with SLIMS to give a better user experience to our Customers. We do not share any sort of Personal Data with integration Partners. Only Customer scientific Data may be processed by the software developed by the integration Partners in order to give our Customers a better user experience. The contracts between Genohm and these integration Partners stipulate the requirements for them to maintain the confidentiality of that Customer Data.

Service Desk: genohm.com contains a link to Genohm’s Service Desk. It is a platform used by Customers to report bugs and suggest new features. This service runs on the JIRA platform developed by Atlassian. The JIRA platform is directly hosted on our servers. Therefore, Atlassian has no access to Personal Data from Customers or other Customer Data that Customers register there when they use JIRA. Genohm does not share any kind of data relating to Customers with Atlassian.

Anonymized information from the Websites: Google Analytics have access to the raw information on the visitors of our Websites. Genohm does not access this information. The Company does not share or sell the anonymized data it has access to.

Law Enforcement, Legal Processes and Compliance: Genohm may be forced to disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws. The Company will disclose information only in response to a relevant valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

Genohm also reserves the right to disclose Personal Data or other information in the case that the Company believes in good faith it is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Company, the Product, the Service, the Websites and any facility or equipment used to perform its business operations, or (v) protect the property of the Company or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

Change of Ownership: information about Customers and Visitors, which may include Personal Data and Customer Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the Personal Data and Customer Data commits to a Privacy Policy that has terms substantially consistent with the GENOHM Privacy Policy.

Customer Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing the operation of the Product, the Service and the Websites, and only if the recipient of the Private Data and Customer Data commits to a Privacy Policy that has terms substantially consistent with the GENOHM Privacy Policy.

What are your Data Protection Rights

Access, Update, Correct, Delete Personal Data: At Genohm we value the importance of Personal Data and Customer Data. Data Protection is important for us. The Company respects your privacy rights and will provide you with reasonable access to the Personal Data that you may have provided through your use of SLIMS, the Websites or other communication channels. If you wish to access, update, correct or delete any Personal Data that the Company holds about you, you may contact per email our Data Protection Responsible at dataprotection@genohm.com or by regular mail addressed to our R&D Europe Office: Genohm BVBA, Dendermondsesteenweg 48B/102, 9000 Gent. Belgium.

At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. Please note that any changes you will make or objections you will raise will be reflected in active databases in a reasonable period of time. However, we may be required to retain certain information for prevention of fraud and abuse, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate legal reason to do so.

It is your right to decline to share certain Personal Data with us or to decline the consent for certain Cookies. Please be aware that in this case, we may not be able to provide to you the full features and functionalities of SLIMS, the Service or the Websites.

Please note that this provision does not apply to Personal Data that is part of Customers Data processed on SLIMS. In this case, the management of the Customers Data is totally dependent from the Customers’ Privacy Policy. Any request for Access, Update, Correct, Delete of these specific Personal Data need be made to the Customer responsible for the processing of such data on SLIMS. If the Customer asks Genohm to delete such data, we will respond to its request within thirty (30) days. The Company requires a written request to do so from the Customer who is responsible for the deletion of that Personal Data, unless we have a legal right to retain such Personal Data. We reserve the right to retain a copy of such data to defend our rights in litigation. Any such request regarding Customer Data should be addressed per email to the Data Protection Responsible at dataprotection@genohm.com or by regular mail addressed to our R&D Europe Office: Genohm BVBA, Dendermondsesteenweg 48B/102, 9000 Gent. Belgium. It should contain all the necessary information for Genohm to identify the Customer and the information to be deleted.

Cookies and other web technologies: The Websites lists all the Cookies and web technologies that Genohm uses. Visitors and Customers may easily opt-out from the automatic collection of navigation information about their visit of the Websites by following the instructions found on the Cookie Policy page on genohm.com.

Communications on SLIMS, Events and Workshops: Visitors of the Websites may have requested information on SLIMS. Customers may be keen on Workshops organized by the Company. Official communication from Genohm will be delivered to Visitors and Customers that have opted-in or expressed their consent to this kind of communications. They may unsubscribe at any time as these communications have an opt-out feature at their bottom that can be easily activated. In case of doubt, please contact via email our Data Protection Responsible at dataprotection@genohm.com or by regular mail addressed to our R&D Europe Office: Genohm BVBA, Dendermondsesteenweg 48B/102, 9000 Gent. Belgium.

Data Protection and Security

Genohm has taken reasonable steps to protect the information that it requires to process to execute its business plan. The Company maintains the necessary administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, loss, alteration, disclosure or access and misuse. We are equipped with effective technologies such as firewalls, encryption, data masking, password protection and other access and authentication controls. We use SSL technology to encrypt sensitive Personal Data during transmission via the internet. In order to further anonymize Personal Data, we use application-layer security features.

Genohm is aware that no data protection or security technology is 100% secure. Therefore, we cannot guarantee the 100% security of any information you submit to us. You submit it at your own risk. The Company has put in place a secure environment in which to process Personal Data. If you believe that your Personal Data has been compromised despite all the data protection and security efforts from our side, please contact by email our Data Protection Officer at dataprotection@genohm.com or by regular mail addressed to our R&D Europe Office: Genohm BVBA, Dendermondsesteenweg 48B/102, 9000 Gent. Belgium.

If we learn of a security systems breach, we will inform you of the occurrence of the breach in the time frame of the requirements of the current applicable law.

Data sharing with integration Partners

The Websites contain links to websites provided by our integration Partners. If you access their websites, products and services through the Websites and you provide them directly with information, be aware that that information is subject to their existing policies governing privacy and security, even if you access them through our Websites. We are not responsible for the privacy and security practices of our integration Partners whose links are provided in the Websites. We strongly suggest that you to learn about their privacy and security policies before providing them with any sort of information.

SLIMS may be integrated with software solutions developed by our integration Partners to give a better user experience to our Customers. The utilization of these integrated software is solely at the discretion of our Customers. These software have only access to Customer Data for further processing and to give our Customers a better user experience. The contracts between Genohm and these integration Partners stipulate the requirements for them to maintain the confidentiality of that Customer Data.

Data Transfer inter-company and outside Genohm

Genohm has offices in several locations worldwide. It is possible that in the course of its business, the company will have to transfer some Personal Data or Customer Data to another office location away from the original location. Therefore, the company has taken the necessary steps in order to protect the safety of the information in these cases.

Where such Personal Data will be transferred to, and processed in the USA by Genohm group companies, Genohm has put in place the European Commission’s model contracts for the transfer of personal data to third countries (the “Model Clauses”), pursuant to Decision 2004/915/EC. Please contact privacy_advocate@agilent.com, if you would like to see a copy of the Model Clauses. We may also transfer your Personal Data to our Genohm group company in Switzerland on the basis that this jurisdiction has been judged by the European Commission to provide adequate data protection laws.

In addition to the above, Genohm’s global organizational structure also requires the global transfer of Personal Data within the Genohm group of companies. As a consequence, as it is in our legitimate interests for the efficient operation of a global company, and as permitted by applicable law, the personal information that you provide to us will be transferred across state or country borders, including to countries outside the country in which you reside (including to countries outside the EEA), to consolidate data storage, simplify information management or synchronize customer relationship activities globally.

We may also share your Personal Data with suppliers. Where the GDPR applies and the recipient of your personal information is located outside the European Economic Area (“EEA”), such transfer will either be: (i) to a recipient certified to the US Department of Commerce’s EU-US Privacy Shield; (ii) based on an adequacy decision of the European Commission (ii) subject to the Model Clauses. For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield website. If you would like to see a copy of the Model Clauses, please contact privacy_advocate@agilent.com

Genohm has established processes, records and registers that make sure that its external partners and service providers that process personal data for administrative purposes are regularly audited and strictly adopt the same regulations. The company does not engage sub-processors to perform its business activities related to the SLIMS platform.

Data Retention

We only retain the Personal Data collected from Customers and Partners for as long as their business relationship with Genohm is active. We retain and use their Personal Data and other information in order to be able to comply with our legal obligations, resolve disputes, and enforce our agreements. Once that account is no longer active, the Personal Data and information will be kept for the necessary time required by the law enforced where the information is processed. Once that retention time expired, all information will be deleted.

We only retain the Personal Data collected from a Visitor, a business prospect, a job candidate or any other person of interest for the Company for a maximum of 5 (five) years. Once that retention time expired, all information will be deleted.

Minors and Children’s Privacy

Processing Personal Data from minors under the age of 18 is not possible without prior verifiable parental consent. If you are employing staff, apprentices, interns or volunteers who are under 18 years of age, you need to obtain their parental consent before allowing them to submit any Personal Data to Genohm. If we learn that such Personal Data has been processed without verifiable parental consent, we will alert you and immediately delete this information.

If you have any specific question on this Policy you can contact us by email at the attention of our Data Protection Officer at: dataprotection@genohm.com.

Or by regular mail addressed to our R&D Europe Office: Genohm BVBA, Dendermondsesteenweg 48B/102, 9000 Gent. Belgium.

We will be pleased to get back you with the requested information. Thank You.

Legal Status of Policy and Policy Changes

The Genohm Privacy Policy is not a contract, and it does not create any legal rights or obligations. Genohm reserves the right to modify or amend this Policy. For instance, the Policy may need to change as new legislation is introduced or as it is amended. An updated Policy will be posted on https://www.genohm.com.

This GENOHM Privacy Policy was last updated on September 11, 2018.