1. Introduction
OpenDNA (“we,” “us,” or “our”) is committed to protecting your privacy. This policy explains how we collect, use, process, and disclose personal and genetic data when you interact with our website, testing services, and other offerings.
Last updated: 7/8/2025
2. Data We Collect
a. Personal & Contact Data: Name, email, address, phone, date of birth.
b. Technical & Usage Data: IP address, browser type, device identifiers, access logs.
c. Genetic & Clinical data: We collect raw sequence or genotyping data, health/medical history, and self-reported clinical and lifestyle-related attributes.
d. Aggregated & Research Data: De‑identified summaries or statistical data.
e. Biological Samples: DNA samples are securely stored and processed by GeneByGene, our affiliated genetic testing laboratory. All handling of samples complies with industry-standard privacy and security practices. For details on how GeneByGene manages and protects genetic information, please refer to their privacy policy GeneByGene privacy policy.
3. How We Use Your Data
- Service Delivery: Analyze genetic and clinical data for reports, and for personalized insights.
- Research & Development: Only with explicit, opt‑in consent, and always with data de‑identified.
- Communications: To provide updates, support, and surveys.
- Security & Compliance: Fraud prevention, legal obligations (HIPAA, GINA).
4. Legal Basis for Processing
- Consent: For collection/sharing of genetic data, research, marketing.
- Contractual Necessity: For providing services.
- Legitimate Interests: Improving service quality, preventing fraud.
- Legal Obligations: Responding to law enforcement requests, preserving public safety.
5. Data Sharing & Disclosure
We do not sell your personal or genetic data. We may share it under the following conditions:
- Service vendors (lab testing, storage, IT) under confidentiality and HIPAA agreements.
- With patient consent, de-identified, for research or clinical collaborations.
- Legal requirements: subpoena, court order, regulatory compliance.
- Corporate changes: merger, sale—with restrictions for buyers to honor our policy.
6. How We Protect Your Data
- Encryption in transit & at rest
- Physical and logical access controls
- Two-factor authentication for accounts
- Regular audits & monitoring
- HIPAA compliance
7. Retention & Sample Disposal
- Data retention: As long as needed for service delivery, compliance, or with ongoing consent.
- Biological sample storage/disposal: Samples are stored according to Gene by Gene’s privacy policy GeneByGene privacy policy. According to the policy, a user may request for data deletion and Physical sample destruction or return.
8. Your Rights
- Access & portability: Request copies of your data.
- Rectification & deletion: Correct or delete data. We support full account deletion, though we retain minimal data if legally required.
- Consent withdrawal: For research uses.
- Objection & restriction: Based on legitimate interests.
- Lodge complaints: To us or regulators (e.g. U.S. state AGs).
9. Children’s Privacy
Users must be at least 18 years old (or the age of consent). We do not collect data from minors under 18 without parental consent.
10. Changes to This Policy
We may update this policy to reflect legal or operational changes. Updates will be posted with revised “Last Updated” dates.
11. Contact Information
For questions or privacy concerns, please contact our Chief Information Security Officer (CISO)
Email: erez@open-dna.com
Phone: +1 (240) 401-9712
Notes on Compliance and Best Practices
- Based on Future of Privacy Forum’s Best Practices, requiring explicit consent, transparency, and strong security.
- We adhere to GINA to prevent genetic discrimination in employment and health insurance (https://ginahelp.org/)