Last updated: June 24, 2024

HaploX GeneTech (Hong Kong) Limited (hereinafter as "HaploX") is well aware of the importance of user information security and privacy protection, and HaploX will take security protection measures to improve the transparency of information processing and ensure the security and control of your personal information.

HaploX will strictly abide by the applicable laws and regulations and follow the following user information and privacy protection principles to provide you with safe and reliable services, including but not limited to the recommended products for scientific research and testing, promotion of clinical research, clinical research project recommendation, disease field research, etc.:

1. Reasonably necessary: In order to provide you with better services, HaploX only collects necessary information. The information collected will be used to provide you with suitable solutions and services.
2. Be fully informed: HaploX strives to use concise and easy-to-understand expressions to state user information and privacy protection policies to you, so that you can clearly understand how HaploX processes information, and you can freely and actively decide whether to provide relevant information to relevant personnel of HyproX.
3. Safe and reliable: HaploX makes every effort to prevent the leakage, damage and abuse of your information through reasonable and effective information security technology and management processes. HaploX integrates the concept of privacy protection into all aspects of the service process.

The Privacy Policy applies to personal information collected or processed by HaploX Online (through Website, App, Email, and others) ("Online Services"); and in other situations where you interact with HaploX, including, but not limited to, interacting with or visiting HaploX's sites and offices or HaploX's events (e.g., trade shows and conferences) (collectively, the "Products and Services"). It also applies to personal information that is collected or processed when you interact with HaploX in person, by phone or by mail.

This Privacy Policy outlines the types of personal information that HaploX may collect or process, how HaploX uses and discloses that personal information, and how you may exercise any rights you may have regarding HaploX's processing of your personal information. By providing your personal information to HaploX or otherwise interacting with HaploX, you agree to this Notice and Policy to the extent permitted by applicable law. If you disagree with the policies, procedures, and practices described herein, you may choose not to access or use HaploX's products or services, or not to transmit personal information to HaploX.

This Privacy Policy will help you understand the following:

1. Definitions

   • "Third Party" means an entity or individual with no ownership or control relationship with HaploX.
   • "Personal information" or "personal data" refers to personal information, which refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information. Such as name, date of birth, ID number, personal biometric information, address, communication contact information, communication records and content, health and physiological information, etc.
   • "Sensitive personal information" refers to personal information that could easily endanger personal and property safety or lead to harm if leaked, disclosed, or abused.
   • "Data Breach" is a breach of security leading to the accidental or unlawful destruction, loss, alteration, or unauthorized disclosure of, or access to, personal information.

2. What and how HaploX collects your personal information

   HaploX collects personal information directly from the personal information Subject or from a Third Party with the consent of the Personal Information Subject, where not prohibited by applicable laws.
   The personal information collected includes, but is not limited to:

   • Full name, address and contact details
   • Job title and employer details
   • Date of birth
   • Gender
   • Weight
   • Height
   • Nationality
   • Identification details
   • Financial Information
   • Internet-connected device and browsing information
   • Content you choose to share
   • Marketing and Communications Preferences

   2.1 Information You Provide Directly to HaploX

   HaploX collects certain personal information, including genetic data, directly from you under the following circumstances:

   • When you complete a contract or place an order for HaploX’s services
   • When you send a test request to HaploX or a local service provider contracted by HaploX
   • When you sign up for a HaploX customer account on HaploX's website
   • When you request a quotation or place an order on HaploX's website
   • When you submit a quote request or send an inquiry through HaploX's website
   • When you request HaploX to claim insurance compensation on behalf of you
   • When you provide your details at conferences, events, or tradeshows
   • When you respond to emails from HaploX that you have agreed to receive
   • If you contact HaploX or send a message through social media channels

   This information is essential for fulfilling the contract or purchase order between you and HaploX and for complying with legal obligations. Without it, HaploX may be unable to provide the requested services.

   2.2. Information HaploX Collect from Third Parties

   When third parties collect your information with your informed consent, their privacy policies and practices will apply. HaploX is not responsible for the privacy practices of these third parties, and this privacy policy does not cover your activities on their services. HaploX recommend reviewing their privacy policies before providing any information.
   Third-party service providers acting on our behalf must sign confidentiality agreements and will process personal information only as necessary to perform their functions in accordance with this Notice and applicable laws.
   HaploX may combine personal information collected from various sources to enhance HaploX’s services. Where law permits, HaploX may indirectly collect your personal information from third parties. HaploX strive to verify the legitimacy of these sources; however, HaploX do not control or supervise third-party data processing. Any requests regarding the disclosure of your personal information to HaploX should be directed to the third party.

3. Automatic Collection of Personal Information Using Cookies and Similar Technologies

   A cookie is a plain text file stored on your computer or mobile device by web servers and can only be retrieved or read by the server that created it. Each Cookie is unique to your web browser or mobile application and typically includes an identifier, site name, and some numbers and characters.
   Cookies allow websites to store data such as user preferences or shopping cart contents.
   To ensure our website's proper functioning and personalize your experience, we use Cookies and similar tracking technologies (e.g., web beacons, pixels, mobile identifiers) to analyze trends, operate our site, track user movements, and gather demographic information. We will not use Cookies for purposes other than those stated in this privacy policy.
   As with most websites, we automatically collect certain information, which may include IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, files viewed on our site (e.g., HTML pages, graphics), operating system, date/time stamp, and clickstream data to analyze trends and administer the site.
   You can manage or delete Cookies according to your preferences. Most web browsers offer a Do Not Track function. If enabled, our websites will respect this choice.
   HaploX products or services may link to external websites, applications, products, or services not owned or operated by HaploX. Please review the privacy policies of these third-party websites and services, as we are not responsible for their privacy practices.

4. How HaploX Uses Your Personal Information

   • Perform HaploX's services
   • Enhance HaploX's services
   • Keep you informed about HaploX's services
   • Contact you regarding other relevant services you might be interested in

   4.1 Use Upon Your Consent

   With your consent, HaploX may process your personal information for the following purposes:

   Providing and improving HaploX's Services: HaploX use the personal information collected by HaploX to provide the services, process your orders, and fulfill contractual obligations between you and HaploX. HaploX will not use your genetic data for any purpose other than providing services without your consent.
   Advertising and Marketing: HaploX use your personal information to personalize and enhance HaploX's advertising, send you promotional messages, and provide marketing and other information that may interest you based on your preferences.
   HaploX will obtain your consent in advance if we intend to use your information for purposes other than those specified in this privacy policy.

   4.2 Use Without Your Consent

   In accordance with applicable law, HaploX may process your personal information without your consent for the following purposes:

   • To fulfill contractual obligations based on agreements with you
   • To protect the vital interests of the personal information subject or another individual if the subject is physically or legally incapable of giving consent
   • To comply with applicable laws, regulations, guidance, or court orders
   • For HaploX's legitimate interests

5. How long HaploX Keep Your Personal Information

   HaploX retain personal information for as long as necessary for the specific business purpose for which it was collected or as required by law. Whenever possible, HaploX aim to anonymize or remove unnecessary identifiers from records that we may need to keep for extended periods.

6. How HaploX Shares and Discloses Your Personal Information

   Within HaploX, personal information is only accessible to staff members who require it to perform their specific tasks..
   With your consent, HaploX may also share your personal information with affiliates, trusted third parties, vendors, and subcontractors involved in providing services to you. This includes sharing information with insurers when necessary. affiliated companies, trusted third parties, suppliers, and subcontractors involved in providing you with services. This includes sharing information with insurance companies if their involvement is necessary.
   HaploX will not share or disclose your personal information without your consent unless:

   • Required by applicable local law or court order concerning national security, public security, public health, or significant public interest
   • Directly related to the investigation, prosecution, trial, or execution of criminal judgments
   • Necessary to protect the life, property, or other significant legal rights and interests of personal information subject or others, and obtaining consent is unreasonably difficult or impractical.
   • The personal information has been publicly disclosed by the subject
   • Otherwise provided by applicable laws and regulations.

7. How Your Personal Information Is Transferred

   Subject to local legal requirements, your personal information may be transferred, stored and processed outside the country where you reside or have ordered HaploX’s services. This includes transfers to HaploX's affiliates companies and service providers in other jurisdictions, where it may become subject to local laws. The primary location for storing or processing your personal information for the services you have ordered will be specified in the service contract or test request form.
   HaploX will only share your personal information with HaploX's subsidiaries, affiliates, and service providers when necessary to fulfill the purpose for which you provided it, particularly for delivering services and support. HaploX ensures that HaploX's affiliated companies adhere to HaploX's data protection policy, this privacy notice, and applicable local laws when handling personal information. Additionally, HaploX's service providers implement adequate safeguards to protect the personal information entrusted to them, as described below.

   7.1 Transfer of Personal Information across National Borders

   Please note that the personal information collected and processed by HaploX may be transferred and maintained outside your country, where privacy laws may not be as protective as those in your country. HaploX will implement lawful transfer mechanisms and adequate protection measures in accordance with applicable legal requirements to protect your personal information

8. How HaploX Protect Your Personal Information

   In accordance with applicable laws and requirements, HaploX has implemented physical, technical, and administrative safeguards to protect personal information from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure, consistent with legal obligations and industry practices. However, as with all websites, applications, products, and services, HaploX cannot guarantee absolute security for data collected through HaploX's products and services. You are also responsible for safeguarding passwords, ID numbers, and similar personal information associated with your use of HaploX's products and services. When HaploX shares personal information with external suppliers, subcontractors, or service providers, HaploX may establish written agreements that require them to keep the personal information confidential and implement appropriate security measures to protect it. Some safeguards HaploX use include firewalls, data encryption, and access controls. For example, HaploX strictly limits the scope of personnel who have access to information, requires them to comply with confidentiality obligations, conduct security self-assessments, organize relevant employee training, etc.
   In the event of a personal information breach, HaploX will inform you without undue delay about the primary conditions and potential impact of the breach, response measures, precautionary suggestions, and corrective actions. To the extent permitted by law, HaploX will notify you promptly via email, fax, telephone, push notification, or other appropriate communication methods. If individual notification is not feasible, HaploX will issue a public announcement.

9. Your Rights

   HaploX respects your legal rights concerning your personal information. You may exercise the following rights by contacting HaploX via the email address provided at the end of this Policy (see "Contacting HaploX"). For security purposes, HaploX may require you to verify your identity before processing your request.

   • Access: Unless otherwise restricted by applicable laws, you have the right to access and request a copy of the personal information HaploX holds about you.
   • Information: HaploX aim to be transparent about how HaploX uses your personal information. This Privacy Policy provides detailed information about HaploX's data usage practices.
   • Rectification: If you discover any inaccuracies or incomplete information in your personal information, you have the right to request corrections.
   • Deletion: Under certain conditions, you can request the deletion of your personal information if there is no legal basis for HaploX to continue processing it.
   • Restriction: You may ask HaploX to limit the processing of your personal information. Although restricted, HaploX can still store your data, but will not process it further.
   • Objection: You have the right to object to the processing of your data, even if it is based on HaploX's legitimate interests, official authorization, direct marketing or statistical purposes.
   • Complaint: You have the right to file a complaint with your local data protection authority if you believe your privacy rights have been violated or if you have suffered due to unlawful processing of your personal information.
   • Withdrawal of Consent: You may withdraw your consent or refuse to transfer your personal information at any time by sending a written statement to HaploX. HaploX will honor your choice in accordance with HaploX’s legal obligations. Note that this may affect our ability to perform actions necessary to fulfill the purposes outlined in this privacy policy and could impact our interactions with you and related entities. This withdrawal will not affect the legality of processing based on consent before its withdrawal. HaploX will not be responsible for any direct or indirect damage resulting from the withdrawal of consent.

   Please note that HaploX may be contractually obligated to retain certain information for legitimate business interests, to comply with legal requirements, or as mandated by current applicable laws and regulations.Please note that HaploX may be contractually obligated to retain certain information for legitimate business interests, to comply with legal requirements, or as mandated by current applicable laws and regulations.

10. How HaploX Process Personal Information of Minors

    For minors, HaploX will only use, share, transfer or disclose personal information as permitted by laws and regulations, with the explicit consent of the guardian, or as necessary to protect minors. If HaploX discovers that it has collected a minor's information without permission, HaploX will immediately delete the data. A legal custodian is defined as each parent if they are married and not undergoing divorce proceedings or a parent/third party appointed as the minor’s custodian by a competent court.

11. Updates to this Privacy Policy

    HaploX periodically updates this Privacy Policy to reflect new legal, technical, or business developments. Changes may occur due to modifications in HaploX's service model, ownership structure, organizational structure, or the primary recipients of disclosed personal information, among other reasons.
    HaploX will notify you of significant changes by updating the "Last Updated" date on the HaploX website and posting the revised privacy policy. HaploX recommend revisiting this Policy periodically to stay informed of any updates.

12. Contact HaploX

    If you have any questions about the privacy policy, please contact HaploX at support@haplox.net. HaploX will respond to your inquiry as required by law.