Personal Information Collected by Acorn
Through your use of our products and services, including cell collection, cryopreservation, and analysis services, and use of online services, mobile applications, and other online interactions with Acorn (collectively, the “Services”), Acorn may collect the following personal information (“Personal Information”):
- Information which may be used to identify you, either alone or in combination with other information, including but not limited to your name, address, email address, user ID, password, and other information which you supply to Acorn upon registration for Services or at any other time;
- Your credit card or other payment information;
- Information you submit to Acorn relating to your medical history or genealogy;
- Information about your genetic makeup gathered from the analysis of hair follicles or other tissue or cell samples you provide to Acorn, or other information about your genetic makeup which you may supply to Acorn (“Genetic Information”);
- Information about your cells gathered from the analysis of hair follicles or other tissue or cell samples you provide to Acorn including, for example, information about the viability of your cells and telomere length (“Cellular Information”); and
- Information about your interaction with Acorn websites, mobile applications, and other information services, including IP addresses, browser information, ISP, referring/exit pages, platform, date/time stamp, and other information relating to your use of online Services and other online interactions with Acorn.
Genetic Information is information about your inherited characteristics and can be highly sensitive personal information. Cellular Information is information about the state of cells in the samples you provide to Acorn, and may reveal details about your inherited characteristics or medical history. Combined with contact, health, lifestyle, and financial information, Genetic Information and Cellular Information can provide a lot of information about you. Your Genetic Information can potentially reveal personal information of your family members as well.
Use of Personal Information
Acorn may use your Personal Information to provide you with the Services. Acorn may use your Personal Information to process, analyze, and deliver analysis results to you as part of the Services. Acorn may also use your Personal Information to monitor usage of our Services, analyze how the Services are used, and to improve the Services for you and for other users.
Acorn may also use your Personal Information to communicate with you about the Services, provide you with customer support, to conduct market surveys and polls, to obtain testimonials, or to send you marketing communications.
Acorn may also use your Personal Information to investigate legal claims and for such other purposes as you may otherwise consent to from time to time.
Acorn may use and process your Personal Information to generate aggregated or anonymized data sets where it is no longer identifiable as your own, for instance by removing any information that would allow you to be identified and associated with any particular Genetic Information or Cellular Information, and/or by combining your Personal Information with similar information from a number of other individuals to create aggregated datasets (“Anonymized Information”). Anonymized Information is no longer considered to be Personal Information.
Acorn may use Anonymized Information, and, where we have express consent to, your Personal Information, to conduct scientific research, market research, or to develop or commercialize new products which may or may not form part of the Services.
We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable privacy laws. We will process, collect, use, and disclose information received through our website only to pursue our legitimate business interests in keeping you updated on our services and products, respond to your queries, establish communication with you and your company, and to enhance user experience by analyzing your use of our website.
Disclosure of Personal Information
Acorn may disclose your Personal Information to third parties when the disclosure is necessary to provide you with the Services, for example, to process credit card information and payments, to storage or process data on an on-premise or cloud-based server, or to perform data analysis. If we provide information to third party service providers, we require that the service providers keep your Personal Information secure, and only handle it for limited purposes. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes.
Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; (f) to allow us to pursue available remedies or limit the damages that we may sustain.
Acorn may disclose or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation, or any other type of acquisition, disposal, transfer, conveyance, or financing of all or any portion of Acorn or of any of the business or assets or shares of Acorn or a division thereof, in order for you to continue to receive the Services from such third party, in accordance with applicable law.
If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.
Protection of Personal Information
Acorn will ensure that access to your Personal Information is restricted to selected employees or representatives that have a need to access the Personal Information to provide you with the Services.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “How to Contact Us” section below.
Transfer, Storage and Retention of Personal Information
Your Personal Information may be stored and processed at our offices in Canada, or at the office of our third party service providers. Personal Information may be transferred to and stored outside of Canada, including in the United States. As a result, your Personal Information may be subject to privacy laws which may be different from, or not as strict as in Canada.
Acorn retains Personal Information for as long as necessary to fulfill the purposes for which it was collected.
Opting Out of Communications
If you no longer want to receive marketing-related emails from us, you may opt-out of receiving emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below.
We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.
Third Party Websites and Services
Access to, Correcting or Updating Your Personal Information
You have the right to access, update, and correct your Personal Information in our custody and control, subject to certain exceptions under law.
If you request access to Personal Information, subject to certain exceptions, we will inform you of the existence, use and disclosure of your Personal Information that is under Acorn’s control.
You may request to access, update and correct inaccuracies in your personal information that we have in our custody or control by contacting us at email@example.com. We may request certain personal information from you for the purposes of verifying your identity before providing access to any records.
How to Contact Us
For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor