Privacy Policy

Effective date: July 28, 2021

We at Othram Inc., a Delaware corporation doing business as DNASolves (“DNASolves,” “our,” “us”, or “we”), value your privacy. This privacy policy (this “Policy”) describes the privacy practices of DNASolves and applies to the DNASolves® family of offerings (the “Offerings”) provided by DNASolves. The Offerings include all websites, products, and services offered by or through, or maintained under, the DNASolves® brand, including (1) dnasolves.com, (2) connect.dnasolves.com and the DNASolves® Connect program, and (3) the repository of consented DNA profiles collected and maintained by DNASolves that have been voluntarily submitted by persons like you (the “Registry”).

  1. Scope. In this Policy, we describe how we collect, use, and disclose information about users of the Offerings. This Policy is incorporated into, and made a part of, DNASolves’ Terms of Use (the “Terms of Use”) and is subject to all terms and conditions of the Terms of Use, including any disclaimers, waivers, limitations, or dispute resolution procedures set forth in the Terms of Use. Capitalized terms (such as Your Account or Registration Information) that are used but not defined in this Policy have the meanings given to such terms in the Terms of Use. Please refer to the Terms of Use for those definitions. You agree that your personal information will be handled as described in this Policy.
  2. Changes. We may change this Policy from time-to-time, so please be sure to check back periodically. We will post any changes to this Policy on dnasolves.com. If we make any changes to this Policy that materially affect our practices about the personal information that we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as via email or prominent notice on dnasolves.com.
  3. Contact Us. If you have questions about the privacy aspects of the Offerings or would like to make a complaint, please contact us at support@dnasolves.com.
  4. Collection of Information. We may collect information directly from you and by automated means as set out below. The type of information that we collect from you depends on your interaction with the Offerings, but generally includes the below information.
    1. Account Registration.
      1. In connection with certain Offerings, you will be required to create Your Account and submit your Registration Information. This will likely include, among other items:
        1. A unique username;
        2. A password;
        3. Your valid email address; and
        4. Your DNA or your DNA profile. Please refer to the Terms of Use for a description of the difference between your DNA and your DNA profile.
      2. As a registered user, you may be required to provide further information and you may be allowed to submit additional DNA data for other persons. In such cases, you may be required to provide, among other items:
        1. Legal names;
        2. Dates of birth; and
        3. Names of parents
      3. By submitting the information described in this Section 4.1, you acknowledge and agree that such information is offered voluntarily by you to allow for access to, and sharing of, your data in accordance with this Policy and the Terms of Use. If you are located outside of the United States, you consent to the storage, processing, and transfer of your personal information outside of your country. Any DNA or DNA profiles that you submit, whether yours or belonging to another person, are jointly referred to in this Policy as “DNA Data.”
    2. DNA Data.
      1. When you upload DNA Data through the Offerings, you agree that the DNA Data you provide meets one of the following criteria:
        1. It is your DNA Data;
        2. It is the DNA Data of a person for whom you are a legal guardian;
        3. It is the DNA Data of a person who has granted you specific authorization to upload such person’s DNA Data through the Offerings; or
        4. It is the DNA Data of a person known by you to be deceased.
      2. You acknowledge and agree that you will not upload DNA Data that does not satisfy one of the criteria in Section 4.2(a).
      3. DNASolves will not be responsible for any DNA Data provided to DNASolves in violation of this Policy. Violators of this Policy will have such violators’ DNA Data and other personal information deleted without warning and account access revoked. Additional remedial steps may also be taken, including any legal action allowed under law.
    3. Interactions and Communications. We collect information, including personal information, directly from you, such as when you request additional information from us and reach out to connect with us. We also maintain records of customer service and other communications with users.
    4. Usage Data. We automatically collect information regarding your use of the Offerings through cookies, web beacons, log files, and possibly including other methods. Information collected includes: (1) IP address, (2) app identifier, (3) device ID, (4) advertising ID, (5) location information, (6) browser type, (7) device type, (8) domain name, (9) the website from which you navigated to the Offerings, (10) the website to which you navigate after leaving the Offerings, (11) the dates and times you access the Offerings and perform certain activities, (12) device name and model, (13) operating system type, name, and version, (14) the length of time that you are logged into or using the Offerings, (15) the links you click, and (16) your other activities within the Offerings (all of these are jointly defined as “Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section title “Third-Party Analytics” below for more information.
  5. Use of Information. We use your information, including your personal information, as set forth below:
    1. Providing or Improving Our Services. We use your information to provide and maintain our Offerings; to improve our Offerings; to develop new features, products, or services; to perform technical operations, such as updating software; and for other customer service and support purposes.
    2. Research and Analytics. We use your information to monitor, analyze, and understand usage and activity trends, to conduct analytics on photos and images, and for other research, analytical, and statistical purposes.
    3. Marketing and Communications. We use your information to communicate with you about your use of our Offerings via email, including to send you updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Please see the “Your Choices” section for more information about how to change your communications preferences.
    4. Protecting Rights and Interests. We use your information to protect the safety, rights, property, or security of DNASolves, the Offerings, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or the Terms of Use.
    5. Legal Compliance. We use your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
    6. General Business Operations. We use your information where necessary for the administration of our general business, accounting, recordkeeping, and legal functions and as part of our routine business administration, such as employee training, compliance auditing, and similar internal activities.
  6. Disclosure of Information. In general, we may share your information, including personal information, as follows:
    1. Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors, or agents who perform functions on our behalf.
    2. Business Transfers. We may disclose your information to another entity in connection with an acquisition or merger, sale, or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions.
    3. Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of DNASolves, the Offerings, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that we, in our sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Policy or the Terms of Use.
    4. Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
    5. Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about you and other users for analytics, research, compliance, or other purposes.
  7. Third-Party Analytics. We may use third-party analytics companies, for example, Google Analytics, to evaluate use of the Offerings. We use these tools to help us understand use of, and to improve, the Offerings, performance, ad campaigns, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform such entities’ services.
  8. Third-Party Sites and Services. The Offerings may contain links to third-party websites. Any access to, and use of, such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third parties.
  9. Security. For information that we collect, we have implemented precautions to protect such information from loss, misuse, unauthorized access, and unintended disclosure, alternation, or destruction. Please be aware that no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to Your Account, your password, your phone, and your computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your Registration Information private. We are not responsible for any lost, stolen, or compromised Registration Information or for any activity on Your Account, including unauthorized activity.
  10. Your Choices.
    1. Opt-Out. You may opt out of any promotional or informational communications sent by DNASolves by following the opt-out instructions found at dnasolves.com or emailing us at support@dnasolves.com. Please note that it may take up to ten business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information that we think may interest you, we may still send you emails about any Offerings which you have requested or received from us.
    2. Retention. We may retain certain information about you as required by law or as permitted by law for legitimate business purposes. For example, if you request that we delete your information, but we believe that you have violated the Terms of Use, we may retain information about you in order to attempt to resolve the issue before deleting it.
  11. Age Restriction. The Offerings are not designed for children under 18, and we do not intentionally collect information via the Offerings from those we actually know are under 18. If we discover that a person under 18 has provided us with personal information, we will delete such information from our systems.