GPS Origins™ Privacy Policy
Version June 2016

At GPS Origins™, we respect and protect the privacy of our customers and those who use our websites, products and services. DNA Diagnostic Center, Inc., dba GPS Origins™ (“GPS Origins™” or “we” or “us”) is committed to protecting your privacy. We prepared this Privacy Policy (the “Privacy Policy”) to describe our practices regarding the information we collect from users of our website, located at www.gpsorigins.com, and use of our related services, including without limitation our web applications. By submitting information through our website or through our related services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your information in accordance with this Privacy Policy.

1. Types of Information We Collect.

1.1 Information You Provide Us Directly. We may collect information from you, including, but not limited to your username, first and last name, e-mail, password, phone number, and mailing address, when you create an account to log in to our network or at other times. We retain information that you post, store or upload through your account and/or on our website. If you exchange any messages through our site or through our service, we may store those as well. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us, such as a resume.
1.2 Information and Social Media. We may offer social media services in which our registered users have the ability to share information about themselves with their friends and family, including information about their interests and test results. Information provided by the registered user does so at the discretion of the user, and GPS Origins™ makes no claims or warranties regarding the information that is provided by the user.
1.3 Information Collected via Technology. To make our website and related services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. We also use Cookies (as defined below) and navigational data to gather information regarding the date and time and duration of your visit and the solutions and information for which you searched and which you viewed. This information includes, without limitation, characters you type, your search and browsing history, articles you click, and pages you view. Like most Internet services, we automatically gather this information and store it in log files each time you visit our website or access your account on our network. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our website. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable Cookies, some areas of our website or service may not work properly. We use Google Analytics on our site. Google Analytics is a web analytics service provided by Google. Google Analytics uses cookies to collect anonymous traffic data to help use analyze how users use the website. The information generated by a cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the site, compiling reports on site activity for us and providing other services relating to site activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. By using the website, you consent to the processing of data about you by Google in the manner and for the purposes described in this Privacy Policy.
1.4 Do Not Track. We do not respond to browser-based "do not track" signals. We do not have any third parties that push content to our site.
1.5 US – EU Safe Harbor. The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy the EU law requirement that personal information transferred from the EU to the United States be adequately protected. We comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://www.export.gov/safeharbor/ or at Safe Harbor Policy.

2. Use of Your Data.

2.1 General Use. In general, information you submit to us is used either to respond to requests that you make, to provide our products and services to you, or to otherwise aid us in serving you better. Features of our products and services include the analysis and (with your consent) publication on social media platforms of data that you upload into our system, such as test results generated by us or by your other service providers. We will store and process your uploaded data for such purposes. Other use of your data includes the following: GPS Origins™ uses your information to facilitate the creation of and secure your account on our network; identify you as a user in our system; provide improved administration of our website and services; improve the quality of experience when you interact with our website and services; send you administrative e-mail notifications; or respond to your inquiries related to employment opportunities or other requests.
2.2 Use of your Testing Information. We will only use the DNA results and related personal data that you provide to us or that we provide to you (“Testing Information”) in order to perform for you the services that you ordered or to otherwise respond to your specific requests. Your Testing Information is confidential. We will not disclose your Testing Information to any other person or party for any reason whatsoever, except with respect to anonymous data (as set forth in the next section) or a merger/sale of our company, and unless in connection with a court order or other such legal requirement. You are free to share your Testing Information with third parties at your own discretion and risk.
2.3 Creation of Anonymous Data. We may create anonymous data records from information (including Testing Information) by excluding all information that makes the data personally identifiable to you (such as your name and DNA results). We may use this anonymous data only to analyze request and usage patterns and to help us enhance the content of our services, improve reporting accuracy, and improve site navigation. GPS Origins™ reserves the right to use anonymous data for any purpose in its discretion.
2.4 Feedback. If you provide feedback on any of our services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your information. GPS Origins™ will collect any information contained in such communication and will treat the information in such communication in accordance with this Privacy Policy and Terms of Use.

3. Disclosure of Your information.

3.1 Affiliates. We may share some or all of your information, except Testing Information (aka, DNA test results that you provide to us or that we generate per our DNA testing analysis), with our parent company, any subsidiary, or any other company under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company or our assets, that company will possess the information collected by it and us and will assume the rights and obligations regarding your information collected by us as described in this Privacy Policy.
3.2 Other Disclosures. Regardless of any choices you make regarding your information (as described below), GPS Origins™ may disclose information if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on GPS Origins™; or (b) protect or defend the rights or property of GPS Origins™ or users of the services.

4. Third-party websites. We may link to third-party websites. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our site and go to another site. During this process, another entity may collect information from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or framed websites, or to any collection of data after you click on links to such outside websites.

5. Your Choices Regarding Your information

5.1 Choices. We offer you choices regarding the collection, use, and sharing of your information. We will periodically send you free newsletters and e-mails that directly promote the use of our site or services and may contain advertisements for third party companies. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by opting out here. Should you decide to opt-out of receiving future mailings, we may share your e-mail address with third parties to ensure that you do not receive further communications from third parties. Despite your indicated e-mail preferences, we may send you emails related to your account or transactions thereunder, or notices of any updates to our Terms of Use or Privacy Policy.
5.2 Changes to information. You may change any of your information in your account by sending an email to us at customerservice@gpsorigins.com. You may request deletion of your information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain period of time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

6. Security of Your information. We are committed to protecting the security of your information. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. Despite these measures, you should know that we cannot fully eliminate security risks associated with information, and we do not take responsibility for the security practices of any third-party websites or services (including social media platforms).

7. Dispute Resolution. If you have any questions or concerns, please contact GPS Origins™ by email at customerservice@gpsorigins.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If you and MyDNATest are unable to reach a resolution to the dispute, you may submit your complaint to JAMS for mediation under the JAMS International Mediation Rules, which are accessible on the JAMS website at www.jamsadr.com. Questions or comments regarding this policy should be submitted to directly to our privacy officer here.

8. A Note About Children. We do not intentionally gather information about visitors who are under the age of 18. If you are under the age of 18 you should not use our site or service.

9. A Note to Users Outside of the United States. Your information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of information may be less stringent than the laws in your country.

10. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any substantial changes in the way we use your information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our website or on our service. Any material changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our site or on our service. These changes will be effective immediately for new users of our website or services. Please note that at all times you are responsible for updating your information to provide us with your most current e-mail address. In any event, changes to this Privacy Policy may affect our use of information that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your information, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our website, or services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

11. Contact Information. We welcome your comments or questions regarding this Privacy Policy. Please e-mail us at customerservice@gpsorigins.com or contact us at the following address or phone number:

GPS Origins™
One DDC Way
Fairfield OH 45014
1-800-831-1026

Revision Date: 6/20/2016