Arboretum Privacy Policy

 

Arboretum LifeSciences, Inc. (“Arboretum,” “we,” “our,” and/or “us”) values the privacy of individuals who use our websites and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users”). It applies to research study participants (“Research Participants”) as well as research affiliates (“Research Affiliates”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service .

 

This Privacy Policy does not apply to the extent we process information in the role of a processor or service provider on behalf of our customers (for example, as part of providing our Greenhouse product). In that context, our customers are the data controllers and their privacy policies will apply to the processing of your personal information. We are not responsible for the privacy or data security practices of our customers, which may differ from those disclosed in this Privacy Policy.

 

Information We Collect

 

We may collect a variety of information from or about you or your devices from various sources, as described below.

 

A. Information You Provide to Us.

Registration and Account Information. When you sign up for a Research Participant account, we ask you for your name, email address, and/or phone number to register your account. Within your Research Participant account, you may add additional information such as your date of birth, address, gender, healthcare provider information, and other health-related information. Your profile, and all associated health information, cannot be viewed by other Research Participants, but may be shared with your healthcare providers or to other third parties (such as Research Affiliates) with your consent. Research Affiliate accounts will be provisioned for you by Arboretum.

Reported Health Information. As a Research Participant, you may submit information to us about your health, such as by filling out a health survey questionnaire related to a research study.

Imported Health Information. As a Research Participant, you may import other health data, such as health records imported from patient portals, or wearable device data, using the Services.

Biospecimen Information. As a Research Participant, you may be invited to donate a biospecimen specimen to a research study for genetic sequencing. We collect this information to help facilitate research; we do not share it in response to general third-party inquiries (e.g., requests from your employer or insurance provider). Please see How We Disclose the Information We Collect for more information about our information disclosure practices.

Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone number, the contents of messages or attachments that you may send to us, and other information you choose to provide. When you communicate with us online, third party vendors receive and store these communications on our behalf. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, and your Device Information (described below), to learn how to deliver a better customer experience and improve our Services.

 

Payment Information. If you make a payment on our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.

 

B. Information We Collect When You Use Our Services.

 

Consents. As a Research Participant, when you complete a consent form via our Services, we receive the information that you have included in the consent form.

 

Device Information. We receive information about the device and software you use to access our Services, including IP address (which can be used to infer your general location information), device type, device identifiers, web browser type and version, and operating system version.

 

Usage Information. We automatically receive information about your interactions with our Services, like the pages or other content you view, referrer information (the website you visited before coming to our Services), and the dates and times of your visits.

 

Information from Cookies and Other Tracking Technologies. We and our third-party partners collect information about your activities on our Services using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics, advertising, and security partners, may also use these technologies to collect information about your online activities over time and across different services.

 

C. Information We Receive from Other Sources.

 

Information from Third-party Services. If you choose to link our Services to a third-party account (e.g., an account with your third-party healthcare provider), we may receive information about you, including your profile information, contact information, and health information.

 

Clinical Trial Participant Information. If we receive information about your participation in a clinical trial from a third party (e.g., the trial sponsor) we may link that information to your account.

 

How We Use the Information We Collect

 

We use the information we collect:

 

●      To return genetic sequencing results back to Research Participants, including results such as ancestry information and diagnostic information (where eligible);

●      To identify ways in which genes and other health factors that might increase one’s risk of getting a disease or the likelihood of a treatment response;

●      To notify Research Participants of additional testing or treatment opportunities, including relevant products, services, and research studies such as clinical trials;

●      To provide, maintain, improve, and enhance our Services;

●      To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services;

●      To personalize your experience on our Services such as by providing tailored content and recommendations;

●      To understand and analyze how you use our Services and develop new products, services, features, and functionality;

●      To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

●      For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;

●      To send you text messages;

●      To facilitate transactions and payments;

●      To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as scientific research or to publish reports;

●      To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;

●      For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

●      For other purposes for which we provide specific notice at the time the information is collected.

 

How We Disclose the Information We Collect

 

Affiliates. We may disclose any information we receive to our current or future affiliates for any of the purposes described in this Privacy Policy. 

 

Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services.

 

Healthcare Providers. For Research Participants eligible to receive Research Clinical Results that include diagnostic information, those results may be reported to the healthcare provider(s) involved in your care.

 

Marketing. We may disclose your contact information with third parties so that they can contact you regarding their products and services. For example, we may disclose your contact information with companies that offer products and services related to diagnostic tests or treatments. You can opt out of this data disclosure within your Research Participant account settings, or by emailing us at support@arboretum.bio.

Analytics Partners. We may use analytics services such as Google Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.

 

Advertising Partners. We may work with third-party advertising partners to collect and process your information in order to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info) and serve ads through cookie-based technologies. Please visit their opt-out pages to learn about how you may opt out of receiving certain web-based personalized ads from member companies. These opt-outs will apply only to our third-party advertising partners that are members of these organizations. These opt-outs will not apply when our partners serve ads through non-cookie based technologies.

 

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

 

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

 

Consent. We may also disclose your information with your permission.

 

Your Choices

 

Marketing Communications. We may send you emails concerning research opportunities, our products and services, and third party products and services. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional email messages from us, you will continue to receive administrative messages from us. You can opt out from our promotional SMS messages by replying “STOP” to our message.

Third Parties

 

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

 

Security

 

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

 

Children’s Privacy

 

We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of our Service is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@arboretum.bio.

International Visitors

 

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

 

Update Your Information

 

You can update your account and profile information within your Arboretum account, using the Services we provide to you. To close your account, email support@arboretum.bio.

 

Changes to this Privacy Policy

 

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

 

Contact Information

 

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@arboretum.bio.

 

Last Updated: March 20, 2025