Legal Notices – Privacy Policy

Last modified: February 16, 2023

Introduction

This Privacy Policy (“Privacy Policy” or “Policy”) explains how TwinStrand Biosciences, Inc. (“TwinStrand,” “we,” or “us”) collects and uses personal information to provide information and our services to our customers. This Privacy Policy applies to personal information we collect when our customers and their personnel use our website (the “Website”) or when our customers or their personnel otherwise interact with us. It also describes how we collect personal information in connection with the customers’ purchase and use of our offerings, which are described below. This Privacy Policy does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

Please read this Policy carefully to understand our policies and practices regarding personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or our offerings. By accessing or using this Website, or our offerings, you agree to this Privacy Policy. This Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of this Website or our offerings after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates, which will be effective as of the date of any such updates, as posted above.

What We Do

TwinStrand is a genomics company that offers tools to enhance next-generation DNA sequencing accuracy and analytics. TwinStrand provides proprietary sample preparation kits (the “Kits”) and access to post-sequencing advanced error-correction analysis in our DuplexSeq™ Bioinformatics Platform (the “Platform”) that together enable detection of rare genetic variants. Using the Kits, DNA samples are tagged with proprietary identifiers so that each strand of DNA from the sample can be associated with its original molecule and differentiated from the complementary strand of the same molecule. After sequencing, the sequence read data is uploaded by our customers to the Platform for error correction and analysis using our proprietary bioinformatics software.

Information We Collect Through Our Sale of Offerings

Information Collected Through Kits and Platform

Our customers may submit data to our Platform and may modify such data or generate new data using our Platform (all such data referred to as “Sample Data”). The purposes for which we use such Sample Data are set forth in our Product Terms and Conditions, found below (the “Product Terms”), along with this Privacy Policy. We require such Sample Data to be deidentified and anonymized such that the Sample Data cannot be re-associated with an individual or individuals from which the sample originated. We analyze the Sample Data solely for the customer who has provided that data. We also may use Sample Data for purposes of improving the functionality or performance of the Platform. We do not use the Sample Data or the data resulting from the analysis in any other way, except as described in this Policy and in our Product Terms.

Information Collected Through Orders

We may collect certain information about our customers’ personnel when customers submit a purchase order (the “Order Data”). That information may include contact information such as name, email and phone number. We use the Order Data in the following ways:

To provide notices about a customer’s account/subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between a customer and us, including for billing and collection.
To notify customers about changes to our Website or any products or services we offer or provide though it.
In any other way we may describe when a customer provides the information.
To fulfill any other purpose for which a customer provides it.
For any other purpose with a Website visitor’s consent.

Information Collected By Our Personnel

We may also collect information from customers and others through our Sales Team, Application Support Team, or other personnel. This information may include name, email address, phone number, employer and title. We may use this information to improve the quality of our products and services, to improve customer service, or to fulfill any other purpose for which a customer or other individual provides it.

Information We Collect Through Our Website

It is important to note that the Website is not intended for children and we do not knowingly collect data relating to children.

We collect the following information directly:

Information provided by customer’s personnel by filling in a form on our Website on behalf of that individual’s employer. This includes information provided in a customer intake form requesting additional information about Kits and the Platform. In connection with forms, we may collect an individual’s name, email address, telephone number and employer, and any other information provided by the individual completing the form.
Records and copies of correspondence (including email addresses) with customer personnel who contact us.
Individuals’ responses to surveys that we might ask for in connection with research purposes.

We collect certain information automatically as a Website visitor navigates through and searches the Website. Details may include:

Traffic data, location data, logs, and other communication data and the resources that the visitor accesses and uses on the Website.
Information about the visitor’s computer and internet connection, including IP address, operating system, and browser type.
Other Information such as search queries, usage details, and information collected through tools such as Google Tag Manager.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. A visitor may refuse to accept browser cookies by activating the appropriate setting on their browser. However, selecting this setting may prevent access to certain parts of our Website. Unless a visitor has adjusted browser setting so as to refuse cookies, our system may issue cookies when the visitor directs his or her browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about a Website visitor’s preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information” below.
Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use information that we collect about customer personnel or that a visitor provides to us, including any personal information:

To present our Website and its contents to the visitor.
To provide prospective and current customers and their personnel with information and our company, products or services requested from us.

The information we collect helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about a visitor’s preferences, allowing us to customize our Website according to that visitor’s individual interests.
Speed up searches.
Recognize visitors who return to our Website.

Other Ways We Use Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also use a visitor’s or customer’s information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please indicate this in the “Message” box in the form on the Contact page of our website. For more information, see “Choices About How We Use and Disclose Your Information” below.

We may disclose personal information that we collect or that you provide as described in this Privacy Policy:

To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TwinStrand’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TwinStrand about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use, which is may be found above.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TwinStrand, our customers, or others.
To protect ourselves, our customers, and individuals from fraud. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. You can control your information by taking the following steps:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on the Adobe^® website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Promotional Offers from the Company. If you do not wish to have your email address or contact information used by the Company to promote our products or services, you can opt-out by indicating this in the “Message” box on the form on the Contact page of our website located at https://twinstrandbio.com/contact. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions, or by following the “unsubscribe” link contained in the email.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Accessing and Correcting Your Information

You may contact us through our Contact page, located at https://twinstrandbio.com/contact to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We require our third-party data hosting vendors to make data security commitments.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Unethical Behavior Reporting

We are committed to maintaining high ethical standards and ensuring that all our business practices are conducted with integrity. We take any reports of unethical behavior seriously and have created a reporting form to provide our customers with a confidential and secure channel to report any such behavior. Any reports received will be thoroughly investigated and appropriate action will be taken to address the issue. We hope that you will feel comfortable using this form without fear of retaliation or retribution as it will help us to maintain the highest ethical standards in all our business operations.

To use this form, please click on the following link: Report Unethical Behavior

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address you specified in your order (if applicable) or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

TwinStrand Biosciences, Inc.
3131 Elliott Ave, Suite 750
Seattle, WA 98121

You may also reach us through our Contact page, located at https://twinstrandbio.com/contact