Privacy Policy

PanGenomic Health Corp, (collectively “Nara”, “we”, “us”, or “our”) respects your privacy. This Privacy Policy (“Agreement”) describes how your Personal Information is collected, used, and disclosed through the delivery of our Service.

A. Information Nara Collects

User Personal Information” is any information about you (our “Users”) which could, alone or together with other information, personally identify you or otherwise be reasonably linked or connected with you. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address, and a photograph are examples of “User Personal Information.” User Personal Information does not include aggregated, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize our Website and Service.

Information Users Provide Directly to Nara

  1. Registration Information: We require some basic information at the time of account creation. When you create your own username and password, we ask you for a valid email address.
  2. Payment Information: If you sign on to a paid Account with us, and subscribe to our Subscription Plans, we collect your full name, address, and credit card information or PayPal information. Please note, Nara does not process or store your credit card information or PayPal information, but our third-party payment processor, Stripe, does.
  3. Profile Information: You may choose to give us more information for your Account profile, such as your full name, an avatar which may include a photograph, your biography, your location, your company, and a URL to a third-party website. This information may include User Personal Information. Please note that your profile information may be visible to other Users of our Service.

Information Nara Automatically Collects From Your Use of the Service

  1. Transactional Information: If you have a paid Account with us, and subscribe to our Subscription Plans, or other add-on plans, we automatically collect certain information about your transactions on the Service, such as the date, time, and amount charged.
  2. Usage Information: If you’re accessing our Service or Website, we automatically collect the same basic information that most services collect, subject, where necessary, to your consent. This includes information about how you use the Service, such as the pages you view, the referring site, your IP address and session information, and the date and time of each request. This is information we collect from every visitor to the Website, whether they have an Account or not. This information may include User Personal information.
  3. Cookies: As further described below, we automatically collect information from cookies (such as cookie ID and settings) to keep you logged in, to remember your preferences, to identify you and your device and to analyze your use of our service
  4. Device Information: We may collect certain information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer. This information may include User Personal information.
  5. Information We Collect from Third Parties: Nara may collect User Personal Information from third parties. For example, this may happen if you sign up to receive information about Nara from one of our vendors, partners, or affiliates. If you integrate Nara via API between chat services, we may obtain Personal Information via this integration. Nara does not purchase User Personal Information from third-party data brokers.

B. Information Nara Does Not Collect

We do not intentionally collect “Sensitive Personal Information”, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data.

If you are under the age of 13, you may not have an Account on Nara. Nara does not knowingly collect information from or direct any of our content specifically to anyone under 13. If we learn or have reason to suspect that you are a User who is under the age of 13, we will have to close your Account. Please see our Terms and Conditions Agreement for information about Account termination. Different countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not have an Account on Nara.

C. How Nara Uses Your Information

We may use your information for the following purposes:

  • We use your Registration Information to create your account, and to provide you the Service.
  • We use your Payment Information to provide you with the Paid Account service.
  • We use your User Personal Information, specifically your username, to identify you on Nara.
  • We use your Profile Information to fill out your Account profile and to share that profile with other users if you ask us to.
  • We use your email address to communicate with you if you’ve said that’s okay, and only for the reasons you’ve said that’s okay. Please see our section on email communication for more information.
  • We use User Personal Information to respond to support requests.
  • We may use User Personal Information to invite you to take part in surveys, beta programs, or other research projects, subject, where necessary, to your consent.
  • We use Usage Information and Device Information to better understand how our Users use Nara and to improve our Website and Service.
  • We may use your User Personal Information if it is necessary for security purposes or to investigate possible fraud or attempts to harm Nara or our Users.
  • We may use your User Personal Information to comply with our legal obligations, protect our intellectual property, and enforce our Terms and Conditions Agreement.
  • We limit our use of your User Personal Information to the purposes listed in this Privacy Policy. If we need to use your User Personal Information for other purposes, we will ask your permission first. You can always see what information we have, how we’re using it, and what permissions you have given us in your account settings.

Our Legal Bases for Processing Information

To the extent that our processing of your User Personal Information is subject to certain international laws, Nara is required to notify you about the legal basis on which we process User Personal Information. Nara processes User Personal Information on the following legal bases:
  1. Contract Performance:
    1. When you create a Nara Account, you provide your Registration Information. We require this information for you to enter into the Terms and Conditions Agreement with us, and we process that information on the basis of performing that contract. We also process your username and email address on other legal bases, as described below.
    2. If you have a paid Account with us, we collect and process additional Payment Information on the basis of performing that contract.
  2. Consent:
    1. We rely on your consent to use your User Personal Information under the following circumstances: when you fill out the information in your user profile, and for marketing purposes, where applicable. All of this User Personal Information is entirely optional, and you have the ability to access, modify, and delete it at any time. You may withdraw your consent at any time without penalty by deleting your account.
  3. Legitimate Interests:
    1. Generally, the remainder of the processing of User Personal Information we perform is necessary for the purposes of our legitimate interest, for example, for legal compliance purposes, security purposes, or to maintain ongoing confidentiality, integrity, availability, and resilience of Nara’s systems, Website, and Service.
If you would like to request deletion of data we process on the basis of consent or if you object to our processing of personal information, please contact us at info@nara.care.

D. How Nara Shares the Information We Collect

We may share your User Personal Information with third parties under one of the following circumstances:

With Your Consent

We share your User Personal Information, if you consent, after letting you know what information will be shared, with whom, and why.

With Service Providers

We share User Personal Information with a limited number of service providers who process it on our behalf to provide or improve our Service, and who have agreed to privacy restrictions similar to the ones in our Privacy Policy by signing data protection agreements or making similar commitments. Our service providers perform payment processing, network data transmission, security, and other similar services. While Nara processes all User Personal Information in Canada, our service providers may process data outside of Canada.

For Security Purposes

Nara may share your username, Usage Information, and Device Information to the extent that such information is provided only to investigate or respond to a security incident that affects or compromises the security of your or another organization.

For Legal Disclosure

Nara strives for transparency in complying with legal processes and legal obligations. Unless prevented from doing so by law or court order, or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. Nara may disclose User Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, a similar government order, or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties or the public at large.

Change in Control or Sale

We may share User Personal Information if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our Website or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will have to honour any promises we made in our Privacy Policy or Terms and Conditions Agreement.

Aggregate, Non-Personally Identifying Information

We share certain aggregated, non-personally identifying information with others about how our users use Nara. We do not sell your User Personal Information for monetary or other considerations.

E. How Nara Shares the Information We Collect

Public Information on Nara

Some of Nara’s services and features may be public-facing. If your content is public-facing, third parties may access and use it in compliance with our Terms and Conditions Agreement, such as by viewing your profile. We do not sell that content; it is yours. Your User Personal Information associated with your line directories could be gathered by third parties. 

F. How You Can Access and Control Information We Collect

You can control the information we collect about you by limiting what information is in your profile, by keeping your information current, or by contacting Nara Support.

Data Retention and Deletion of Data

Generally, Nara retains User Personal Information for as long as your account is active or as needed to provide you services. If you would like to cancel your account or delete your User Personal Information, you must submit a request through Nara Support. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile (within reason) within 90 days of your request.

G. Our Use of Cookies and Tracking

Cookies

Nara only uses strictly necessary cookies. Cookies are small text files that websites often store on computer hard drives or mobile devices of visitors. We use cookies solely to provide, secure, and improve our service. For example, we use them to keep you logged in, remember your preferences, identify your device for security purposes, analyze your use of our service, compile statistical reports, and provide information for future development of Nara. We use our own cookies for analytics purposes, but do not use any third-party analytics service providers. By using our service, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept these cookies, you will not be able to log in or use our service.

DNT Signals

Some browsers have a “Do Not Track” functionality that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals. We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.

H. How Nara Secures Your Information

We will strive to use the necessary measures to protect the security of your data and prevent unauthorized access to your Personal Information. However, we cannot guarantee that data transmission over the Internet is 100% secure, or that your Personal Information will be immune to malicious attack or compromise. As such, be aware that transmission of Personal Information is at your own risk. We will continue to enhance security procedures as new technologies and procedures become available.

We encrypt the transmission of your Personal Information and password as part of your account setup.

I. Nara Global Privacy Practices

PanGenomic Health Corp. is the controller responsible for the processing of personal information in connection with the Service, except when you and Nara have entered into a separate agreement that covers data privacy.

We store and process the information that we collect in Canada in accordance with this Privacy Policy, although our third-party service and infrastructure providers may store and process data outside of Canada. However, we understand that we have Users from different countries and regions with different privacy expectations, and we try to meet those needs even when Canada does not have the same privacy framework as other countries.

We provide the same high standard of privacy protection—as described in this Privacy Policy—to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business. Additionally, if our affiliates have access to User Personal Information, they must sign agreements that require them to comply with our privacy policies and with applicable data privacy laws.

In particular:
  • Nara provides clear methods of unambiguous, informed, specific, and freely given consent at the time of data collection when we collect your User Personal Information using consent as a basis.
  • We collect only the minimum amount of User Personal Information necessary for our purposes unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
  • We offer you simple methods of accessing, altering or deleting the User Personal Information we have collected, where legally permitted.
  • We provide our Users notice, choice, accountability, security, and access regarding their User Personal Information, and we limit the purpose for processing it. We also provide our Users a method of recourse and enforcement.

Cross-Border Data Transfers

Nara processes personal information both inside and outside of Canada and relies on Standard Contractual Clauses as the legally provided mechanism to lawfully transfer data.

J. How We Communicate With You

We use your email address to communicate with you, if you’ve permitted email as your point of contact and only for the reasons you’ve permitted for. By accepting the terms of this Privacy Policy, you consent to receive electronic communications from Nara. For example, if you contact our Support team with a request, we respond to you via email.

Depending on your email settings, Nara may occasionally send notification emails about changes on the platform, new features, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There is an “unsubscribe” link located at the bottom of each of the marketing and product support emails we send you. Please note that you cannot opt-out of receiving important communications from us, such as emails from our Support team or system emails, but you can configure your notifications settings in your profile to opt-out of other communications.

K. Resolving Complaints

If you have concerns about the way Nara is handling your User Personal Information, please let us know immediately. We want to help. You may contact us by sending a direct email to info@nara.care with the subject line “Privacy Concerns.”

In the unlikely event that a dispute arises between you and Nara regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority, and you might have more options.

L. Changes in Our Privacy Policy

Although most changes are likely to be minor, Nara may change our Privacy Policy from time to time. We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your Nara Account.

M. Contacting Nara

Questions regarding Nara’s Privacy Policy or information practices should email info@nara.care.