- Overview and Application to COVID-19 Related Efforts
InBios International, Inc. (“InBios,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Notice (“Privacy Notice”). This Privacy Notice describes the types of Information we may collect from you when you register for and use the InBios ReaDX mobile application (“App”). It also describes our practices for collecting, using, maintaining, protecting, and disclosing that Information.
InBios does not collect and store Personal Information beyond the required user e-mail registration information and de-identified image test results accessible by a unique code. Please reference the additional text in this Privacy Notice for more information.
The App may also be used for performing and interpreting tests related to other diseases beyond COVID-19 (i.e., other rapid tests), and data collection for these rapid tests will be further limited to the Information required and necessary.
Please read this Privacy Notice to understand our policies and practices regarding your Information when you use the App. If you do not agree with our policies and practices, do not use the App. By accessing or using the App, you agree to this Privacy Notice.
This Privacy Notice applies only to the InBios ReaDX App. The Privacy Notice for the InBios website is available on the website.
InBios may change this Privacy Notice at any time, at its discretion. Your continued use of the App after we make changes is deemed to be acceptance of those changes, so please check the Privacy Notice periodically for updates.
- The Types of Information That App Collects About You and How The App Collects Information About You
The App only collects a small amount of data about you. That data is either Personal Information or Non-Personal Information (collectively “Information”).
- “Personal Information” refers to data by which you may be personally identified.
- “Non-Personal Information” means data that is about you but does not identify you specifically.
The only Personal Information that you provide to InBios directly through our App is your email address. InBios does not have access to any of your Personal Information you enter into the App other than your email address. Any other Personal Information you enter into the App is stored on your mobile device.
The Non-Personal Information that InBios may collect and store about you when you use the App includes an image of anonymized test results, which is linked to your device by a unique code, and other non-identifying information about your mobile device that allows the App to function.
The App collects Information about you by the following means:
- Through the registration process.
- Through your device’s camera, which captures the image of your test results.
- Automatically when the App is installed on your device and while it is operating, although this Information is limited to information necessary for the App to function.
If you contact InBios about the App, then InBios will have your contact information as well as any other Personal Information you provide at that time.
- How The App Uses Information It Collects About You and the Purpose for the Collection and Use
The App uses the limited Personal Information it collects about you:
- To register your device with the App, using your email address. This is typically the only use the App makes of your Personal Information.
- To retain your test result image on the InBios systems, so that your test results can be forwarded or accessed if you choose.
- If necessary, InBios may use Personal Information to enforce our rights arising from any contracts entered into between you and us.
- InBios might also use your Personal Information in any other way we may describe when you provide the Information and for any other purpose with your consent, but such uses would be rare and typically involve responding to your inquiries.
The App uses the limited Non-Personal Information it collects about you to present the App and the content on it.
InBios will retain your Information for as long as necessary to provide the services you have requested, comply with our legal obligations, resolve disputes, and enforce our agreements.
- How InBios Protects Your Information
We have implemented measures designed to protect your Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the internet is not completely secure. Although we are working to protect your Information, we cannot guarantee the security of your Information either in transmission or when stored. We are not responsible for circumvention of any privacy settings or security measures contained on the App.
- When InBios Shares Your Information
We may use and disclose Non-Personal Information about our users without restriction. We may disclose Personal Information that we collect or you provide as described in this Privacy Notice:
- To the U.S. Department of Health and Human Services (HHS), if you enable Information sharing on the App. The App will share the Personal Information directly with HHS from your device, without InBios accessing that Personal Information
- To our subsidiaries and affiliates, where applicable.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor (potential or actual) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of InBios’ assets, including any related due diligence.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the Information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of InBios or others.
InBios does not sell any of your Personal Information.
- Third Parties Providing Services On Our Behalf
We use third parties to host some aspects of the App, design and operate the App features, and to perform administrative, analytics, and payment processing. We may disclose your Information to these companies so they can carry out these services. These companies are bound by contractual obligations to keep Information confidential.
- Information From Children
- Do Not Track
InBios does not have a mechanism in place for responding to browser “do not track” signals or other similar mechanisms used to limit collection of information for use in online advertising.
- Your Choices About Information
If you choose not to provide Information, you may be unable to access all or portions of the App. Please report your concerns about collection or use of Personal Information through the App to firstname.lastname@example.org.
- Your California Privacy Rights
Under the California Consumer Privacy Act of 2018 (CCPA), California consumers may have certain rights regarding their Personal Information, including the rights listed below.
- The right to know the categories of Personal Information that InBios has collected and the sources from which InBios obtained the Information.
- The right to know the business purposes for sharing Personal Information.
- The right to know the categories of third parties with which InBios has shared Personal Information.
- The right to access the specific pieces of Personal Information that InBios has collected in a portable format.
- The right to request the deletion of Personal Information.
- The right to opt-out of the sale of their Personal Information and in some cases the sharing of their Personal Information. Note that InBios does not sell your Personal Information.
- The right to correct their Personal Information.
- The right to restrict processing of sensitive Personal Information, such as social security numbers, passport numbers, health information, racial or ethnic origin, and financial account and payment card information.
This Section contains information about these rights and how to exercise them.
Categories of Personal Information the App Collects:
- Identifiers (“Identifiers”) and Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (“Customer Records Information”) such as your email address, as well as any identifying information you provide in communications with InBios.
- Sensitive Information such as health information contained in the image of your test results, which InBios stores anonymously and is linked to your device by a unique code (“Sensitive Information”).
The list of categories of Personal Information that we have shared with or disclosed to third parties for a business purpose is: Identifiers, Customer Records Information and Sensitive Information.
The criteria used to determine the length of time InBios will retain your personal information with regard to the categories listed above is in Section 3 of this Privacy Notice.
Additional information about the categories of Personal Information collected and the categories of sources from which Personal Information is collected is in Section 2 of this Privacy Notice. The purpose for collecting the Personal Information listed above is in Section 3 of this Privacy Notice. The third parties with which InBios may share the Personal Information listed above are in Section 5 of this Privacy Notice.
Exercising Your Rights
To exercise rights described above, please email us at email@example.com or contact us at 1-866-462-4671. There are exceptions, so not all of these rights may apply to you. Let us know if you have questions about these exceptions.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period. If we deny your request, we will provide reasons for the denial.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
We will not discriminate against you for exercising any of your CCPA rights.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site that are California residents to request certain information regarding InBios’s disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact InBios at the email address included below.
- How To Contact Us About This Privacy Notice
To ask questions about this Privacy Notice and our privacy practices, contact us at firstname.lastname@example.org or by mail at:
InBios International, Inc.
ATTN: Legal Department
307 Westlake Ave. N., Suite 300
Seattle, Washington 98109
EFFECTIVE DATE: March 14, 2022