Privacy Policy for Patients

Introduction

At GeneSilico, we are committed to protecting your privacy and security when you access our application / website (each a Platform) while ensuring compliance with applicable laws and best practices (Privacy Policy).

The Platform is an analytical tool which uses Artificial Intelligence (AI) to analyze your historical personal data by aggregating information, which assists oncologists in identifying specific treatment regimens tailored to your needs.

Scope and Terms of Privacy Policy

For the purpose of this Privacy Policy any reference to ‘you’ means you, the natural person, whose personal data is being voluntarily submitted to and being processed by GeneSilico (the patient). If you are a patient who is under the age of 18, or a person with a disability preventing you from providing valid consent, the reference to ‘you’ includes you as well as your parent(s) or legal guardian(s) (as the case may be) who are consenting to GeneSilico processing your personal data on your behalf.

For the purpose of this Privacy Policy any reference to ‘personal data’ means any information about the patient by or in relation to which the patient can be identified, as is specifically detailed at Clause 3 (Data Collection) below.

This Privacy Policy describes how we collect, use, store, process, and safeguard the personal data of the patients who provide their personal information to us for the purpose of processing by the Platform, and who access our Platform.

You hereby provide your free and informed consent to the processing of your personal data by GeneSilico as per the terms set out in this Privacy Policy and such free and informed consent will subsist throughout the duration that you access our Platform, unless revoked by you specifically in writing.

If you do not agree with the terms of this Privacy Policy, you are requested to immediately cease your access to and use of the Platform and services provided through the Platform by GeneSilico. GeneSilico retains the right to refuse services if you fail to accept the terms of the Privacy Policy.

The Platform also collects the following limited personal information from any GeneSilico employee, consultant, publication reviewer, medical oncologist, genetic counselor, and GeneSilico approver (collectively, the GeneSilico Representatives) who have access to the Platform:

their first and last name
their phone number
their e-mail address.
their password.

It is expressly clarified that this privacy policy does not apply to any GeneSilico Representatives, and the processing of their limited personal information collected will be in accordance with the agreements separately executed with each such GeneSilico Representative at the time of their onboarding. We further confirm that each GeneSilico Representative will not have complete access to your personal information on the Platform, and the access levels are determined and allocated by GeneSilico strictly on a need-to-know basis.

Data Collection

We collect and process your personal data only to the extent necessary to provide you with our services on the Platform and as specifically set out in this Privacy Policy. The nature of personal data we collect from or about you may vary depending on the purpose for which it is provided to us by you.

Your free and informed consent and the security and accuracy of your personal information is our utmost priority. For the purpose of maintaining accuracy of all your personal information, your personal information will be orally collected from you by the doctor and/or counsellor who has been appointed by GeneSilico under a valid agreement. They will explain to you the nature of the personal information collected from you as well as the purpose for which it is collected. Such a doctor and/or counsellor will only then upload your personal information on the Platform.

You will be able to review all your personal information as collected by GeneSilico on the Platform and will be able to request the correction or erasure of any such personal information which is not accurate.

At the time of sign up, and during the course of us providing you with services on the Platform, the following personal information will be collected either directly from you, or through a third party that you have authorized to provide us with your personal information, and uploaded on the Platform:

Your full name
Date of Birth
Home Address / Alternative Address
Phone Number
Email Address
Weight
Ethnicity
Sex
Medical Record Number / Unique Health Identification Number
Clinical Information
Primary diagnosis and stages of diagnosis
Date of Original Diagnosis
Past medical records (prior therapy, prior treatment)
Family History including family member name (relation to the patient)
Hospital information (Name, Address, Hospital ID, Point of Contact)
Patient status at time of the sample collection
Physician Information including Referring Physician Name, Contact Number, and Email ID
Records/Reports including recent copies of reports (blood, pathology, radiology, molecular testing, and NGS advanced testing)
Pathology Lab’s Name and Submitting Pathologist Name
Details about the biological sample including FFPE Tissue, Fresh Frozen Tissue, Purified DNA, Streck Cell-Free Blood DNA, and PaxGene Blood DNA
Date of Collection of the biological sample
Shipment details of the biological sample including origin, courier service used, shipment source (hospital or laboratory), intended destination, and tracking number
Your medical history relevant to our services as provided on the Platform, including information related to your genetics
Your financial information for billing
Your healthcare insurance records

In addition to the personal data that you submit to us, we automatically collect some information when you visit our Platform. This type of information is listed below:

Our webservers may collect certain information such as your IP address, browser details, device information, and usage logs.
We use cookies to store information for your convenience in accessing the Platform’s features.
We also collect information voluntarily provided by you during your use of the Platform and in respect of which you have not indicated that you do not consent to the use of your personal data, including any documents and analytical results you provide on the Platform.

Data Usage

We will only process your personal data for the purposes as specifically outlined below:

For registering you on the Platform, enabling your access to the Platform, and providing access to all its features.
For providing uninterrupted services and assistance with respect to your treatment, including but not limited to conducting consultations, performing risk assessments, providing treatment insights, sending appointment reminders, dispatching specimen collection kits, and any activities incidental to these services.
For billing and collection of payments (from you or your insurance provider) related to treatment assistance and services, including verification of health insurance coverage.
For internal management and administrative operations.
For genomic counseling with GeneSilico’s Genetic Counselor to determine whether Next Generation Sequencing (NGS) testing is required.
To analyze your genetic material using our testing services and generate reports from your NGS tests.
For billing purposes and verification of your healthcare insurance.
To communicate with you via email or text message regarding health-related products and services that may be relevant to you, including treatment options and alternative treatments.
To comply with applicable legal and regulatory requirements, including court orders, tax obligations, payment processing requirements, and the exercise of GeneSilico’s legal rights.
To process any queries, requests, complaints, or grievances raised by you regarding GeneSilico and/or the Platform.
For any other purpose reasonably necessary to fulfill our obligations toward you.
If you are the parent or lawful guardian of a patient under 18 years of age, or a person with a disability preventing them from providing valid consent, we will collect your personal data to verify your identity and obtain valid consent before processing the patient’s data.

As GeneSilico’s Platform is an AI-powered analytical tool, we de-identify and anonymize your personal data and feedback on the Platform for the following purposes:

To combine your de-identified and anonymized data with anonymized data from third-party service providers and consultants engaged by GeneSilico to create the Platform’s Analytics Database.
To improve and update GeneSilico’s precision oncology gene panel and genetic testing services.
To improve and refine GeneSilico’s AI agents, including by sharing anonymized data with third-party large language model providers such as OpenAI and Anthropic.
To enable third-party large language models to assist in improving the functionality and performance of GeneSilico’s AI systems.
To contribute to our variant classification program.
To conduct clinical research and studies, the results of which may be published in peer-reviewed journals.
To contribute to internal anonymized registries and publicly available healthcare databases, including the National Center for Biotechnology Information (NCBI) and ClinVar.

Disclosure of personal data

We do not trade, share, or sell personal data that you provide to us with organizations that intend to use it solely to market their products or services to you.

The purpose for which GeneSilico shares your personal data with third parties varies in each case and depends on the purpose for which you provide us with such personal data. Generally, when you submit your personal data to GeneSilico, we may disclose it for the following purposes:

When we perform laboratory tests ordered by your healthcare providers, we may disclose your personal data to third-party laboratories that process test orders, perform testing, and provide test results.
To support healthcare operations, including monitoring and improving the quality of testing services, evaluating outcomes, assays and protocols, internal training, and customer support.
To GeneSilico affiliates and third-party service providers engaged by us to ensure continuity of services and assistance. All such third parties are contractually obligated to protect your personal data on terms equal to or stronger than those provided by GeneSilico.
Where disclosure is necessary for your treatment or related billing activities, including verification of insurance coverage, payment processing, and incidental disclosures required during the normal course of treatment and billing operations.
Where such disclosure is required or permitted under applicable laws and regulations.
With individuals authorized by you to make healthcare decisions on your behalf, including parents or guardians of minors and persons with disabilities. If no such person has been designated, we may disclose your personal data to persons legally authorized to act on your behalf or on behalf of your estate.
To family members, relatives, or other related persons involved in your healthcare or healthcare payments, where appropriate.
To assist in disaster relief efforts, including informing family members and friends about your location, general health condition, or death. Upon your death, we may disclose personal data to authorized persons or those involved in your healthcare or payment for healthcare unless you have expressly prohibited such disclosure.
With other healthcare providers specifically requested by you.
With organ procurement organizations, tissue banks, transplant entities, and funeral directors, where specifically requested by you or persons authorized by you. In the absence of such authorization, we may disclose information where we reasonably determine it is in your best interests.
With GeneSilico group companies, affiliates, and entities that are legally part of the same corporate group or subsequently become part of that group, to fulfill the purposes outlined in this Privacy Policy.
With courts, tribunals, regulatory authorities, government agencies, legal bodies, and third parties where disclosure is necessary to comply with legal or regulatory obligations.
Where GeneSilico reasonably believes disclosure is necessary to comply with applicable laws, regulations, legal processes, governmental requests, or to establish, exercise, or defend legal rights and claims.
With auditors, accountants, lawyers, consultants, and other professional advisors who require access to the information to provide services or advice to GeneSilico.
In connection with a merger, acquisition, restructuring, or sale of business assets, your information may be transferred to the involved third party, provided they agree to process and protect your information in a manner consistent with this Privacy Policy.
We may disclose your personal data with direct identifiers such as your name and date of birth removed for research, healthcare operations, and public health activities, subject to a separate data use agreement where applicable.
For research, scientific analysis, and archival purposes.
Where disclosure is necessary to lessen or prevent a serious threat to your health or safety, or the health or safety of another person, and to authorities legally responsible for disease prevention, public health, child protection, abuse prevention, neglect prevention, and similar protective functions.
With your employer where services are being provided at your employer’s request.
With schools, universities, or other educational institutions where the information relates to immunization records.
We will obtain your explicit consent before disclosing your information for any purpose not described in this Privacy Policy, including but not limited to disclosures for marketing purposes, disclosure of psychotherapy notes, or disclosures that would constitute a sale of personal data.

Cookies

We use cookies and similar tracking technologies to analyze your website usage to improve your user experience. Your cookie preferences while accessing the Platform can be altered through your browser settings.

Data Storage and Retentions

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected (as mentioned under Clause 4 of this Privacy Policy), in accordance with applicable laws and as outlined in this Privacy Policy, save and except if we are required to retain this personal data for any longer period to comply with applicable laws.

Your personal data is stored securely on encrypted servers hosted in compliance with industry standards and applicable laws.

Data Security Measures

GeneSilico employs robust security measures to protect user data, including:

Encryption: Data is encrypted both in transit using Transport Layer Security (TLS) and at rest using AES-256 encryption.
Access Controls: Role-based access management and multi-factor authentication (MFA) are implemented to restrict access to authorized personnel only.
Regular Audits: Periodic security reviews, compliance checks, and vulnerability assessments are conducted to identify and mitigate potential risks.
Monitoring: Continuous monitoring of systems and infrastructure is performed to detect and respond to suspicious or unauthorized activities.
Backup and Recovery: Secure data backup procedures and disaster recovery protocols are maintained to ensure data availability and business continuity.

User Rights

You have the right to access, review, correct, update, revoke your consent, or request the erasure of your personal data that GeneSilico stores by submitting a written request to GeneSilico.

To ensure the security of your personal data, we may ask you to provide certain identifiers to verify your identity before processing your request. We may also require you to provide reasons for amending or updating your personal data to help ensure the accuracy and integrity of the records we maintain.

Please note that we may charge a reasonable fee to provide a compiled copy of your personal data where you request such information in a specific format.

You may request to nominate or authorize one or more persons to exercise any of the rights described in this section on your behalf.

You may access our grievance redressal system to address any concerns or complaints regarding the processing of your personal data. If you wish to file a grievance, you may do so using the contact details provided below.

We will endeavor to provide a prompt resolution to your grievance as soon as reasonably practicable from the date of receipt and, in all cases, within the timelines prescribed by applicable law. We maintain appropriate technical and organizational measures to ensure the effectiveness of our grievance redressal process.

You acknowledge that the deletion of all or part of your personal data may result in GeneSilico being unable to provide certain services, updates, or continued access to the Platform.

You further acknowledge that any request to delete all or part of your personal data will not result in modifications to GeneSilico’s Platform, as your personal data and feedback may have already been de-identified and anonymized for analytical and operational purposes.

If you:

Have any questions regarding this Privacy Policy;
Wish to exercise any of your rights described in this section; or
Wish to submit a complaint or grievance regarding our privacy practices;

You may contact us at: privacy@genesilico.ai

Compliance

GeneSilico complies with all relevant and applicable privacy and security regulations in all territories of its operations, including but not limited to any sector specific regulations as may be applicable.

Breach Notification

In the event of a personal data breach, GeneSilico is committed to informing you without any delay. Upon becoming aware of the breach, we will notify through your user account on our Platform and the communication methods you have registered with us.

We will take all necessary steps, in compliance with applicable laws, to ensure that your personal data remains secure

Third-Party Links

The Platform may contain links to third-party websites. GeneSilico is not responsible for the privacy practices of these external sites. You are encouraged to review the privacy policies of third-party services.

Policy Updates

This policy may be updated periodically to reflect changes in practices or regulations. GeneSilico will inform you of any changes in the Privacy Policy via a notification or e-mail or any other reasonable and preferred methods of communication you have previously informed us about. In any case we encourage you to periodically visit and review this Privacy Policy.

Contact Us

For questions, concerns, or requests related to this Privacy and Security Policy, please contact us:

Email: privacy@genesilico.ai