Privacy Policy (ENG)

Inocras Inc. and its subsidiaries and affiliates (“Inocras,” “we,” “us,” or “our”) are committed to protecting your privacy. This Privacy Policy describes how and why we collect, store, use, or share personal information. By the term “personal information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular person or household.

We collect, store, use, or share your personal information when you:

• Access or use our website, platforms, products, solutions, or services (collectively, “Services”);
• Interact with us, including by transmitting data or information by email, telephone, social media, and in person; or
• Otherwise communicate with us.

This Privacy Policy will help you understand your privacy rights and choices. Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our website or platform. If you still have any questions or concerns after reading this Privacy Policy, please contact us at the contact point as set out below.

In this Privacy Policy, “Patients” are the patients whose data or samples are being provided to us for sequencing or analysis. “Members” are the registered users of our website or platform.

Please use the headings below to navigate through the sections of this Privacy Policy.

1. Purpose of Processing Personal Information.
2. Personal Information to be Collected and Processed and Lawful Basis.
3. Period of Retention and Use for Personal Information.
4. Provision of Personal Information to Third Parties.
5. Your Rights, and How to Exercise Them.
6. Destruction of Personal Information.
7. Safety Measures for Personal Information.
8. Transmission Of Data To Other Countries.
9. Contact Information.
10. Updates to This Privacy Policy.
11. Special Provision for Patients.

Privacy Notice to California Residents

1. Purpose of Processing Personal Information

Inocras collects and uses personal information for the following purposes:

• To provide Services to you, or to perform any contract that we will enter into or have entered into with you.
• To process your registration on our websites or platforms.
• To personalize your experience on our websites or platforms, including by using cookies and similar tracking technology to keep track of your preferences.
• To communicate with you and respond to or carry out your requests, questions, and feedback.
• To verify your identity.
• To maintain the quality of, and improve, existing Services and develop new Services.
• To enforce and improve our security measures.
• To maintain compliance with laws and regulations that apply to us.
• Where we are allowed to do so by law or your consent, to provide you with marketing, promotion, or advertising information, including by providing you with opportunities to participate in research or clinical trials.
• Where we are allowed to do so by law or your consent, to de-identify your personal information and use the de-identified information for statistical compilation, scientific research, record-keeping for public interest purposes, and other uses of de-identified information as allowed by law.

To the extent we store and use deidentified personal information, we will not try to reidentify the information, except to test our deidentification methods. If we share deidentified personal information we will obligate the recipient not to try to reidentify the information.

2. Personal Information to be Collected and Processed and Lawful Basis

Inocras collects and processes the following personal information of the Members (“Member Information”):

• Contact information. This includes information such as your name, phone number, fax number, mailing/shipping address, email address, job title, affiliation (office/hospital/institution), account log-in ID/username, and password. We collect this information when you or your healthcare provider provide it to us. We have a legitimate interest in providing account related functionalities to users.
• Client Information. This includes name and contact information of our clients and their employees with whom we may interact. We have a legitimate interest in contacting our clients and communicating with them about business activities such as projects, services, and billing.
• Payment-related information. This includes information such as billing address, debit/credit card numbers, and other financial account information. We collect this information when you or your healthcare provide it to us. We use this information to perform our contract to provide products or services.
• National Provider Identifier (NPI). If you are a healthcare provider and provide your NPI to us.
• Testimonials. If you provide us with testimonials related to your experiences with our Services. We use this information with your consent.
• Technical data. such as your internet protocol (“IP”) address, access logs, and cookies. This information is automatically collected when you use our website or platform. We have a legitimate interest in making our website operate. We also use it to understand how you interact with our websites, gather analytics, improve our websites, and learn your preferences. We may also use this data to help detect and prevent fraud. Where required by law, we base the use of technologies upon consent.
• Website Targeted Advertising Technology. We may let third parties place tracking technology on our websites (e.g., a cookie or a pixel). The third party might also collect data over time and across other websites. Among other things, they may use this data to serve ads tailored to your interests, which may include ads about our products or services. Where required by law, we base the use of third-party tracking technologies upon consent.
• Patient Information. Inocras collects and processes the following personal information of the Patients (“Patient Information”).
• Demographic, clinical, genetic, or other information related to testing. This includes information such as biological sex at birth, date of birth, age, marital status, patient ID numbers attributed to you by clinicians, Test Acquisition Number (a unique ID number generated by us) attributed to you, medical records/history, status/risks of any disease/condition, and information revealing your race or ethnic origin. We collect this information when you or your healthcare provider provide it to us. In the case of genetic information, we collect genetic information when we generate it from your sample and also if you or your healthcare provider provide it to us. We have a legitimate interest in receiving and acting upon feedback.

3. Period of Retention and Use for Personal Information

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected such information to the extent permitted by applicable law. This includes the purposes of satisfying legal, accounting, or reporting requirements. For example, we may retain your personal information until the completion of the respective investigation if there is an ongoing investigation regarding a violation of relevant laws and regulations; and until the settlement of the relevant debts if any debts resulting from your use of the services remain unsettled. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the data. We also weigh the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we obtained the data and whether we can meet those purposes through other means, as well as applicable legal requirements.

4. Provision of Personal Information to Third Parties

We may share your personal information with other parties as below, to the extent allowed by applicable law:

• Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Service Providers and Contractors. We use trusted third parties (e.g., IT services, analytics services, etc.) to help us provide, improve, protect, and promote our Services, and to perform business operations, such as determining eligibility for our products. These third parties may contact you on our behalf to perform these business operations. These third parties will access your personal information only to perform tasks on our behalf in compliance with this Privacy Policy.
• Service Providers. We may share your personal information with service providers. Service providers may help us to run our website, provide technical support, process payments, fulfill orders, and more.
• Other Applications and Third-party Links. The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website or platform, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.
• The Public. We may make your testimonials public. If you gave us consent to use and share your testimonial but wish to update or delete it, please contact us at inquiry@inocras.com.
• Advertising Partners. We may share personal information with third-party advertising companies.
• For Compliance, Fraud Prevention and Safety. We may share personal information for the compliance, fraud prevention, and safety purposes described above and to comply with legal requirements and processes.
• Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
• Legal Purposes. We will disclose your personal information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant, or similar legal process; or if necessary to assert or protect our rights or assets.
• Other Parties. To another party or parties for any other purpose disclosed by us when you provided your personal information, with your consent or authorization, or as otherwise permitted or required by applicable law.

5. Your Rights, and How to Exercise Them

You may, at any time, exercise the right to peruse, correct, delete, and suspend the processing of your personal information against Inocras, by contacting us at inquiry@inocras.com, which we will honor without delay, subject to certain exceptions provided by applicable laws.

You may exercise this right through your agents such as your legal representative or a delegate, although you will be required to submit a power of attorney to Inocras confirming such delegation.

We will confirm whether the person making the request holds such rights or is a legitimate agent.

Please note that your request may not be carried out if your personal information has already been de-identified, anonymized, or pseudonymized, or if you authorized us to share your personal information with others and we already shared your information with others in reliance of such authorization.

In some regions, you may have certain further rights under applicable data protection laws, and you may contact us at the contact point as set out below to request exercising such rights. Inocras will consider and act upon any such request in accordance with applicable data protection laws.

If you are a resident of certain U.S. states including California, you may further have the following rights; provided that these provisions only apply to the users residing in particular states or another jurisdiction whose laws or regulations recognize such rights:

• Right to be Informed. You have the right to know the following:
  • whether we collect and use your personal information;
  • the categories of personal information that we collect, the purposes;
  • the purposes for which we collected personal information is used; and
  • whether we sell or share personal information to third parties, the categories of the sold or shared personal information thereof, and the categories of third parties to whom the personal information was sold or shared;
• Right to Access. You may request access to your personal information. In certain limited cases, you may ask to receive access to your data in a portable, machine-readable form.
• Right to Request a List of Third-Party Recipients. You may request a list of specific third parties to which we have disclosed personal information. Some areas also allow you to obtain a list of the categories of third parties to which we have disclosed personal information. You can find that information in the table below under Section 2 of the Supplemental Privacy Notice to U.S. Residents.
• Right to Correct Inaccurate Personal Information. You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Request Deletion of your Personal Information. You have the right to request that we delete the personal information we have about you subject to certain limitations. If we do not delete your personal information for reasons permitted under applicable law, we will let you know the reason why.
• Right to Object to or Restrict of Certain Processing. In certain circumstances, you may object to the processing of your personal information or ask that we restrict processing of your personal information. To do so, follow the instructions below.
• Right to limit the use and disclosure of sensitive personal information. For the sensitive personal information collected by Inocras, you have the right to limit our use and disclosure of such information by clicking here.
• Right to opt out. The user has the right to opt out of the sale or sharing of the user’s personal information by clicking here.
• Right to Withdraw Consent. Where we process your personal information based upon consent, you may revoke consent. Note, if you revoke consent for processing personal information, we may no longer be able to provide you some types of services.
• Right to non-discrimination for your exercise of privacy rights. Inocras will not discriminate against you if you exercise your privacy rights.

In some instances, your privacy rights and choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you disagree with our denial of a request, you may appeal our decision by contacting us with the subject line “Appeal.” If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the section below. If you are not satisfied with our response and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.

Identity Verification for requests. If you make a request related to personal information about you, you will be required to supply a valid means of identification as a security precaution. We will verify your identity with a reasonably high degree of certainty using the following procedure where feasible: we will match identifying information you provide when making the request to the personal information maintained by us, or use a third-party identity verification service. If it is necessary to collect additional information, we will use the information only for verification purposes and will delete it as soon as practicable after complying with your request. For requests related to particularly sensitive information, we may require additional proof of your identity.

Authorizing a Third Party to Make a Request. If you wish to authorize a third party to make a request on your behalf through an authorized agent, you must contact us directly and you or the third party acting on your behalf must provide a valid California power of attorney or comparable documentation of written permission from you and verification of your identity. Such power of attorney must meet the requirements of Probate Code sections 4000 to 4465. You may also make a privacy request on behalf of your minor child.

If you are a Patient, you may further have the following rights:

• getting a copy of your paper or electronic medical record; provided that we may charge a reasonable, cost-based fee;
• correcting your paper or electronic medical record that you consider incorrect or incomplete; provided that we may reject your request pursuant to applicable laws, in which case we will inform you of the reason of rejection within 60 days;
• requesting confidential communications;
• limiting your information to be shared; provided that we may reject your request to limit your information to be share for the treatment, payment, and health care operations purposes;
• getting a list of those with whom we’ve shared your information for 6 years prior to the date you ask; provided that we will provide one list a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months;
• getting a copy of this Privacy Policy; and
• asking us to share your medical information with your family, close friends, or others involved in your care.

6. Destruction of Personal Information

Inocras will, without delay, destroy your personal information when your personal information becomes unnecessary, such as in the cases of the expiration of the personal information retention period.

If Inocras needs to preserve your personal information in accordance with the applicable laws and regulations even when the personal information retention period agreed by you has elapsed or the purpose of processing has been achieved, Inocras will securely store your personal information and isolate it from further processing by storing it in a separate database.

Inocras takes the following destruction procedures and methods:

• destruction procedures: Inocras will select the personal information that needs to be destroyed and destroy the personal information with the approval of Inocras’s personnel for the management of personal information; and
• destruction method: Inocras destroys personal information recorded and stored in electronic file format using technical methods so that the information cannot be reproduced, and personal information recorded and stored on paper documents is destroyed by crushing or incineration with a shredder.

7. Safety Measures for Personal Information

Inocras has implemented the following appropriate and reasonable administrative and technical security measures designated to protect the security of your personal information:

• administrative measures: establishment and implementation of internal management plans for personal information, regular employee training, etc.
• technical measures: technical countermeasures against hacking, etc., encryption of personal information, storage access records, and prevention of forgery, etc.

Notwithstanding the foregoing, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure, so Inocras cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will endeavor our best to protect your personal information, the transmission of personal information to and from our website is at your own risk. Further, you should only access our website within a secure environment.

Installation, Operation, and Refusal Thereof of Automatic Personal Information Collection.

Inocras uses ‘cookies’ to store and retrieve your usage information from time to time to provide individually customized services. Cookies are a small amount of information sent to your PC browser by the server (HTTP), which are used to operate the website, etc., and stored in your computer’s hard disk.

Purpose of use of cookies: Inocras uses cookies to provide you with optimized information by identifying the type of visit and use of each service and website you visit, popular search terms, and whether you have a secure connection.

Installation, operation, and rejection of cookies: You can reject the storage of cookies by setting your web browser’s privacy and security options; provided that by refusing to save cookies, you may experience difficulties in using customized services.

8. Transmission Of Data To Other Countries

By submitting your personal information to us you acknowledge that we may transfer, store, and process your personal information in a country other than your country of residence including, but not limited to, the United States. For more information on our attempts to apply the privacy principles applicable in one area to data when it goes to another, contact us using the contact information below. You may also request a copy of any Standard Contractual Clauses we use for the transfer of your data outside of the EEA, which includes the categories of information transferred by contacting us using the contact information below.

9. Contact Information

If you have questions, comments, or complaints on our privacy practices, or if you need to access this Privacy Policy in a different form due to a disability, please contact us using the contact information below. We will try to address your requests and provide you with additional privacy-related information.

Inocras has designated the Privacy Officer, who manages personal information tasks and handles your complaints about personal information. Our Privacy Officer’s contact information is as follows:

Name: Alexis Paner
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Position: Privacy Officer
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Contact: (858)-665-2120 / inquiry@inocras.com

You may inquire about all personal information protection-related inquiries, handling complaints, damage relief, etc. that occurred while using Inocras’s services to our Privacy Officer, and the following department in charge:

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Department: Quality Assurance
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Contact: (858)-665-2120 / inquiry@inocras.com

Inocras endeavors to ensure your right to self-determination of personal information and to provide consultation and damage relief due to personal information infringement. If you intend to report or consult, please contact the department above.

10. Updates to This Privacy Policy

Inocras may amend the Privacy Policy to comply with applicable law or to reflect any changes in the provision of service, in which case Inocras will attempt to notify you of such amendment before the effective date of such amendment using your email address we have on file and/or by publishing the new version of the Privacy Policy on our website.

11. Special Provision for Patients

If you are a Patient, Inocras will further have the following responsibilities to process your personal information:

• we are required by law to maintain the privacy and security of your protected health information;
• we will let you know promptly if a breach occurs that may have compromised the privacy or security of your information;
• we will follow the duties and privacy practices described in this privacy policy and promptly give you a copy of this Privacy Policy upon your request; and
• we will not use or share your information other than as described here unless you give us written approval or unless otherwise provided in this Privacy Policy or any applicable.

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Supplemental Privacy Notice to California Residents

This Section only applies to users of our Services that reside in the State of California, in addition to the above. For purposes of this Section, the term “personal information” does not include information subject to HIPAA or the California Confidentiality of Medical Information Act. For example, this Section does not apply to genetic test records or to any data or medical records stored by us.

California law requires us to disclose the following information on our privacy practices. If you are a California resident, the following disclosures apply to you in addition to Privacy Policy.

Categories of Personal Information We Collect and Share. California requires us to disclose whether the following categories of personal data are collected, shared with third parties for a “business purpose,” or “sold,” or transferred for “valuable consideration.” The table below indicates the categories of personal data we collect and transfer in a variety of contexts. We do not “sell” your personal data for money.

California Sensitive Information Disclosure. We collect the following categories of sensitive personal data (as defined under California law): race, ethnicity, driver’s license or government-issued identification number. We collect this data to process transactions, comply with laws, manage our business, or provide services. Note that we do not use such data for any purposes that are not identified within Cal. Civ. Code § 1798.121. We do not “sell” or “share” sensitive personal data for cross-context behavioral advertising, although we may transfer it to third parties when you instruct us to do so. When that occurs, third parties will use it for the purposes indicated in their privacy notices.

California Shine the Light Law. California residents may also request information from us once per calendar year about any personal information shared with third parties for the third party’s own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To make such a request, please reach us at the contact information listed above. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.

The Privacy Policy was last updated and shall take effect on April 28, 2025.

Privacy Policy (KOR)

㈜이노크라스코리아 개인정보 처리방침