Privacy policy effective by 25th, May 2018

The italian version of this policy will be available soon.

Introduction

Icgene is a diagnostic system distributed by Avantech Group and Enbiotech. Icgene web is a web application designed, developed and provided by Infobiotech S.r.l., a private limited startup company registered in Italy that develops and manufacture technological systems for the science field. Infobiotech provides digital services through web pages, web applications, APIs and native mobile apps.

All Infobiotech's digital services acquire personal and non-personale data, collected, stored and processed according to their purpose and in compliance with current international regulations. To help users understand what information are collected, how are they used and what are their available choices, this policy will be keeped updated and available at https://web.icgene.com/privacy/policy. For more information do no hesitate to contact Infobiotech via email: 6c5b074603b37a1o4n5b074603b37a3t3a5b074603b37a5c17t5b074603b37a6@5i5b074603b37a7n9f5b074603b37a8o3b5b074603b37a9i9o5b074603b37aat3e5b074603b37abc4h5b074603b37ac.1c5b074603b37ado5m5b074603b37ae

Definitions

Icgene system
Icgene system is, for the purpose of this privacy policy, the combination of icgene web application, icgene API and icgene Android app.
Personal data
Personal data means data about a living individual who can be identified from those data (or from those and other information either in possession or likely to come into possession of the data controller).
Usage data
Usage data is data collected automatically either generated by the use of icgene system or from icgene system infrastructure itself.
Cookies
Cookies are small pieces of data stored on a user’s device.
Data controller
Data controller means a person or an organization who (either alone or jointly or in common with other persons and/or other organizations) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this privacy policy, Avantech Group and Enbiotech are the data controller of users data.
Data processor (or service providers)
Data processor (or service provider) means any person or organization (other than an employee of the data controller) who processes the data on behalf of the data controller. For the purpose of this privacy policy, Infobiotech is the primary data processor of icgene system. Infobiotech use the services of other service providers in order to process data more effectively. For more information about Infobiotech's data processing, please contact Infobiotech.
Data subject
Data subject is any living individual who is the subject of personal pata.
User
The user is the individual using icgene system. The user corresponds to the data subject, who is the subject of personal data.
Icgene data
Icgene data are application data generated and/or managed by icgene system (i.e. experiments results, samples names, etc.) owned by the user. All application data (including icgene data) are secured by Infobiotech and Infobiotech's service providers security systems. For more information about Infobiotech's security systems, please contact Infobiotech.

Data collection and use

Avantech Group and Enbiotech collect several different types of data for various purposes to provide and improve icgene system to the end users.

Types of data collected

Personal data

While using icgene system, Avantech Group and Enbiotech may ask the user to provide certain personally identifiable information that can be used to contact or identify the user (“personal data”). Personally, identifiable information may include, but is not limited to:

  • Contact data (email address)
  • First name and last name
  • Organization and position
  • Online identifiers (IP addresses, devices user agent, etc.)

Avantech Group and Enbiotech may use personal data to contact the user with newsletters, marketing or promotional materials and other information that may be of interest. The user may opt out of receiving any, or all, of these communications from Avantech Group and Enbiotech by following the unsubscribe link or instructions provided in any sent email.

Usage data

Avantech Group and Enbiotech may also collect information on how icgene system is accessed and used (“usage data”). These usage data may include information such as user computer’s Internet address (IP address), browser type and version, the pages of icgene system visited, the time and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking cookies data

Icgene system uses cookies and similar tracking technologies to track the activity on icgene system and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to user's browser from a website and stored on the device. Other tracking technologies are beacons, tags, and scripts to collect and track information and to improve and analyze icgene system.

Users can instruct their browser to refuse all cookies or to indicate when a cookie is being sent. However, if the user do not accept cookies, icgene system may malfunction or become not accessible.

Examples of cookies used by icgene system:

Session cookies
Icgene system uses session cookies to authenticate the user.
Preference cookies
Icgene system uses preference cookies to remember user's preferences and settings.
Security cookies
Icgene system uses security cookies for security purposes.

Icgene system do not uses advertising cookies. Advertising cookies are tipically used to serve advertisements that may be relevant to you user's interests.

All the data is collected directly from the data subject. Icgene system do not collect data from 3rd party sources via cookies.

Use of data

Infobiotech uses the collected data for various purposes:

  • To provide and maintain icgene system.
  • To notify the user about changes to icgene system.
  • To provide customer and technical support.
  • To gather analysis or valuable information necessary to improve icgene system.
  • To monitor the usage of icgene system.
  • To detect, prevent and address technical issues.

Legal basis for data processing

Avantech Group and Enbiotech use several legal bases for processing data:

  • Consent.
  • Performance of a contract.
  • Compliance with legal obligations.
  • legitimate interest of Avantech Group and Enbiotech, such as for marketing purposes, to control the regular operation of icgene system, to defend rights or to improve services.

Retention of Data

Avantech Group and Enbiotech will retain users personal data only for as long as is necessary for the purposes set out in this Privacy Policy. Avantech Group and Enbiotech will retain and use users personal data to the extent necessary to comply with legal obligations (for example, if required to retain data to comply with applicable laws), resolve disputes, and enforce legal agreements and policies.

Infobiotech will retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of icgene system, or when legally obligated to retain this data for longer time periods.

Transfer of data

Users information, including personal data, may be transferred to — and maintained on — servers and computers located outside of user's state, province, country or other governmental jurisdiction where the data protection laws may differ than those from user's jurisdiction.

The collected data that is mostly processed in Italy and United States.

Avantech Group, Enbiotech and Infobiotech transfer data to a country outside the European Economic Area only when that country ensures an adequate level of protection within the meaning of the legislation in force and, in particular, within the meaning of the GDPR - General Data Protection Regulation (for more information on the countries offering an adequate level of protection, see: https://goo.gl/KK9wLQ), or within the limits permitted by the legislation in force, for example by ensuring the protection of data by appropriate contractual provisions.

User's consent to this privacy policy followed by the submission of such information represents user's agreement to that transfer.

Avantech Group and Enbiotech will take all steps reasonably necessary to ensure that user's data is treated securely and in accordance with this privacy policy and no transfer of user's personal data will take place to an organization or a country unless there are adequate controls in place including the security of data and other personal information.

Disclosure of data

Business transaction

If Avantech Group, Enbiotech or Infobiotech are involved in a merger, acquisition or asset sale, user's personal data may be transferred. Avantech Group and Enbiotech will provide notice before personal data is transferred and becomes subject to a different privacy policy.

Disclosure for law enforcement

Under certain circumstances, Avantech Group and Enbiotech may be required to disclose personal data if required to do so by law or in response to valid requests by public authorities.

Legal Requirements

Avantech Group and Enbiotech may disclose users personal data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation.
  • To protect and defend the rights or property of Avantech Group and Enbiotech.
  • To prevent or investigate possible wrongdoing in connection with icgene system.
  • To protect the personal safety of users of icgene system or the public.
  • To protect against legal liability.

Security of data

The security of users data is important to Avantech Group, Enbiotech and Infobiotech, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While Avantech Group, Enbiotech and Infobiotech strive to use commercially acceptable means and best practise to protect users personal data, no one can guarantee its absolute security.

User's rights

Avantech Group and Enbiotech aims to take reasonable steps to allow users to correct, amend, delete, or limit the use of their personal data.

Whenever made possible, users can update their personal data directly within their account settings section. If users are unable to change their personal data, it's possible contact Infobiotech to make the required changes.

If users wish to be informed what personal data Avantech Group and Enbiotech hold about them and if they want it to be removed from all the systems, it's possible to contact Avantech Group and Enbiotech.

Users have the right to:

  • access and receive a copy of the personal data held about them;
  • rectify any personal data held about them that is inaccurate;
  • request the deletion of personal data held about them;
  • withdraw their consent over the data processing;

Users have the right to data portability for the information provided to Avantech Group and Enbiotech. Users can request to obtain a copy of their personal data in a commonly used electronic format so that can be managed and moved.

Avantech Group and Enbiotech may ask to verify user's identity before responding to such requests.

Service Providers

Avantech Group and Enbiotech employed third party company Infobiotech (service provider and data processor), to provide icgene system on their behalf, to perform service-related services or to assistance in analysing how icgene system is used.

This third party (and his service providers) have access to users personal data only to perform these tasks on behalf of Avantech Group and Enbiotech and are obligated not to disclose or use it for any other purpose. Icgene specific data is obfuscated and secured by layers of security. For more information about data security, it's possible to directly contact Infobiotech.

Analytics

Avantech Group, Enbiotech and Infobiotech may use third-party service providers to monitor and analyze the use of icgene system.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of icgene system. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

Users can opt-out of having made their activity on icgene system available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

More information on the privacy practices of Google, available at Google Privacy Terms web page https://policies.google.com/privacy

Obligation to provide data

Website and icgene system users, are under no statutory or contractual obligation to provide personal data. If users enter into a contractual relationship with Avantech Group and Enbiotech, they may need to provide some personal data for the purpose of the realization of the contract.

Links to other sites

Al Avantech Group, Enbiotech and Infobiotech services may contain references and/or links to other websites anf/or services that are not operated by them. If users click on a third party link, they will be directed to that third party’s resource. Avantech Group, Enbiotech and Infobiotech strongly advise users to review the corresponding third party’s privacy policy.

Avantech Group, Enbiotech and Infobiotech have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s privacy

Icgene system does not address anyone under the age of 16.

Avantech Group and Enbiotech do not knowingly collect personally identifiable information from anyone under the age of 16. If the parent or the guardian of a child is aware that their child has provided Avantech Group and Enbiotech with personal data, please contact Avantech Group and Enbiotech. If Avantech Group and Enbiotech become aware to have collected personal data from children without verification of parental consent, Avantech Group and Enbiotech will take steps to remove that information.

Changes to this privacy policy

Avantech Group and Enbiotech may update this privacy policy from time to time. Avantech Group and Enbiotech will notify users of any changes by posting the new privacy policy on this page. Avantech Group and Enbiotech could let users know via email and/or a prominent notice on icgene system, prior to the change becoming effective and update the effective date at the top of this privacy policy.

Users are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.

Jurisdiction

The current privacy policy is subject to Italian and European law. For cases related to the current document, Avantech Group and Enbiotech appoint the court in Angri (SA), Italy as the competent one.

Contacts

For any questions about this privacy policy, please contact Avantech Group, Enbiotech or Infobiotech.