Our Privacy Policy

Date Published

June 12 2023



Q Bio, Inc. (“Q Bio”) is committed to protecting your privacy in connection with your use of our Site. We have prepared this Privacy Policy to describe to you our practices regarding Personal Data health information (as each term is defined below) we collect from users of our website, located at https://q.bio, and our widgets (collectively, the “Site”) together with our Services. “Services” means Q Bio’s products, services, platform, and software tools, including those provided to Registered Members, Non-Members, and Site Visitors. By visiting the Site, using or downloading the Application, or using any of our Services, you agree that your personal information will be handled as described in this Privacy Policy.

Personal Data for purposes of this policy includes any data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

We will only process your Personal Data, health information, and Anonymous Data in accordance with applicable data protection and privacy laws and this Privacy Policy.

Protected health information. In certain circumstances, we may collect or use your information through our Sites and Services while acting as a Business Associate under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may constitute “Protected Health Information.” A “Business Associate” includes an entity that provides services to a HIPAA Covered Entity that involves the use or disclosure of Protected health information. If your health care provider or health insurance company qualifies as a Covered Entity, and we provide services to them or on their behalf, we may qualify as their Business Associate. “Protected Health Information” as defined under HIPAA, generally means information about you that identifies you and that relates to your physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. To the extent your PHI is collected while operating as Business Associate under HIPAA, we will only use and disclose your information as permitted by HIPAA, which may include, but not be limited to, fulfilling our service obligations, our internal management and administration, to carry out our legal responsibilities, de-identify or aggregate data, or as otherwise required by law.

The Information We Collect About You

We collect information about you directly from you and from third parties, and automatically through your use of our Site or Services.

Information We Collect Directly from You

The information we collect from you depends on how you use our Services. You are responsible for the accuracy of any information you provide to us.

Registered Member. A Registered Member completes the registration process to become a paying member of Q Bio’s Services. The registration process includes, but is not limited to, creating an account, accepting a Registered Member Terms of Use, submitting a signed research consent to participate in our research protocol described in the research consent and Registered Member Terms of Use (“Research Study”) and completing the payment process. A Registered Member is able to use the Services to store health information.

Non-Member. A Non-Member may access a Registered Member’s Q Bio profile and Gemini Dashboard upon invitation by the Registered Member. A Non-Member may also create and register an Access Account through which he or she could view a Registered Member’s Q Bio profile upon invitation by the Registered Member.

Site Visitor. Any visitors to Q Bio’s sites or services who are not registered or logged in.

We also collect the following information from Registered Members.

  • We may collect health information from you when you register your Account, during each Gemini Exam, any health information you choose to share with us through your Q Bio profile, and when you authorize us to compile your medical records created by healthcare professionals you consulted prior to joining Q Bio.
  • We may collect information about your healthcare professionals or other designated individuals from you when you sign up for our Services and when you choose to grant a healthcare professional or other individual permission to view your Q Bio profile as a Non-Member.
  • We may collect your payment information, as well as any needed contact information and a delivery address of any recipient when and if we provide your health information at your request.
  • We retain information on your behalf, such as the Personal Data and health information that you store using your Account.
  • When your health information is uploaded through our Services, the information will be stored in our servers (or those of our service providers and affiliates) and shared only with individuals to whom you grant access.

Information we collect from Third Parties.

Q Bio may collect information from third parties.

  • We may collect information about Registered Members from the third party labs and other providers that analyze your anonymized biological specimens that we gather as part of the Service.
  • We may collect information gathered by third party providers we work with in order to provide the Service to Registered Members, like imaging centers.
  • We may collect information about Registered Members from previous healthcare professionals through a third party medical records aggregation service with your consent.
  • Individuals to whom you grant access to your health information through the Q Bio platform as Registered Members who may upload, annotate or provide supplemental information.
  • We may collect information about Site Visitors, Non-Members, and Registered Members from our partners and third parties, such as advertising networks, for to refine our Site and Services and for advertising purposes.

Collected via Technology. Certain technology, such as Cookies, Pixel Tags, and Analytics Service technologies may collect information from Site Visitors, Non-Members, and Registered Members while you are on our Site.

Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site and Services, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Site and Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to determine if the computer or device used to access the Site and Services is authorized to view your data or Account information.

Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your website browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site and Services more useful to you and to tailor the experience with us to meet your special interests and needs.

Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, website beacons, or website bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of website users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in website pages. Pixel Tags also allow us to send e-mail messages in a format that users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user.

How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on our site.

Analytics Services. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Site. This includes third party analytics services, including but not limited to analytics service providers (“Analytics Services”), that we engage to help analyze how users use the Site and Services. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve our Site and Services. The information generated by the Cookies or other technologies about your use of our Site and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using our Site and Services, you consent to the processing of your Personal Data by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at support@q.bio.

Information Collected by Our Servers. To make our Site and Services more useful to you, our platform, which includes server (which may be hosted by a third party service provider) and client side software to collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

We will use the information we collect

In general, we use the information we collect to provide Services, conduct the Research Study, respond to requests, or to aid us in serving you better, including but not limited to:

  • provide improved administration of our Site and Services
  • improve the quality of experience when you interact with our Site and Services
  • for internal administrative purposes
  • respond to inquiries related to information about our Services, employment opportunities or other requests
  • facilitate our advertising and customer/prospective customer outreach efforts
  • improve our service offerings, such as by better understanding Member or prospective Member demographics, interests, locations, or other information.

In addition, if you are a Non-Member or Registered Member, we use your Personal Data to:

  • facilitate the creation of and secure your Account on our network
  • identify you as a user in our system
  • provide the Services you request
  • send you Account verification e-mails or text messages in order to secure access to your Account
  • send e-mails or text messages in order to provide the Service
  • send you administrative e-mail notifications, such as security or support and maintenance advisories

If you are a Registered Member, your Personal Data and/or health information are additionally used to:

  • conduct each Gemini Exam, including sample and imaging collection and analysis
  • compile and store your health information for your use
  • facilitate our Research Study
  • develop measurement protocols optimized to identify pathologies dependent on individual risk factors
  • develop generalized and personalized models of human biological processes
  • develop diagnostics and clinical decision support tools
  • grant access to your Q Bio profile to healthcare professionals and other individuals to whom you grant access, as Non-Members
  • make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Q Bio
  • for internal administrative purposes
  • improve our algorithms and derive insights to make our Site and Services more accurate and useful to you and other Members
  • develop new techniques and service offerings

De-identified Data:

We may create de-identified-and aggregated data records from the Personal Data and health information we obtain from you by permanently removing information (such as your name) that makes the data personally identifiable to you. We reserve the right to use or disclose such aggregated or de-identified information for any purpose. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

We may share the information we collect

We share or disclose the information we collect as described below and as described elsewhere in this Privacy Policy.

We may share information with:

  • Third Parties Designated by You. The Personal Data and health information provided by you as a Registered Member will be shared with the third parties that you designate to receive such information according to your preferences. We may share your Personal Data and health information with your healthcare professionals and other individuals to whom you provide access as Non-Members. You may change who has access to your health information at any time by logging into your Q Bio Registered Member account.
  • Third Party Service Providers. We may share the your Personal Data with third party service providers, agents or contractors who perform services or functions on behalf of Q Bio. These service providers may include, but are not limited to technology service providers such as Microsoft or Google, administrative service providers, payment processors, clinical laboratories or health care facilities.
  • Affiliates. If you are a Site Visitor, Non-Member, or Registered Member, we may share some or all of your Personal Data, and if you are a Registered Member, we may share your health information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
  • Advertising Partners. We may share de-identified or aggregate data with our advertising partners.

We may also share information as a result of:

  • Corporate Restructuring. If you are a Site Visitor, Non-Member, or Registered Member, we may share some or all of your Personal Data, and if you are a Registered Member, we may share your health information in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data and health information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data and health information collected by us and will assume the rights and obligations regarding your Personal Data and health information as described in this Privacy Policy.
  • Legally Required Disclosures. Regardless of any choices you make regarding your Personal Data and health information, in limited circumstances, Q Bio may disclose the Personal Data of a Site Visitor, Non-Member, or Registered Member, and/or the health information of a Registered Member, if it believes in good faith that such disclosure is required (a) to comply with relevant laws or to respond to subpoenas or warrants served on Q Bio; (b) to protect or defend the rights or property of Q Bio; (c) to protect the rights of users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the applicable Terms of Use.

You can contact us if you have questions or need to report anything

If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:Q Bio, Inc.

1411 Industrial Road
San Carlos, CA 94070

Our Site is not for children

We do not intentionally gather Personal Data or health information from visitors who are under the age of 13. If a child under 13 submits Personal Data or health information to Q Bio and we learn that the Personal Data or health information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data or health information from a child under 13, please contact us at support@q.bio.

Our Site is not designed for Users Outside of the United States

By visiting the Site and providing us with data, you acknowledge that our Site is not intended for users outside of the United States. If you are outside the United States and choose to submit your Personal Data and health information, it may be processed for any purposes consistent with the Privacy Policy. In addition, your Personal Data and health information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data and health information may be less stringent than the laws in your country.

We take steps to secure the information provided to us

Q Bio employs reasonable safeguards to secure Personal Data and health information. You play a vital role in protecting your own Personal Data and health information. When registering on the Q Bio Site, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to your Account. Q Bio will never ask you for your password in an unsolicited call or an unsolicited email. We may ask you to confirm personal identifiers when registering an Account or requesting support, which we use in conjunction with other security measures — such as email verification — to confirm your identity and safeguard your personal information.

Information about Third Party Websites that may be on our Site

Third Party Websites. Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

You have choices regarding how we use your information for our Service

Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.

Email Communications. We may periodically send Non-Members and Registered Members free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to the applicable Terms of Use or Privacy Policy.

Changing or Deleting Your Personal Data and health information. All Registered Members may review, update, correct or delete the Personal Data in their user Account by editing their user Account via the Services. You may also be able to review, update, correct or delete self-reported health information, but you may not be able to delete data that has been received by Q Bio from third-party partners as part of the Service.

If you wish to deactivate or delete your Account and associated Personal Data and health information, please contact us at support@q.bio. Our data retention and deletion policy is subject to the terms of our Registered Member Terms of Use. We may retain an archived copy of your records as required by law or for legitimate business purposes.

We may retain your information

Information Retention. If you are an Site Visitor or a Non-Member, we will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. If you are a Registered Member, we will retain your Personal Data and/or health information for the period necessary to provide you with Services and completed our Research Study, or as required by law or for legitimate business purposes.

This Privacy Policy may change from time to time

Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision. If we make any material changes in the way we use your Personal Data and/or health information as a Non-Member or Registered Member, we will notify you by sending you an email to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Data and/or health information, you may notify us prior to the effective date of the changes that you wish to deactivate your Account with us by contacting us at support@q.bio. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes.

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