AscencioDx® Detector Portal Privacy Policy
Anavasi Diagnostics (“Anavasi,” “we,” “us,” or “our”) provides a secure website reporting platform for the AscencioDx COVID 19 Molecular Diagnostic System, which is initially accessed via a QR code on the back of the Detector and subsequently accessed through a secure login. It allows healthcare/medical providers to access and store patient information and access healthcare resources and services and also allows patients direct access to their healthcare information (collectively, the “Anavasi Services”).
This Privacy Policy applies to visitors to the Website and subscribers to the Anavasi Services. For the purposes of this Disclaimer, “you” and “your” means you as the visitor of the Website and users of the Anavasi Services.
We provide the Anavasi Services as a professional resource intended to support healthcare professionals in their efforts to provide high quality medical care to patients. You can choose whether or not you want to use the Anavasi Services. If you do choose to use the Anavasi Services, you must agree to our Terms of Use which is a contract between us and users of the Anavasi Services. By agreeing to Terms of Use, you confirm that you have read and understand this Privacy Policy, which explains how we collect, disclose, transfer, secure and use information about you in connection with your use of the Anavasi Services and the rights and choices you have regarding these activities. If you do not want us to collect and use information about you as described in this Privacy Policy, then you may not access the Website or use the Anavasi Services.
DO NOT USE THE ANAVASI SERVICES FOR YOU OR SOMEONE ELSE THAT REQUIRES EMERGENCY MEDICAL ATTENTION. PLEASE DIAL 911 OR SEEK YOUR NEAREST EMERGENCY ROOM FACILITY FOR ANY EMERGENCY NEEDS.
BY DOWNLOADING THE ANAVASI SERVICES, YOU (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY; (B) REPRESENT THAT YOU ARE 18 YEARS OF AGE OR OLDER/OF LEGAL AGE TO ENTER INTO A BINDING AGREEMENT; AND (C) ACCEPT THIS THE TERMS OF THEIR PRIVACY POLICY AS A BINDING AGREEMENT BETWEEN YOU AND ANAVASI, MEANING YOU AGREE THAT YOU ARE LEGALLY BOUND BY ITS TERMS. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT ACCESS THE WEBSITE OR UTILIZE THE ANAVASI SERVICES
ANAVASI DOES NOT PROVIDE ANY SERVICES OTHER THAN A CONNECTION PLATFORM THAT ALLOWS HEALTHCARE/MEDICAL PROVIDERS, INCLUDING THEIR EMPLOYEES AND BUSINESS ASSOCIATES TO UPLOAD, STORE AND TRACK PATIENT INFORMATION, INCLUDING DIAGNOSES, TREATMENT PLANS, PRESCRIPTIONS, APPOINTMENT NOTES, ETC., MEANING THAT ANAVASI DOES NOT PARTICIPATE IN THE DIAGNOSIS OR TREATMENT OF PHYSICAL, MENTAL, OR MEDICAL CONDITIONS, NOR DOES ANAVASI PARTICIPATE IN DOCUMENTING INTERACTIONS BETWEEN USERS OF THE APPLICATION AND PROFESSIONAL HEALTHCARE PROVIDERS.
Scope Of This Privacy Policy
This Privacy Policy describes the types of Personal Information we collect from visitors of our public Website and users/subscribers of the Anavasi Services, and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us. We operate in two ways. First, we work with healthcare/medical providers and their employees and business associates, the type of data that we collect is limited to business-to-business (“B2B”) data, meaning this type information is collected is not about an individual personally, rather, it is collected about the individual’s role with a particular healthcare/medical provider, which would be our client (our client along with all authorized users as hereinafter referred to as “Members”). Second, we collect patient test results. The Anavasi Services allow patients to view their test rests as uploaded by their healthcare/medical provider.
This Privacy Policy does not apply to information that is provided by a healthcare/medical provider via the Anavasi Services via password-protected and secure portions of the Anavasi Services (“Secure Platform”). The Secure Platform allows eligible Members to use Anavasi Services. All information collected and stored by Anavasi or added by our Members into such Secure Platform is considered Protected Health Information (“PHI”) and/or medical information and is governed by laws that apply to that information, for example the Health Insurance Portability and Accountability Act (“HIPAA”). How we use and disclose such PHI is in accordance with the applicable consents and notices. To understand how we use and disclose PHI, for example data you have consented to allow your information to be entered into the Secure Platform, is subject to the terms of our End User Licensing Agreement between our Members and us. We will not use or disclose information received from the Website or the Anavasi Services for advertising, marketing, or other use-based data mining purposes, and will not combine it with other data and will not sell it.
This Privacy Policy also does not apply to the collection and use of certain employment-related information.
Third Party Links
When using the Anavasi Services you may choose to interact with features from third parties that operate independently from Anavasi, such as links to a third-party website or Anavasi Services. Anavasi has no control over and is not responsible for the privacy practices of such third parties. This Privacy Policy does not apply to the extent Anavasi does not own or control any linked Anavasi Services or features you visit or use. We recommend that you familiarize yourself with the privacy practices of those third parties.
Limited Geographic Access
By using the Anavasi Services, you acknowledge that we will store, use and otherwise process your information in the United States and that we only provide the Anavasi Services to users in the United States. Unless otherwise specified herein or on the property from which you have accessed this Privacy Policy, Anavasi is the controller of the personal information that we collect about you as described in this Privacy Policy.
Type Of Personal Information We Collect
While accessing our Website or while using Anavasi Services, you may provide us with certain information about you including the following:
Agent Information. In order to access parts of the Website or use the Anavasi Services, you may be required to register an account and provide certain Personal Information such as your full name, name, occupation/job title, employer, employer address, and employer-provided email address. You may choose to update or supplement the Personal Information that you provided at registration at any time through your account settings or by contacting us.
When you use the Website or the Anavasi Services, we may automatically collect information through the use of cookies and other tracking technologies as follows:
Device Information. We automatically collect and store information about your use of the Anavasi Services, such as your engagement with particular content, whether you opened a particular email, clicked on a link, your search queries and how often and when you engage with the Services. We also collect information about your device when you access the Services including IP address, precise location information, browser information (including referring URL), cookie information and advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device). We use cookies and other tracking technologies, such as pixels, tags, web beacons and software development kits, to collect the information about your use of the Services and your device.
Agent Information and Device Information is referred to as “Personal Information”.
How Do We Collect Personal Information?
We may collect Personal Information using the following methods:
Directly from you when you provide it to us (such as information you answer inquiries, provide responses, engage with the Anavasi Services, and during registration to use a Secure Platform).
From third parties, such as Google Analytics, including demographic information such as gender and age (see below).
Automatically through tracking technologies such as cookies, web beacons (also known as pixels) and log files, including over time and across third-party Anavasi Services or other online services.
“Cookies” are small files that a website stores on a user’s computer or device. The Anavasi Services may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are “session” cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Anavasi Services and to limit the amount of redundant data that is downloaded during a single session. We also may use “persistent” cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our services. We may use session and persistent cookies for analytics and advertising purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (see below). In accordance with applicable law, we may obtain your consent separately before collecting information by automated means using cookies or similar devices.
How We Use Your Information
We may use your Personal Information for the following purposes:
Operate, maintain, supervise, administer, and enhance the Anavasi Services, including monitoring and analyzing the effectiveness of content on the Anavasi Services, aggregate site usage data, and other usage of the Anavasi Services such as checking your eligibility and assisting you in completing the registration process.
Provide you with a tailored and user-friendly experience as you navigate our Anavasi Services.
To promote and market our Anavasi Services to you.
To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information, refer you to a specialized healthcare provider.
Conduct research on your demographics, interests, and behavior based upon information provided during use of our Anavasi Services.
Anonymize and aggregate information for analytics and reporting.
Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Anavasi Services and safety of users.
Develop, test, improve, and demonstrate the Anavasi Services.
Any other purpose which we provide you notice and/or that you provide your consent.
How We Share Your Information
Our processing of your Personal Information is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to us, in some cases, your Personal Information may be accessible to certain types of persons in charge, involved with the operation of the Anavasi Services, e.g., administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by us. The updated list of these parties may be requested from the Owner at any time. We may share Personal Information with third parties in certain circumstances or for certain purposes, including:
For business purposes. We may share your Personal Information with service providers, including our data hosting and data storage partners, analytics, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms. We may disclose your name, email address, phone number, and address if you provided it to us via a form on the website or during an incomplete or failed registration to Service Providers.
With your direction or consent. We may share your Personal Information with third parties if you request or direct us to do so. This includes your use of social media widgets on our Anavasi Services.
With affiliates within our corporate group. We may share your Personal Information with any subsidiaries within our corporate group.
Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
In the context of a transaction. We may share your Personal Information connection with an asset sale, merger, bankruptcy, or other business transaction.
For other business reasons. We may share your Personal Information to enforce any applicable Legal Disclaimer, and to ensure the safety and security of the Anavasi Services and/or our users.
We also may disclose de-identified information.
Currently, we interact with the following business partners to allow you to view our Website and access the Anavasi Services:
Google Fonts (Google LLC): Google Fonts is a typeface visualization service provided by Google LLC that allows us to incorporate content of this kind on our Website pages and throughout the Anavasi Services.
Adobe Fonts (Adobe Systems Incorporated): Adobe Fonts is a typeface visualization service provided by Adobe Systems Incorporated that allows us to incorporate content of this kind on our Website pages and throughout the Anavasi Services.
Microsoft Azure (Microsoft Corporation): Microsoft Azure is a hosting services provided by Microsoft Corporation.
Squarespace (Squarespace, Inc.): Squarespace is a platform provided by Squarespace, Inc. that allows the Owner to build, run and host the Anavasi Services. Squarespace is highly customizable and can host websites from simple blogs to complex e-commerce platforms.
These services host and run key components of the Website and the Anavasi Services from within a unified platform, and provide a wide range of tools to us, e.g., analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Information.
Security Of Personal Information
We take steps to secure Personal Information through administrative, technical, and physical safeguards designed to protect against the risk of accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.
Retention Of Personal Information
We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements. Because we maintain our Anavasi Services to protect from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or put beyond use where deletion is not possible.
California Data Subject Rights
Shine the Light Law
Under California Civil Code Sections 1798.83-1798.84, we may now or in the future elect to share information about you with third parties for those third parties’ direct marketing purposes. Specifically, California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of Personal Information to third parties for their direct marketing purposes. If this law applies to you, you may obtain the categories of Personal Information shared by us and the names and addresses of all third parties that received Personal Information for their direct marketing purposes from us during the immediately prior calendar year (e.g., requests made in 2021 will receive information about 2020 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send us an email with “California Privacy Rights” as the subject line or mail us a letter. You must include your full name, email address with which you registered on our Site, and postal address in your request.
California Consumer Privacy Act (“CCPA”) “Notice”
If you are a California resident, or were within the last year, you have the following rights under applicable California law in relation to your Personal Information, subject to certain exceptions:
Right to Know. You have the right to, up to twice in a 12-month period, request what Personal Information we collect, use, disclose, and/or sell, as applicable.
Right to Delete. You have the right to request the deletion of your Personal Information that is collected by us.
Right to Opt-Out of Sale. You have the right to opt-out of the sale of your Personal Information by a business. However, as noted above, we do not currently sell any Personal Information.
Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
Right to Data Portability. You have the right to request a copy of your Personal Information we have collected and maintained about you in the past 12 months or at any time since January 1, 2022.
Understand, however, that based on the information we gather, and the fact that We do not “sell” personal information as that term is defined in the CCPA, your rights are somewhat limited as these rights are not absolute and are subject to certain exceptions. For instance, we are not required to respond to requests concerning employment/application data, B2B data, and cannot disclose or permit access to specific pieces of personal information if the disclosure or access would present a certain level of risk to the security of the personal information, your account with us, or the security of the business’s systems of networks.
Specifically, employment/application data is not subject to this Privacy Policy if it is Personal Information that is collected by us in the course of your acting as a job applicant, employee, owner, director, officer, medical staff member, or contractor to us to the extent your personal information is collected and used by us solely within the context of your role or former role as a job applicant to, employee of, owner of, director of, officer of, medical staff member of, us or a contractor/third party business partner/service provider of ours. This also extends to any emergency contact information or benefits administration information you may have provided us in this context.
B2B data is similarly not subject to this Privacy Policy if the data reflects a written or verbal communication or transactions between you and us if you are acting as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit, or government agency and whose communications or transaction with us occurs solely in the context of us conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, nonprofit or government agency. If you are a California consumer, we will process your request to exercise your rights in accordance with California Laws.
Please note that if you request deletion of your Personal Information, we may deny your request or may retain certain elements of your Personal Information if it is necessary for us or our service providers to:
Complete the transaction for which the Personal Information was collected, provide goods or services requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between our business and you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.
To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
Comply with a legal obligation.
Otherwise use the Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted by the CCPA. To submit a request, please click this link, or have your designated representative click this link or email us. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the Personal Information on. These rights are also subject to various exclusions and exceptions under applicable laws.
You may also designate an authorized agent, in writing or through a power of attorney, to request to exercise the above rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
We currently do not collect household data. If we receive a Right to Know or Right to Delete request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13 as we do not collect Personal Information from any person under the age of 13.
We will respond to your request within 45 days after receipt of a Verifiable Consumer Request for a period covering 12 months and for no more than twice in a twelve-month period. We reserve the right to extend the response time by an additional 45 days when reasonably necessary and provided consumer notification of the extension is made within the first 45 days.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Requests to Opt-In for Minors
If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time. We do not and will not sell personal information of consumers we actually know are less than 16 years of age unless we received affirmative authorization from the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age, to opt-in to the sale of their personal information. Upon the receipt of this request to opt-in, we will inform the minor of the right to opt-out later and of the process for doing so.
Sale and Disclosure of Personal Information
Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. It does not necessarily mean money was exchanged for the transfer of personal information. We have taken substantial steps to identify whether any of our data sharing arrangements would constitute a “sale” under the CCPA. Due to the complexities and ambiguities in the CCPA, we will continue to evaluate some of our third party relationships as we wait for final implementing regulations and guidance. For example, it is currently unclear whether the use of certain types of advertising partners would be considered a sale under CCPA. Based on our understanding of the CCPA at this time, in the preceding 12 months We have not sold any Personal Information to any third parties. In the preceding 12 months, We have disclosed Personal Information to third parties for business purposes including to customer service, technical support, payment processors, information technology, and sales, recruiting and marketing partners. We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.
Security Of Data
We have implemented measures that are designed to limit access to Personal Information to authorized individuals and to prevent the loss or corruption of data. We have implemented commercially reasonable data security technologies designed to preserve the security of all Personal Information collected and/or processed on our platform, including encryption for all such Personal Information in transit and at rest when applicable except for metadata and photos which are publicly accessible and not encrypted at rest.
Please understand, however, that no security system is impenetrable or perfectly secure. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to or from us over the Internet. As a result, you use the Site at your own risk. When registering with us on the Site, we encourage you to choose passwords of sufficient length and complexity, install the latest security updates and anti-virus software on your computer to help prevent malware and viruses, not share your password with others, and review your account information periodically. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, please contact us using the contact information provided above.
Data Retention
We only collect and process Personal Information that we need to perform the services, including communicate with you, process an order or as otherwise described in this Privacy Policy. We have adopted policies that require us to delete or anonymize all data that are no longer required for the performance of these functions.
Passwords
For the purposes of accessing some of the Anavasi Services, you may have to set up an account, which includes choosing a username and password. You are responsible for the security and confidentiality of your password and login information.
Do Not Track (Including California Do Not Track Disclosure)
Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, We do not respond to Web browser “do not track” settings or signals. We currently do not support “Do Not Track” requests.
Minors/Childrens’ Privacy
Neither the Website nor the Anavasi Services are directed toward, or intended for use by, individuals under age 18. We do not knowingly collect information from anyone under age 18. If you are under the age of 18, please do not use the Website or otherwise attempt to access the Anavasi Services and do not register with, order or purchase from, or provide any Personal Information to, us. If we find out that we have collected information from a minor under age 18, we will take all commercially reasonable steps delete that information immediately. If you are under the age of 18, you should use the Website only with the involvement of a parent or legal guardian and should not submit any Personal Information to us. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided us with their Personal Information, you may contact us using the below information to request that it be deleted.
International Users
Our Website and the Anavasi Services are not available and are not marketed to users outside the United States. If you are a user from a country outside the United States, and you choose to access the Website, you are deemed to consent to the transfer of any Personal Information you disclose from the country from which you reside or from which you access the Website to United States, as allowed by law.
Accessibility
We strive to assure that our Website and that the Anavasi Services are accessible. If you experience any difficulty in accessing any part of the Website, the Anavasi Services or this Privacy Policy, please contact us immediately.
Severability and Enforceability
To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.
Updating This Privacy Policy
This Privacy Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.
How To Contact Us
Should you have any questions about our privacy practices or this Privacy Policy, please email us at info@anavasidx.com or contact us at:
Anavasi Diagnostics
Fluke Hall
4000 Mason Rd.
Seattle, WA 98195