This Privacy Statement applies to all websites owned and operated by Basepaws, Inc. (“Basepaws”), including https://basepaws.com/, and any other websites, pages, features, or content we own or operate, and to your use of the Basepaws mobile app and any related Services. Our Privacy Statement is designed to help you better understand how we collect, use, store, process, and transfer your information when using our Services.
Please carefully review this Privacy Statement and our Terms of Service. By using our Services, you acknowledge all of the policies and procedures described in the foregoing documents. If you do not agree with or you are not comfortable with any aspect of this Privacy Statement or our Terms of Service, you should immediately discontinue use of our Services.
1. KEY DEFINITIONS.
a. Aggregate Information: information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.
b. De-identified Information: information that has been stripped of your Registration Information (e.g., your name and contact information) and other identifying data such that you cannot reasonably be identified as an individual, also known as pseudonymized information.
c. Individual-level Information: information about a single cat’s genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.
d. Personal Information: information that can be used to identify you, either alone or in combination with other information. Basepaws collects and stores the following types of Personal Information:
a. Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, user ID and password, and payment information).
b. Genetic Information: information regarding your cat’s genotypes (i.e. the As, Ts, Cs, and Gs at particular locations in your cat’s genome), generated through processing of your cat’s saliva or hair by Basepaws or by its contractors, successors, or assignees; or otherwise processed by and/or contributed to Basepaws.
c. Reported Information: Information you provide directly to us, including your cat’s disease conditions, other health-related information, traits, breed, history, and other information that you enter into surveys, forms, or features while signed in to your Basepaws account.
e. Sensitive Information: Information about your cat’s health markers, Genetic Information, nutritional information and certain Reported Information such as breed and origin.
f. User Content: all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials – other than Genetic Information and Reported Information-generated by users of Basepaws Services and transmitted, whether publicly or privately, to or through Basepaws.
g. Web-Behavior Information: information on how you use Basepaws Services collected through log files, cookies, web beacons, and similar technologies, (e.g., browser type, domains, page views).
2. INFORMATION WE COLLECT.
a. Information you provide directly to us:
- Registration Information. When you purchase our Services or create a Basepaws account and register your kit, we collect Personal Information, such as your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information (e.g. email and phone number).
- Reported Information. You have the option to provide us with additional information about your cat through surveys, forms, features and applications. For example, you may provide us with information about your cat’s traits (e.g., eye color, weight), breed, disease conditions, other health-related information, and history.
- User Content. Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission (“User Content”). For example, User Content includes any discussions, posts, or messages you send on Basepaws’s Forums.
- Blogs and Forums. Our website offers publicly accessible blogs. Additionally, Basepaws customers may participate in our online Forums. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. To request that we remove or de-identify your Personal Information from our blog or Forums, contact us at email@example.com. Please note that whenever you post something publicly, it may sometimes be impossible to remove all instances of the posted information, for example, if someone has taken a screenshot of your posting. Please exercise caution before choosing to share Personal Information publicly on our blogs, Forums or in any other posting. You may be required to register with a third party application to post a comment. To learn how the third party application uses your information, please review the third party’s privacy statement.
- Social media features and widgets. Our Services include Social Media Features, such as the Facebook “Like” or “Share” button and widgets (“Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third-party social media services to provide us information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the social network. Features are either hosted by a third-party or hosted directly on our site. Your interactions with these Features are governed by the privacy statements of the third party companies providing them. You should always review and, if necessary, adjust your privacy settings on third party websites and services before linking or connecting them to our website or Service.
- Third party services (e.g., social media). If you use a third party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person’s name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third party site. We do not control the third party site’s information practices, so please review the third party’s privacy statement and your settings on the third party’s site carefully.
- Customer service. When you contact Customer Care or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Service, Privacy Statement or applicable laws or regulations; and analyze and improve our Services.
b. Information related to our genetic testing services:
- Saliva and/or hair sample and biobanking. To use our genetic testing services, you must purchase, or receive as a gift, a Basepaws Genetic Service testing kit, create an online account and register your kit, and ship your cat’s saliva or hair sample to our laboratory. Our laboratory will extract your cat’s DNA from the saliva or hair sample for analysis.
- Genetic Information. Information regarding your cat’s genotype (e.g. the As, Ts, Cs, and Gs at particular locations in your pet’s genome), your pet’s Genetic Information, is generated when we analyze and process your cat’s saliva or hair sample, or when you otherwise contribute or access your cat’s Genetic Information through our Services. Genetic Information includes the Basepaws results reported to you as part of our Services, and may be used for other purposes, as outlined in Section 3 below.
c. Web-Behavior Information collected through tracking technology (e.g. from cookies and similar technologies).
i. help us recognize you when you use our Services;
ii. customize and improve your experience;
iii. provide security;
iv. analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service);
v. gather demographic information about our user base;
vi. offer our Services to you;
vii. monitor the success of marketing programs; and
viii. serve targeted advertising on our site and on other sites around the Internet.
3. HOW WE USE YOUR INFORMATION.
Basepaws will use and share your Personal Information with third parties only in the ways that are described in this Privacy Statement. No personally identifiable information about the pet, or the pet parent, is sold or shared with insurance, food, drug or any other company for any reason. Some aggregate data, such as disease and genetic marker association data, may be later shared as part of joined R&D efforts.
a. To provide you with Services and analyze and improve our Services.
We use the information described above in Section 2 to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with this Privacy Statement to: open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals); enable and enhance your use of our website and mobile application(s), including authenticating your visits, providing personalized content and information, and tracking your usage of our Services; contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.); enforce our Terms of Service and other agreements; monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks; and perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities.
b. To process, analyze and deliver your genetic testing results.
As described above, to receive results through the Personal Genetic Service, you must create a Basepaws account, register your kit, and submit your cat’s saliva or hair sample to our laboratory, which processes and analyzes your cat’s sample to provide us with your cat’s raw Genetic Information. Once we receive your cat’s raw Genetic Information, we further analyze it to provide you with our reports, dependent on the Service purchased. Basepaws continuously works to improve our Services based on our research and product development, and genetic associations identified in scientific literature. If you are eligible to receive additional reports or updates in the future, you may be notified of or may directly access these updates.
c. To allow us to share your Personal Information for Basepaws Research purposes.
You have the choice to participate in Basepaws Research by providing your consent here. “Basepaws Research” refers to research aimed at publication in peer-reviewed journals and other research conducted by Basepaws, or by sharing our data on an aggregated level with other academics, researchers or companies to promote the study of animal health.
Basepaws Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or other companies. Basepaws Research may study a specific group or breed, identify potential areas or targets for product development, conduct or support the development of new features, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve animal health care. Basepaws Research uses Aggregate and/or Individual-level Genetic Information and Reported Information as specified in the appropriate Consent Document(s), as explained in greater detail below.
Your cat’s De-identified Genetic and Reported Information may be used for Basepaws Research. You do not need to specifically consent to any additional document.
Your cat’s Genetic Information and/or Reported Information will be used for research purposes, but it will be de-identified and will not be linked to your Registration Information.
Basepaws may use individual-level Genetic Information and Reported Information internally at Basepaws for research purposes.
Basepaws may share summary statistics, which do not identify any particular individual cat or contain individual-level information, with our qualified research collaborators.
Withdrawing your Consent. You may withdraw your consent to participate in Basepaws Research at any time by contacting us at firstname.lastname@example.org. Basepaws will not include your cat’s Genetic Information or Reported Information in studies that start more than 30 days after you withdraw (it may take up to 30 days to withdraw your information after you withdraw your consent). Any research involving your cat’s data that has already been performed or published prior to your withdrawal from Basepaws Research will not be reversed, undone, or withdrawn. You may also discontinue your participation in Basepaws Research by deleting your Basepaws account (as described in section 5.d).
d. To recruit you for external research. Research is an important aspect of Basepaws’s Services and we want to ensure interested participants are aware of additional opportunities to contribute to interesting, novel scientific research conducted by academic institutions, healthcare organizations, pharmaceutical companies, and other groups. If you have chosen to participate in Basepaws Research, from time to time we may inform you of third party research opportunities for which you may be eligible. For example, if a university tells us about a new cancer research project, we may send an email to Basepaws research participants who potentially fit the relevant eligibility criteria based on their cat’s Reported Information to make them aware of the research project and provide a link to participate with the research organization conducting the study.
e. To provide customer support. When you contact Customer Care, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one customer’s Personal Information to resolve another customer’s dispute or request. For example, if a customer reports behavior that violates our Terms of Service, we will separately process both customers’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another customer without your consent.
f. To conduct surveys or polls and obtain testimonials. We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us.
g. To provide you with marketing communications. By creating a Basepaws account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe”. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
4. INFORMATION WE SHARE WITH THIRD PARTIES.
a. General service providers.
We share the information described above with our third party service providers, as necessary for them to provide their services to us and help us perform our contract with you. Service providers are third parties (other companies or individuals) that help us to provide, analyze and improve our Services. While Basepaws directly conducts the majority of data processing activities required to provide our Services to you, we engage some third party service providers to assist in supporting our Services, including in the following areas:
- Order fulfillment and shipping. Our payment processor processes certain Registration Information, such as your billing address and credit card information, as necessary to enable you to purchase a Basepaws kit from the Basepaws.com online store. Our distribution centers ship your kit(s) to you, and in some cases help return your kit safely to our laboratory so your sample can be processed.
- Customer Care support. Our Customer Care team uses a number of tools to help organize and manage the requests we receive. These tools help to ensure we provide timely, high quality support.
- Cloud storage, IT, and Security. Our cloud storage providers provide secure storage for information in Basepaws databases, ensure that our infrastructure can support continued use of our Services by Basepaws customers, and protect data in the event of a natural disaster or other disruption to the Service. Our IT and security providers assist with intrusion detection and prevention measures to stop any potential attacks against our networks. We have these third party experts perform regular penetration tests and periodically audit Basepaws’s security controls.
- Marketing and analytics. When you use our Services, including our website or mobile app(s), our third party service providers may collect Web-Behavior Information about your visit, such as the links you clicked on, the duration of your visit, and the URLs you visited. This information can help us improve site navigability and assess our Marketing campaigns.
NOTE: Our service providers act on Basepaws’s behalf. We implement procedures and maintain contractual terms with each service provider to protect the confidentiality and security of your information. However, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.
c. Aggregate information. We may share Aggregate Information, which is information that has been stripped of your cat’s name and your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. This Information is different from “Individual-level” information and is not Personal Information because it does not identify any particular individual or cat or disclose any particular individual’s or cat’s data. For example, Aggregate Information may include a statement that “10% of our Siamese cats share a particular genetic trait,” without providing any data or testing results specific to any individual cat. In contrast, Individual-level Genetic Information or Reported Information consists of data about a single cat’s genotypes, diseases or other traits/characteristics information and could reveal whether a specific cat has a particular genetic trait, or consist of all of the Genetic Information about that cat. Basepaws will ask for your consent to share Individual-level Genetic Information or Reported Information with any third party, other than our service providers as necessary for us to provide the Services to you.
d. As required by law. Under certain circumstances your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. For example, we may be required to disclose Personal Information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Basepaws will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that Basepaws may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Basepaws Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Basepaws, its employees, its users, its clients, and the public.
e. Business transactions. In the event that Basepaws goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.
5. YOUR CHOICES.
a. Access to your account. We provide access to your Basepaws data within your Basepaws account. You can access and download data processed by Basepaws within your Account Settings and within applicable Reports, Tools, and features. If you lose access to your Basepaws account or account email address, please contact Customer Care for assistance. If you lose access to your Basepaws account, in certain circumstances, we may require that you submit additional information sufficient to verify your identity before providing access or otherwise releasing information to you. If you choose not to submit the required documentation, or the information provided is not sufficient for the purposes sought, Basepaws will not be able to sufficiently verify your identity in order to complete your request.
You may access, correct or update most of your Registration Information on your own within your Account Settings. Please note that you may not be able to delete User Content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third parties.
b. Marketing communications. As noted in Section 3.g. you may be asked to opt-in to receive product and promotional emails or notifications when creating your Basepaws account depending on where you are located. You can always click the “unsubscribe” button at the bottom of promotional email communications to opt-out.
c. Account deletion. If you no longer wish to participate in our Services, or no longer wish to have your Personal Information be processed, you may delete your Basepaws account and Personal Information within your Account Settings. Once you submit your request, we will send an email to the email address linked to your Basepaws account detailing our account deletion policy and requesting that you confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated Personal Information is deleted and any stored samples are discarded, subject to the following limitations:
6. SECURITY MEASURES.
Basepaws takes seriously the trust you place in us. Basepaws implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information.
a. Basepaws produces secure applications by design. Basepaws incorporates explicit security reviews in the software development lifecycle, quality assurance testing and operational deployment.
b. Encryption. Basepaws uses industry standard security measures to encrypt Sensitive Information both at rest and in transit.
c. Managing third party service providers. Basepaws requires service providers to implement and maintain accepted industry standard administrative, physical and technical safeguards to protect Personal Information.
Your Responsibility. Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify Basepaws of any unauthorized use of your password. Basepaws cannot secure Personal Information that you release on your own or that you request us to release.
7. CAN-SPAM ACT.
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.We collect your email address in order to:
b. Process orders and to send information and updates pertaining to orders.
c. Send you additional information related to your product and/or service
d. Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
b. Identify the message as an advertisement in some reasonable way.
c. Include the physical address of our business or site headquarters.
d. Monitor third-party email marketing services for compliance, if one is used.
e. Honor opt-out/unsubscribe requests quickly.
f. Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can click unsubscribe at the bottom of each email. We will promptly remove you from ALL correspondence.
8. CHANGES TO THIS PRIVCY STATEMENT.
Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our website for 30 days. After 30 days the changes will become
9. CONTACT INFORMATION.
ATTN: Chief Legal and Regulatory Officer
840 Apollo St #100
El Segundo, CA 90245
*This Privacy Statement was last updated on September 18th, 2019.