Privacy Policy

Good Start Genetics, Inc. (“Good Start Genetics,” “we,” or “us”) is committed to protecting the privacy of our customer’s personally identifiable information (“Personal Information”) and protected health information (“PHI”). This Privacy Policy, together with the Notice of Privacy Practices located at www.goodstartgenetics.com/notice-of-privacy-practices/ describes how we collect, use, share, transfer and disclose personal information and PHI. This Policy applies to the Good Start Genetics, Inc. website at www.goodstartgenetics.com and affiliated sites and web pages including our Cost Estimator, Patient Portal and online ScreenSelect services (together the “Website” or the “Site”).  The Site is owned and operated by Good Start Genetics, Inc. located in Cambridge, Massachusetts. USA.

Any Personal Information collected by the Site shall be used only in a manner consistent with this Privacy Policy. By accessing the Site, logging in, requesting a cost estimate, requesting information by email, accessing test results, paying your bill, signing consent forms, checking the status of your orders, participating in a survey, posting information to a public forum, scheduling an appointment with a genetic counselor, or applying for a job (together, the “Services”), you expressly agree to the use of your information for the purposes described in this policy. If you do not agree with this Privacy Policy or any changes to it, you should not use or access our Website or Services.

Changes to Our Privacy Policy
If we decide to change our Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date. Please check back regularly to review any changes to this Privacy Policy.  This policy was last modified on: March 25, 2016.

Personal Information
Personal Information is information about you that is personally identifying, such as your name, email address, or telephone number, and that is not otherwise publicly available. The definition of Personal Information depends on your physical location and may include other types of information such as your IP address. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

Protected Health Information (PHI) and Sensitive Data
PHI is information about you, including demographic information and genetic information, that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services.   Some of this information is also deemed to sensitive information or sensitive personal data (“Sensitive Data”).

Good Start Genetics, Inc. is required by state law and by the Health Insurance Portability and Accountability Act (HIPAA) to protect the privacy of your health information. Staff members, employees, and any volunteers of Good Start Genetics, Inc. must follow legal regulations with respect to:

  • Use of PHI
  • Disclosure of PHI
  • Your Privacy Rights
  • Good Start Genetics, Inc.’s Privacy Duties
  • Your request for Further Information or Complaint

You can view our HIPAA Notice of Privacy Practices, which describes how we may use and disclose your PHI to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law.

100% Opt-In
Providing Personal Information or PHI to the Site to access or use any of the Services is entirely voluntary and is by opt-in only. You can opt-in by using or accessing any of the Services.  If you do not want to provide the requested information you should not opt in. If you do not opt-in you will not have access to any of the Services on the Site and we will have no way of contacting you to respond to your inquiries or requests for information. By opting in you are providing your express consent to the collection, use, retention, processing, transfer, and disclosure, including cross-border transfer and disclosure, of your Personal Information and PHI as explained in this Privacy Policy.

What Personal Information Do We Collect?

If you email us with a question or a request for information, we collect your first name and email address in order to respond to you.  We may also use your email address to send you promotional newsletters and emails regarding meeting, events, and new products or services.   You can unsubscribe from promotional emails at any time by clicking “unsubscribe” at the bottom of our emails.

Cost Estimator
When you use the Cost Estimator to calculate an estimate of your out of pocket expenses, we collect your first and last name, date of birth and policy information such as group number and participant ID.

Patient Portal
When you register on the Site and sign up for a Patient Portal, we collect your first and last name, date of birth and email address.  This information is combined with other Personal Information and PHI that you provide to the Site in order to give you access to your test results, permit you to sign any outstanding consent forms, check the status of your orders, pay your bills, and schedule appointments with a Genetic Counselor through your Patient Portal.

ScreenSelect Service:  Collection of PHI and/or Sensitive Data
When you research your suggested carrier screening considerations through our ScreenSelect Service, we collect the following information, which may be deemed to be PHI and/or Sensitive Data for you and your partner:  name, gender, ethnic background, family medical history of unexplained intellectual disability, unexplained autism, premature ovarian failure, and primary ovarian insufficiency. We collect this information to generate your carrier screening suggestions (the “Test Considerations”).

You are not required to provide this information, and, if you do not want to do so, you may simply not use this Service. By providing us with Sensitive Data, however, you consent to us collecting, processing, using, retaining, and transferring your Sensitive Data for the purposes of providing your Test Considerations.

Scheduling Appointments with Genetic Counselors
If you schedule an appointment with a genetic counselor we collect your name, date of birth, email address and phone number to enable us to contact you and schedule the appointment.  We also ask for your referring doctor’s name and ask if you or your partner have had genetic carrier screening to assist the genetic counselor in preparing for your appointment.

Surveys
We may ask you to complete voluntary surveys for research purposes.  Each survey may be different and the personal information or PHI we collect will depend on the nature of the survey.  Information collected from surveys will be transferred to third parties and will be processed anonymously.

Job Applications
If you apply for a job at Good Start Genetics through the Site, we collect a copy of your resume, a cover letter, and your first name, last name, email address and phone number (optional) to contact you about a potential job opening at Good Start Genetics. We will retain this information until the job is filled.

Aggregate Information
Just like many commercial organizations, we may monitor the use of the Services by collecting aggregate information through the use of cookies (see below). Typically, we collect information about the number of visitors to the Site, to each web page and the originating domain name of the visitor’s Internet Service Provider. This information is used to understand the visitor’s use of the Service and may be shared with our affiliates and with other third parties. We have no means reasonably available to us to ascertain the identity of individual users from aggregated information.

Payment Information
When you request a Service that requires a fee, we collect payment information including your name and credit card number and other information necessary to process your transaction.   We use this information to process your transaction, to contact you about your transaction, and to resolve billing or other issues relating to your purchases with us.

In all instances, we will keep your data only for as long as is reasonably necessary for the purposes described in this Policy and in accordance with any applicable legal or ethical reporting or documentation retention requirements.

Do We Use Cookies?
When you visit the Site or use the Services, we use session “cookies” — a piece of information stored on your computer — to allow us to uniquely identify your browser while you are browsing or interacting with the Site.  Session cookies also help us confirm your identity and are required in order to log into your account. Good Start Genetics uses persistent cookies to identify you as a Good Start Genetics customer and make it easier for you to log into your account. Users who disable their web browsers’ ability to accept cookies will be able to browse our Site, but will not be able to access or take advantage of the Services.

Our partners use session ID cookies to trace user movement on the Site and to collect usage data for the Services. The use of cookies by our partners is not covered by our Privacy Policy. We do not have access or control over these cookies.

How Do We Protect Your Information?
We will take reasonable precautions to protect Personal Information and PHI from loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.

For example:

a. Services are encrypted using SSL.
b. Information collection, storage, and processing practices are periodically reviewed, including physical security measures, to guard against unauthorized access to personal information and PHI.
c. Access to personal information and PHI is restricted to employees, contractors, and agents who are subject to confidentiality under business associate agreements and legal obligations. Failure to meet obligations may result in termination.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

We will retain Personal Information we process for as long as needed to provide the Services. We will retain and use this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Choice and Consent
By accessing the Site or Services or by sending us email you expressly consent to the collection, use, retention, transfer and disclosure, including international transfer and disclosure, of your information as described in this Privacy Policy. Each time you access the Site or any of the Services, you are giving your express consent to the collection, use, retention, transfer and disclosure, including international transfer and disclosure, of your information as described in this Privacy Policy.

If you wish to withdraw your consent for any uses that are incompatible with the uses you have consented to, you may do so at any time by sending an email to solutions@gsgenetics.com. If you withdraw your consent you will no longer be able to use or access our Services and we will not have any means by which to respond to your questions or comments that you email to the Site.

Do We Disclose Personal Information, PHI or Sensitive Data to Third Parties?
We may use and disclose Personal Information for research purposes, if the research has been approved by an institutional review board, in accordance with established protocols to ensure the privacy of your health information.
We disclose Personal Information, PHI and Sensitive Data to third parties acting as agents in providing products and services.

We disclose your PHI to third parties at your request.  We may disclose PHI to persons who are legally permitted to receive PHI to enable us to provide the Services such as other labs, your physician, and your insurance provider.

Non-personally identifiable information may be provided to Google Analytics or other third parties for statistical analysis.

We may release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect our or other’s rights, property, or safety. Because our servers, which store your information, are located in the U.S.A., your information may be available to U.S. government entities or agencies under a lawful court order or other law in the U.S.

In the event we are acquired by or merged with another entity, your Personal Information, PHI and Sensitive Data will be disclosed to the other entity which will be obligated to follow this Privacy Policy.

By accessing our Site or the Services or by sending us email, you provide your express consent to our transfer and disclosure of your Personal Information, PHI and Sensitive Data for the purposes described in this Privacy Policy and in the HIPAA Privacy Notice.

Third Party Sites and Links
Our Site may contain links to other websites that are independent, are not owned or operated by us, are not covered by this Privacy Policy and which may incorporate Third Party Information. These third party sites have separate and independent privacy policies. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We therefore have no responsibility or liability for the content and activities of other websites, even if they are linked to our Site.

Social Media Features
Our Site includes features from social media websites such as the Facebook Like button and features on LinkedIn and Twitter that run on our Site. 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. Social media features are either hosted by a third party or hosted directly on our Site. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

International or Cross-Border Transfer of Your Information and Your Express Consent
Given that the Internet operates in a global environment and that, if you operate outside of the United States, transfer of your data is necessary for you to use our Services or email us for information.  Accordingly, using the Internet to provide Personal Information and Sensitive Data necessarily involves the transmission of data on an international, or cross-border, basis. By using or accessing the Services and/or by emailing us, you acknowledge and expressly consent to our processing and disclosure of your Personal Information, Sensitive Data or other information in this way.

For users who are located outside the United States, Personal Information, Sensitive Data and other information will be transferred outside of the user’s country to the United States where our servers are located and where it will be processed and stored.  The U.S. does not provide an adequate level of protection according to EU data protection regulations. We will take all steps reasonably necessary to ensure that Personal Information is treated securely and in accordance with this Privacy Policy in respect of such transfer, but will not otherwise take steps to ensure compliance with applicable laws in each customer’s country of residence. By using or accessing any of the Services and/or by emailing us, you expressly consent to such transfer and disclosure.   If you reside in a country or jurisdiction that does not permit the collection or processing of Sensitive Data, you must not use or access any of the Services.

Your California Privacy Rights; California Do Not Track Disclosures

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us or our subsidiaries to a third party for the third party’s direct marketing purposes.  Since we do not make such disclosures, we are exempt from these reporting requirements.   In addition, we currently do not honor Do Not Track signals.

Children
Our site is directed to individuals who are the age of majority or older in their jurisdiction.  We do not knowingly collect information from children.  If you believe your child has provided information to the Site please contact our Privacy Officer.

Notice of Privacy Practices for Protected Health Information

This following is an abridged Notice of Privacy Practices for PHI.   For the full HIPAA Notice of Privacy Practices, please see: www.goodstartgenetics.com/notice-of-privacy-practices/.

You have the following rights regarding your privacy and medical information:

a. Right to inspect and obtain a copy.
You have the right to request, in writing, a copy of your medical information that may be used to make decisions about your care. You may request medical and billing records, but the request does not include psychotherapy notes.
b. Right to amend your medical information.
If you believe that the medical information Good Start Genetics, Inc. has is incorrect or incomplete, you may ask to amend the information. You have the right to request an amendment as long as we maintain the information. In the future, your request will become a legal part of your medical record and will be sent out in addition to your medical record whenever a request for a copy is received. No original documentation may be destroyed or changed.
c. Right to request an accounting of disclosures.
You have the right to request an “accounting of disclosures.” An accounting of disclosures is a list of disclosures Good Start Genetics, Inc. made of your medical information without getting authorization, or which were not made for purposes of treatment, payment, or health care operations. This request must be submitted in writing.
d. Right to request restrictions
You have the right to request restrictions or limitations on medical information we use or disclose about you for treatment, payment, or health care operations purposes. We are not required to agree to these restrictions, but if we do, we will abide by our agreement (except in an emergency). Any agreement we may make to a request for additional restrictions must be in writing signed by a person authorized to make such an agreement on our behalf.
e. Right to request confidential communication.
You have the right to request that Good Start Genetics, Inc. communicate with you about medical matters using a certain method of communication or at a certain location. For instance, you may ask Good Start Genetics, Inc. to contact you only at work or by mail. You must make your request in writing to the Privacy Officer. We will not ask the reason for your request.
f. Right to be notified of a security breach that compromised your PHI.
Good Start Genetics, Inc. is required to notify you in the event that there is a breach of your PHI by unauthorized persons or entities unless there is a demonstration, based on internal risk assessment, that there is a low probability that your PHI has been compromised. We must notify you without unreasonable delay when a breach has occurred and no later than 60 days after discovery of the breach. Notification will include information about what happened and what has been and will be done to mitigate risk.
g. Right to a copy of the Privacy Policy.

You have a right to obtain a copy of the Privacy Policy at any time. You may obtain a copy of this notice by accessing Good Start Genetics, Inc.’s website.

Access to Your Information
You may access, review, change, update or delete your Personal Information, Sensitive Data or PHI by emailing us at solutions@gsgenetics.com.  You may also withdraw your consent by calling Client Solutions to do so, to the extent permitted by applicable law. If you wish to unsubscribe from any of our emails, please click on the “unsubscribe” feature on the email you receive from us.

Contact Us About Complaints, Questions or Notices relating to this Privacy Policy
Good Start Genetics commits to resolving complaints about your privacy and our collection or use of your Personal Information or PHI.   If you believe your privacy rights have been violated or you disagree with any action Good Start Genetics, Inc. has taken with regard to your personal or protected health information, you may file a complaint with Good Start Genetics, Inc. or with the Secretary of the Department of Health and Human Services, J.F.K. Federal Building, Room 1875, Boston, MA 02203 or email OCRComplaint@hhs.gov.

To file a complaint with Good Start Genetics, Inc.:
Attn: Privacy Officer
237 Putnam Avenue
Cambridge, MA, 02139

By email: jyoulton@gsgenetics.com
By Phone:  Privacy Officer at (857) 829-3668

 

Terms of Service
Please also visit our Terms of Service section establishing the use, disclaimers, and limitations of liability governing the use of our website https://www.goodstartgenetics.com/terms-conditions/