Privacy Policy
This Privacy Policy explains how Pearl Diagnostics, Inc. (Pearl Diagnostics) handles Personally Identifiable Information (Personal Information) that we collect online, through our websites and through our offline interactions with you (collectively, the “Pearl Diagnostics Services”). Individual use of Pearl Diagnostics Services which link to this Privacy Policy are subject to this Privacy Policy and the Terms of Use.
Please read this Privacy Policy before using the Pearl Diagnostics Services or submitting Personal Information to us. By using the Pearl Diagnostics Services, you accept and expressly agree to our practices surrounding the collection, use, and sharing of Personal Information provided by you in the manner described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, you cannot, and we do not authorize you to, access, browse, or use the Pearl Diagnostics Services.
On occasion, Pearl Diagnostics may offer special programs, activities, events or promotions (“Programs”) that have unique or additional specific terms, privacy notices and/or consent forms that explain how any information you provide will be processed in connection with the Programs. You should review the applicable terms before interacting or participating in the Programs.
Privacy Statement
Pearl Diagnostics, Inc. has created this Privacy Policy to demonstrate its firm commitment to privacy and data protection. Ensuring privacy, responsible usage of data and obligation to effective data privacy laws and regulations is very important to us. Technical and organizational security measures are implemented to protect the personal data from accidental or deliberate manipulation, loss or destruction and from access by unauthorized persons. Our security measures are continuously improved in accordance with the technological progress in the field.
We gather Personal Information for the purpose of contract fulfillment, billing, enforcing contractual claims, customer service and advertisement. To this end, the data is gathered, saved, processed and used. Pearl Diagnostics also collects personally identifiable information, including anonymized health information, about EU individuals who use Pearl Diagnostics products, for medical device reporting, warranty and product support purposes.
For purposes of this Privacy Policy, “Personal Information” is any information by which you can be individually identified directly or in conjunction with other publicly-available information, including, but not limited to individual name, address, e-mail address, telephone number, and any financial information you may provide for purposes of completing a transaction with Pearl Diagnostics.
We do not share individual Personal Information with anyone. The Personal Information we gather is strictly for our use to communicate with our customers. Moreover, only employees who need the Personal Information to perform a specific job are granted access to personally identifiable information.
U.S.-European Union and Swiss Privacy Shield Programs
Pearl Diagnostics complies with the U.S.-EU Privacy Shield and the U.S.-Swiss Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland. Pearl Diagnostics has certified that it adheres to the Privacy Shield Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.
How does Pearl Diagnostics collect Personal Information? In the past twelve (12) months, Pearl Diagnostics has collected Personal Information in a few different ways:
- Information individuals voluntarily submit or choose to provide
- Information individuals give us permission to collect or another source
- From Health Care Professionals
- Through our websites and webforms
- From contract research organizations and clinical trial investigators
- From individuals participation in Pearl Diagnostics programs or clinical trials
- From third party service providers and business partners
- From industry and patient groups and associations
- Automatically from devices individuals use to connect to Pearl Diagnostics Services (See “Cookies and Other Tools” below)
- From public sources including, but not limited to, social media and other websites that enable social sharing
- Information from government agencies, public or third-party information sources
We may also combine information we get from a third-party with information we already have, and we may combine information that we have collected offline with information we collect online.
If you choose to submit any Personal Information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Policy.
Information Pearl Diagnostics Collects
Pearl Diagnostics has collected the following categories of Personal Information in the past twelve (12) months:
- Contact information and preferences (such as name, email address, mailing address, phone number, and emergency contact information)
- Biographical and demographic information (such as date of birth, age, gender, ethnicity, marital status, and sexual orientation)
- We may collect certain health and medical information in connection with managing clinical trials, conducting research, providing patient support programs, distributing and marketing our products, managing compassionate use and expanded access programs and tracking adverse event reports
- Payment-related information we need to complete a transaction (such as credit card number and financial account information)
- Username and password that you may select in connection with establishing an account on our websites
- individual photograph, social media handle or digital or electronic signature
- Publicly available information
- Internet activity, such as individual Internet Protocol (“IP”) address, browsing history, individual search history and information on individual interaction with the Pearl Diagnostics Services and our advertisements
- Device information
- Geolocation data, e.g., individual physical location, mobile phone location data, or movements (See “Cookies and Other Tools” below)
- Inferences drawn from other Personal Information listed above, to create a profile reflecting individual preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes
If you are accessing Pearl Diagnostics websites on individual mobile device, you may also choose to provide us with location data. To protect individual privacy, you should not provide Pearl Diagnostics with any information that is not specifically requested.
Notice
At the time that Pearl Diagnostics collects Personal Information from individuals for any of the purposes identified above, we will inform individuals of the purpose for which the Personal Information is being collected and used, and how to contact Pearl Diagnostics with any questions or complaints, or to update individual Personal Information. Pearl Diagnostics will not disclose Personal Information to third parties except in accordance with this Policy and as disclosed at the time of the collection of the Information. In the past twelve (12) months, Pearl Diagnostics has disclosed the following categories of Personal Information to:
- Provide our products and services to individuals and make them better
- Develop new products and services
- Fulfill individual requests
- Provide customer service
- Send individuals administrative communications regarding Pearl Diagnostics’s products or Services
- Notify individuals about special promotions or offers that may be of interest
- Invite individuals to participate in surveys about our products or services
- Better understand the interests of our customers and visitors who use Pearl Diagnostics Services
- Maintain Pearl Diagnostics’s online services such as websites
- Monitor, detect and prevent fraud, improper activity and ensure Pearl Diagnostics’s policy compliance
- Conduct research including secondary and follow-on research
- Process payments
- Evaluate how individuals and other users interact with our online services
- Protect Pearl Diagnostics and our users
- Secure our online services including our network, and websites
- Conduct audits related to our current interactions with you
- Debug the site and service to identify and repair errors that impair existing intended functionality
- Defend ourselves in litigation and investigations and to prosecute litigations
- Comply with our legal and regulatory obligations
- Pearl Diagnostics may also use information collected from individuals or about individuals to offer customized content, including to:
- Recognize new or past visitors to our websites
- Remember individuals personal preferences
- Show individuals more relevant and meaningful advertisements based on individual interests
Pearl Diagnostics may also use individual Personal Information for other purposes disclosed to you from time to time.
Pearl Diagnostics will not disclose Personal Information to a third party or use it for any purpose other than that for which it was originally collected or subsequently authorized by individuals, except as required by law, court order, or subpoena.
Security
Pearl Diagnostics will take precautions to keep Personal Information secure. All personally identifiable information is subject to restricted access to prevent unauthorized access, modification or misuse.
Data Integrity
Pearl Diagnostics will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To the extent necessary for those purposes, Pearl Diagnostics will take reasonable steps to ensure that Personal Information is relevant for its intended use, accurate, complete and current.
Access
Pearl Diagnostics will provide individuals with reasonable access to Personal Information collected or recorded by Pearl Diagnostics, and will undertake reasonable steps to affect any correction or amendment of Personal Information that individuals demonstrate to be incorrect or incomplete.
Cookies and Other Tools
Pearl Diagnostics and its Service Providers collect information about individuals by using cookies, tracking pixels, web beacons and other technologies (collectively, “Tools”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. This information can make individual use of our Pearl Diagnostics Services easier and more meaningful by allowing Pearl Diagnostics and our Service Providers to provide better service, customize sites based on consumer preferences, compile statistics, provide individuals with more relevant advertisements based on individual interests, analyze trends and otherwise administer and improve our Pearl Diagnostics Services. If we have collected individual Personal Information, we may associate this personal data with information gathered through the Tools.
Transfer to Third Parties
Before Pearl Diagnostics transfers Personal Information to a third party that is acting as an agent, it will ascertain that the third party safeguards Personal Information consistent with this policy, has itself made a Privacy Shield certification, or is subject to the EU Data Protection Directive. Where Pearl Diagnostics has knowledge that an agent is using or disclosing Personal Information contrary to this policy, Pearl Diagnostics will take reasonable steps to prevent or stop the use or disclosure.
Enforcement
Pearl Diagnostics will promptly seek to remedy any instances of noncompliance brought to its attention.
Dispute Resolution
If individuals have any queries in relation to the processing of personal data, they can contact info@pearldx.com.
Pearl Diagnostics does not receive diagnostic data with Personal Information. If identifiable patient information is received Pearl Diagnostics first alerts the sending institution that they have provided patient information and requests that it be anonymized. Otherwise Pearl Diagnostics will immediately de-identify the data by removing Personal Information that is not required IVD product and technical support purposes. We only use information which helps Pearl Diagnostics understand how the assay and/or device is working.
