Privacy Policy

Your Privacy is important to us. This Privacy Policy describes how HTG Molecular Diagnostics (“HTG” or “we”) collects and uses personal information collected from visitors to the www.htgmolecular.com website (the or our “Site”), and tells you about your privacy rights and how the law protects you.

Controller

HTG Molecular Diagnostics, Inc. is the controller and is responsible for your personal data (referred to as “HTG”, “we”, “us” or “our” in this privacy notice).

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Your Consent

By using the Site or providing personal information to the Site, you agree and consent to HTG’s collection, use, and disclosure of your personal information in accordance with this Privacy Policy. We may revise this Privacy Policy from time to time by posting revisions to this location, and ask that you periodically return to this webpage to view any changes or to refresh your memory.

Information Collected

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this does not directly or indirectly reveal your identity.

Our Site is not structured to attract children. We do not knowingly collect personal information from anyone under the age of 18, especially children under 13.

We do not collect any of the following special categories of personal data: data about your religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership.

As part of the services we provide, we may receive information about your health, and genetic and biometric data. We have taken measures to ensure that where we receive this category of data it is anonymized so it can no longer be a personally identifiable piece of information.

By “Contacting Us” (see below), you may at any time request access to a summary of your personal information held by us, and request corrections or updates to that information. We will make reasonable efforts to respond to such requests in accordance with applicable laws. Our response to such requests will be limited to information under our direct control.

You will not have to pay a fee to access your personal data (or to exercise any of your legal rights (see below). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Please note, if you fail to provide personal data where we need to collect personal data by law, or under terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you (for example to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How Your Information Is Collected

We use different methods to collect data from and about you including through:

Automated technologies or interactions

Our web server collects information from you during the course of your visit to the Site. This information includes the Internet Protocol (IP) address of your Internet Service Provider, the content you access, the platform operating system and web browser you use, and the date and time of your visit. We collect this information through the use of routinely available tracking technologies, such as “cookies.” A “cookie” is a message our web server asks your browser to store on your hard drive. Your browser and our Site exchange such message(s) each time you visit the Site. You can usually set your browser to reject cookies or to alert you before one is placed, if you prefer. Please be aware that if you do not configure your browser otherwise it will accept cookies provided by the Site.

Direct Interactions

We may also collect information from you through your voluntary submission. For instance, you may be required to register with HTG and provide basic contact information via this Site in order to access and use certain portions of this Site. The information that is collected via your voluntary submission is used only for internal purposes.

Third Parties

We may receive personal data about you from various third parties. You understand that the third parties utilized for services such as marketing, webcast hosting, payroll and payroll related services may change from time to time.

Use of Collected Information

We have explained below each lawful basis for using your personal data, and the purposes for which we use your personal data.

Performance of a contract

We need to use your personal information, such as Identity Data, Contact Data and Financial Data for the purposes of performing a contract you have entered into with us. For example, to process service payments; to set up or supply equipment and provide support services.

Necessary for our legitimate interests

We use your personal data for ongoing business purposes. For example, we may use your Identity, Contact, Usage and Technical Data to improve this Site, to store your interests and preferences in order to customize your visit to this Site, to communicate with you, to compile and analyze trends, and to carry out the transactions you request when you visit the Site.

Compliance with a legal obligation

We use your Identity, Contact and Marketing and Communications Data to comply with various legal obligations including ensuring that you do not receive marketing communications from us in circumstances where you have advised us that you do not wish to receive those communications.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us using the details set out in our Contact Us section above.

In addition, if you would like further information about the specific lawful basis we rely on when using your personal data please contact us using the details set out in the Contacting Us section below.

Marketing

We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. As part of our ongoing marketing activity, we may use your personal data in the following ways:

• Promotions:

We may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want, need or may be of interest to you. We do this in order to provide you with this most relevant products and services.

You will receive marketing communications from us if you have requested information from us, purchased products from us, or if you have provided us with your details in order to receive marketing promotions and in each case you have not opted out of receiving marketing communications from us.

• Third Party Marketing:

We will get your express opt-in consent before we share your personal data with any company outside the HTG for marketing purposes.

Opting Out: If you do not wish to receive certain communications from HTG you may opt out by “Contacting Us” (see below). Please include the message “REMOVE ME” in the subject line and ensure that the distribution list from which you wish to be removed is clearly indicated. We will comply with opt-out request to the extent required by applicable law or, if not required by applicable law, with commercially reasonable efforts under our circumstances.

Disclosure of Information

As part of fulfilling our contractual obligations we may have to share your personal data with external third parties. HTG occasionally hires other companies to provide services for us, which may require that they have access to some of the information collected. Such companies are required to use the information only to perform the services HTG hired them to provide, and to maintain the confidentiality of the information.

HTG does not provide, sell, or lease information about you to any third parties for their marketing use. HTG will release information about you if you direct us to do so, if we are required or permitted by law, to protect and defend the rights or property of HTG, or in the event of a change in control (e.g., merger or change of ownership) of all or part of HTG.

International Data Transfers

Your personal data is shared and stored at HTG headquarters in the USA which involves the transfer of your data outside of the European Economic Area (EEA).

Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

If you require any further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us using the details provided in the Contact Us section above.

Security of Collected Information

We take reasonable physical, electronic, and administrative safeguards for a company in our industry and of our size to help protect your personal information from unauthorized or inappropriate access. We restrict access to personal information to those individuals who need it in order to assist us in providing our services.

Data Retention

We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your personal data. Please see further information within Your Legal Rights section below.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your Legal Rights

Under EU data protection laws, you have the following rights in relation to your personal data:

• Request access to your personal data

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of personal data that we hold about you

This enables you to have any incomplete or inaccurate information we hold about you corrected. Please note, we may need to verify the accuracy of any new details you provide.

• Request erasure of your personal data

This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. This may also apply where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to delete your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing

This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your personal situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

• Right to withdraw consent

You may withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Request to transfer data

This enables you to request the transfer of your personal data to you or a third party. We will transfer the data in a structured, commonly used, machine readable format. This right applies only in respect of automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of the above rights, please contact us using the details provided in the Contacting Us section below.

Contacting Us

If you have questions or comments about our Privacy Policy, please send us a message by emailing to info@htgmolecular.com.

Our full contact details are:

Legal Entity:                  HTG Molecular Diagnostics Inc.

Address:                        3430 E, Global Loop, Tucson, AZ 85706, USA.

Telephone Number:        877-289-2615

Email address:                info@htgmolecular.com

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

A full list of the data protection authorities in the EU, and the relevant contact details can be found at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.