GDT Web Privacy Statement

Global Diagnostics Technologies LLC and its subsidiaries (collectively “GDT”, “We”, “Us” or “Our”), is a leading global life sciences company that is committed to protecting and respecting your (“Your” or “You”) privacy and personal information, meaning any information about You which is personally identifiable (“Personal Information”), that We may collect from or which You may submit to or through Diagnostic.ly, Platform.Diagnostic.ly, App.Diagnostic.ly or other GDT websites that directly link to this privacy statement (the “Website”).

This privacy statement (the “Privacy Statement”), together with Our Terms of Use, describes how We may use Your Personal Information and how that information may be used or disclosed by Us.

Please read the following carefully to understand Our views and practices regarding Your Personal Information and how We will treat it.

This Privacy Statement applies only to Personal Information collected on the Website. It does not apply to Personal Information collected on any third-party site that may link to or be accessible to the Website over which We have no influence or control. The use of other sites, or the submission of Personal Information to other third-party sites is at Your own risk and is subject to their privacy statements and policies.

Collecting Your Personal Information Directly from You

Generally, You can visit the Website without revealing who You are and without disclosing any of Your Personal Information. However, there may be times when We require Personal Information about You or when You wish to disclose such Personal Information to Us. Such Personal Information is obtained when submitted by You and is subject to the provisions set out in this Privacy Statement.

We may collect and process the following Personal Information about You:

• Information that You provide by filling in forms on the Website, such as Your personal details (e.g., Your name, date of birth, etc.) or contact details (e.g., telephone number, email address, postal address, etc.). This includes information provided at the time of registering to use the registration-only sections of the Website.
• With respect to the use of the Jobs section of this Website, Information You have provided as part of the job application and onboarding process (such as application materials, offer letter, etc.). Before using any of the services available on that section of the Website, You will be required to review and agree to specific terms of use.
• We may also ask You for Personal Information (such as when You report a problem with the Website).
• We may include forms (electronic or on paper) you fill out in conjunction with medical testing ordered by your employer or which you order voluntarily under an agreement with your employer
• If You contact us, in writing, by email or other electronic means, We may keep a record of that correspondence.
• Details of Your visits to the Website and information as You navigate through the Website together with details of the resources that You access. This information includes but is not limited to: usage details, IP addresses, location data and other communication data which will be used in accordance with this Privacy Statement.

Where required by law we may ask for Your explicit consent to collect information considered to be sensitive Personal Information (such as information about Your ethnicity or health information). You may withdraw Your consent at any time by contacting Us at the details below.

We obtain personally identifying information about you only if you voluntarily choose to provide such information via correspondence with GDT. Feedback forms used in GDT correspondence specifically request that you not include personal information such as user names, passwords, social security numbers, and private health information. Correspondence conducted via GDT feedback forms is stored on a third-party server and then downloaded by GDT personnel.

Various GDT webpages and programs give users the option to make electronic payment for services. Information from these bill payment links is not tracked or recorded but may be transmitted to independent third parties for payment processing.

We may be required by law to collect certain Personal information about You or as a consequence of any contractual relationship We have with You. Failure to provide this information may prevent or delay the fulfillment of these obligations.

Collecting Your Information from Other Sources

GDT will also collect the following categories of Personal Information from third parties, such as digital ad agencies, lists from acquired companies, events and conferences, and purchased lists.

• Name, address, email address, company name, title, preferences

We may enhance or merge Your Personal Information with data obtained from third parties for the same purposes for which We use Your Personal Information that You personally volunteer.

How We Will Use Your Personal Information

We may use Your Personal Information for the following purposes, which are in Our legitimate interests:

• We may analyze Your Personal Information to better understand Your needs and how We can improve Our websites, products and services. For instance, We may use Your information to verify that content from the Website is presented in the most effective manner for You and for Your device, or to allow You to participate in the registration-only features of the Website, when You choose to do so.
• We may use Your Personal Information to communicate to You about new services and products that may be of interest to you. When You register online for one of Our services, You may be given the option of receiving periodic informational/promotional mail or email from GDT. You choose whether or not to receive correspondence when You provide this information or by changing Your preferences within Your registration profile or by following the instructions provided in the email at any time. GDT may utilize email marketing software as a third-party service to manage certain email communications.
• We may use Your Personal Information to provide You with the services and products You request, to assist with Your questions about Our services, billing or payment methods, and to process or collect payments made in connection with Our services to You.
• We may use Your Personal Information to respond to subsequent requests You may make of Us.

We may use any of the categories of Your Personal Information to exercise Our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims, or violations of law or the contract.

If You do not want Us to use Your Personal Information in this way, please contact Us at the details below.

Worldwide Transfer of Your Personal Information

Your Personal Information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Information under European Union (EU) law. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements so that Your Personal Information is adequately protected. For more information on the appropriate safeguards in place, please contact Us at the details below.

Third Parties

We may share Your Personal Information with agents, contractors or partners of GDT in connection with services that these individuals or entities perform for, or with, GDT. These agents, contractors or partners are restricted from using this information in any way other than to provide services for GDT, or services for the collaboration in which they and GDT are engaged. We may, for example, provide Your information to agents, contractors or partners for hosting Our databases, for data processing services, such as Pipedrive, Calendly and other similar service providers, or so that they can mail You information that You requested. We will not give, sell, rent, loan or otherwise disclose any Personal Information to any third party, unless permitted or otherwise authorized to do so.

GDT reserves the right to share Personal Information in response to duly authorized information requests of any law enforcement agency, court, regulator, government authority, or other third party, where We believe such disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect Our rights or the rights of any third party.

We may also provide Personal Information to a third party in connection with the sale, assignment, or other transfer of the business of this Website to which the information relates, in which case We will require any such third party to agree to treat Personal Information in accordance with Our Terms of Use.

We also may share aggregate, non-personal information about Website usage with unaffiliated third parties. This aggregate information does not contain any personal identifiable information about our users.

Information Security and Storage

We reserve the right to take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or unauthorized use of this Website. We also reserve the right take any action to prevent the unauthorized use of Our intellectual property rights.

We may cooperate with any law enforcement authorities or court order requesting or directing Us to disclose the identity of or locate anyone for the prevention or detection of crime or the apprehension or prosecution of offenders. There may be other circumstances in which We may be required by law to disclose information about You or Your use of this Website. You waive and hold Us harmless from any claims resulting from such disclosures and from any actions taken as a consequence of investigations by either Us or law enforcement authorities.

We may investigate any complaints or reported breaches of this Privacy Statement and take any action that We deem appropriate (which may include, without limitation, removing any of Your information, issuing warnings, suspending, restricting, or terminating Your access to this Website). We also reserve the right at Our discretion to suspend, restrict, or terminate Your access to this Website at any time without notice if We have reasonable grounds to believe that You have breached this Privacy Statement or Our Terms of Use.

The Safety and Security of Your Personal Information Also Depends on You

If You choose or are given a user identification code, password or any other information as part of Our security procedures for one of the registration-only sections of the Website, You are responsible for maintaining the confidentiality of Your password and user name for the Website and You are responsible for all activities that are carried out under them.

We do not have the means to check the identities of people using the Website and We will not be liable where Your password or user name is used by someone else. You agree to notify Us immediately at the contact information provided below of any unauthorized use of Your password or user name of which You become aware. We have the right to disable any user identification code or password, whether chosen by You or allocated by us, at any time, if in Our opinion, You have failed to comply with any of the provisions of these terms or Our Terms of Use.

Please be aware that while We take appropriate steps to safeguard the security of Your Personal Information, the transmission of information over the Internet is not completely secure and therefore You do this at Your own risk. Once We receive Your Personal Information, we will implement strict security procedures with the objective of preventing unauthorized access.

Financial information and payment data, including credit card numbers, that You provide to Us via a GDT internet bill payment link is encrypted by using secure socket layer (SSL) encryption technology. This information may be accessed only by GDT agents and employees who maintain password and position-required access rights, and third-party vendors who support GDT’s billing operations.

We implement technical and organizational measures to maintain a level of security appropriate to the risk to the Personal Information We process. These measures are aimed at maintaining the on-going integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis.

We will retain Your Personal Information in accordance with Our record retention policy, as updated from time to time, and as long as We have a relationship with You. To request that Your Personal Information be deleted from Our databases, please see below for more information.

Cookies

GDT tracks visitors to our website by collecting data elements called cookies. Cookies collected from the GDT website are used to (1) enable certain functions and tools on this website, (2) assist in the navigation of the website, (3) track resources and data used on this site, (4) promote GDT’s products and services, and (5) remember computer settings. GDT also collects other forms of non-personal information, such as browsers used to access our website, search terms used to find the website, and traffic referrals and links to our website. Cookies are not permanently maintained within our tracking system. You may prevent your computer from accepting cookies by modifying the properties on your web browser; however, stopping your computer from accepting cookies may limit your web browser’s functionality on the GDT website.

GDT also uses the services of Google Analytics software to analyze traffic to the various GDT webpages. Data collected regarding site usage is compiled in aggregate to improve the performance of the site. If you do not wish your information to be included in this aggregated data through Google Analytics, you can download and install Google’s “Google Analytics Opt-out Browser Add-on” available here.

If you wish to prevent the use of cookies or for your information to be included in aggregated data through Google Analytics, You must modify the properties on your web browser for both as described above.

Internet Links

As a convenience to our site visitors, the GDT website may contain links to a number of sites that may provide useful information. Links contained on the GDT website that transfer you to a non-GDT site are not maintained by GDT and may contain different information and/or different privacy policies from those of our Company. You may review the privacy policies of these websites and/or receive specific information regarding that site’s privacy policies and procedures after leaving the GDT site. GDT is not responsible for the content or privacy practices of a non-GDT website. GDT does not control, or have any input into, whether our business partners or internet-linked sites, use or accept cookies on their sites.

Updates and Changes

We may update this Privacy Statement from time to time. When We do update it, for Your convenience, We will make the updated Privacy Statement available on this page. Changes and additions to the Privacy Statement are effective from the date on which they are posted. Please review the Privacy Statement from time to time to check whether We have made any changes to the way in which We use Your Personal Information.

Children’s Privacy

You should be aware that this Site is not intended for, or designed to attract, individuals under the age of 18.

Your Rights over Your Personal Information

You have certain rights regarding Your Personal Information, subject to local law. These include the following rights to:

• access Your Personal Information;
• rectify the information We hold about You;
• erase Your Personal Information;
• restrict Our use of Your Personal Information;
• object to Our use of Your Personal Information;
• receive Your Personal Information in a usable electronic format and transmit it to a third party (right to data portability); and
• lodge a complaint with Your local data protection authority if one exists in Your country.

We encourage You to contact Us to update or correct Your Personal Information if it changes or if the Personal Information We hold about You is inaccurate. Please note that We will likely require additional information from You in order to honor Your requests.

Please note that should You request that Your Personal Information be deleted, You may continue to receive materials for a short period while We are updating Our lists. Your records will then be permanently deleted from Our systems

How to Contact Us

Global Diagnostics Technologies LLC is based in the US and is the controller responsible for Personal Information that it collects and processes.

If You have any questions or concerns regarding the way in which Your personal information is used, please contact Us via mail at: Global Diagnostics Technologies LLC c/o David Shor, 6416 Wilton Dr, Fort Worth, TX 76133, marking Your letter for the attention of the Data Controller, Compliance Department. Our Data Protection Officer can be contacted at [email protected]. This Privacy Statement was last updated January 1, 2024.

HIPAA Information

GDT’s Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Notice of Privacy Practices applies to Global Diagnostics Technologies LLC  and all of its subsidiaries and business units (collectively referred to as “GDT” in this Notice), except to the extent that a subsidiary, division, or business unit of GDT may perform occupational screening, diagnostic tests, forensic tests, paternity/identity tests, clinical trials tests or other services that do not involve standard electronic transactions for which the Department of Health and Human Services (“HHS”) has adopted standards.

GDT’s Protection of Protected Health Information (PHI)

Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), GDT is required by law to maintain the privacy of health information that identifies you, called protected health information (PHI), and to provide you with notice of our legal duties and privacy practices regarding PHI. GDT is committed to the protection of your PHI and will make reasonable efforts to ensure the confidentiality of your PHI, as required by statute and regulation. We take this commitment seriously and will work with you to comply with your right to receive certain information under HIPAA.

GDT’s Use and Disclosure of PHI

As permitted under HIPAA, the following categories explain the types of uses and disclosures of PHI that GDT may make. Some of the uses and disclosures described may be limited or restricted by state laws or other legal requirements, for example, the Clinical Laboratory Improvement Amendments of 1988 (CLIA). Please contact our Privacy Officer, using the contact information provided at the end of this notice, for specific information regarding your state.

• For testing – GDT may use or disclose PHI for testing purposes, including disclosure to physicians, nurses, medical students, pharmacies, and other health care professionals who provide you with testing services and/or are involved in the coordination of your employee and contractor testing, such as providing your physician with your laboratory test results.
• For payment – GDT may use or disclose PHI to bill and collect payment for laboratory services we provide. For example, GDT may provide PHI to your health plan to receive payment for the health care services provided to you.
• Appointment reminders and health-related benefits and services – GDT may use and disclose PHI to contact you as a reminder that you have an appointment with us and may use and disclose PHI to tell you about health-related benefits and services that may be of interest to you. For example, GDT may contact you about new testing services available at GDT.
• Individuals involved in your test or payment for your test – In accordance with EEOC guidelines, GDT may disclose PHI to a person who is involved in your testing or helps pay for your testing, such as your employer. We also may notify your family about your location or general condition or disclose such information to an entity assisting in a disaster relief effort. As allowed by federal and state law, we may disclose the PHI of minors to their parents or legal guardians.
• Business associates – GDT may disclose PHI to its business associates to perform certain business functions or provide certain business services to GDT. For example, we may use another company to perform billing services on our behalf. All of our business associates are required to maintain the privacy and confidentiality of your PHI. In addition, at the request of your health care providers or health plan, GDT may disclose PHI to their business associates for purposes of performing certain business functions or health care services on their behalf. For example, we may disclose PHI to a business associate of Medicare for purposes of medical necessity review and audit.
• Disclosure for judicial and administrative proceedings – Under certain circumstances, GDT may disclose your PHI in the course of a judicial or administrative proceeding, including in response to a court or administrative order, subpoena, discovery request, or other lawful process.
• Law enforcement – GDT may disclose PHI for law enforcement purposes, including reporting of certain types of wounds or physical injuries or in response to a court order, warrant, subpoena or summons, or similar process authorized by law. We may also disclose PHI when the information is needed: 1) for identification or location of a suspect, fugitive, material witness or missing person, 2) about a victim of a crime, 3) about an individual who has died, 4) in relation to criminal conduct on GDT premises, or 5) in emergency circumstances to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime.
• As required by law – GDT must disclose your PHI if required to do so by federal, state, or local law.
• Public Health – GDT may disclose PHI for public health activities. These activities generally include: 1) disclosures to a public health authority to report, prevent or control disease, injury, or disability; 2) disclosures to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; and 3) disclosures to an employer about an employee to conduct medical surveillance in certain limited circumstances concerning work-place illness or injury.
• Health oversight activities – GDT may disclose PHI to a health care oversight agency for activities authorized by law such as audits, civil, administrative, or criminal investigations and proceedings/actions, inspections, licensure/disciplinary actions, or other activities necessary for appropriate oversight of the health care system, government benefit programs, and compliance with regulatory requirements and civil rights laws.
• Personal Representative – GDT may disclose PHI to your personal representative, as established under applicable law, or to an administrator, executor, or other authorized individual associated with your estate.
• Correctional institution – GDT may disclose the PHI of an inmate or other individual when requested by a correctional institution or law enforcement official for health, safety, and security purposes.
• Serious threat to health or safety – GDT may disclose PHI if necessary to prevent or lessen a serious and/or imminent threat to health or safety to a person or the public or for law enforcement authorities to identify or apprehend an individual.
• Research – GDT may use and disclose PHI for research purposes. Limited data or records may be viewed by researchers to identify patients who may qualify for their research project or for other similar purposes, so long as the researchers do not remove or copy any of the PHI. Before we use or disclose PHI for any other research activity, one of the following will happen: 1) a special committee will determine that the research activity poses minimal risk to privacy and that there is an adequate plan to safeguard PHI; 2) if the PHI relates to deceased individuals, the researchers give us assurances that the PHI is necessary for the research and will be used only as part of the research; or 3) the researcher will be provided only with information that does not identify you directly.
• Government functions – In certain situations, GDT may disclose the PHI of military personnel and veterans, including Armed Forces personnel, as required by military command authorities. Additionally, we may disclose PHI to authorized officials for national security purposes, such as protecting the President of the United States, conducting intelligence, counter-intelligence, other national security activities, and when requested by foreign military authorities. Disclosures will be made only in compliance with U.S. Law.
• Workers’ compensation – As authorized by applicable laws, GDT may use or disclose PHI to comply with workers’ compensation or other similar programs established to provide work-related injury or illness benefits.
• De-identified Information and Limited Data Sets: GDT may use and disclose health information that has been “de-identified” by removing certain identifiers making it unlikely that you could be identified. GDT also may disclose limited health information, contained in a “limited data set”. The limited data set does not contain any information that can directly identify you. For example, a limited data set may include your city, county and zip code, but not your name or street address.

Information Breach Notification

GDT is required to provide patient notification if it discovers a breach of unsecured PHI unless there is a demonstration, based on a risk assessment, that there is a low probability that the PHI has been compromised. You will be notified without unreasonable delay and no later than 60 days after discovery of the breach. Such notification will include information about what happened and what can be done to mitigate any harm.

Patient Rights Regarding PHI

Subject to certain exceptions, HIPAA establishes the following patient rights with respect to PHI:

• Right to Receive a Copy of the GDT Notice of Privacy Practices – You have a right to receive a copy of the GDT Notice of Privacy Practices at any time by contacting us at [email protected] or by sending a written request to: HIPAA Privacy Officer, Global Diagnostics Technologies LLC, 6416 Wilton Dr, Fort Worth, TX 76133. This Notice will also be posted on the Global Diagnostics Technologies internet site at Diagnostic.ly, Platform.Diagnostic.ly, App.Diagnostic.ly
• Right to Request Limits on Uses and Disclosures of your PHI – You have the right to request that we limit: 1) how we use and disclose your PHI for treatment, payment, and health care operations activities; or 2) our disclosure of PHI to individuals involved in your care or payment for your care. GDT will consider your request, but is not required to agree to it unless the requested restriction involves a disclosure that is not required by law to a health plan for payment or health care operations purposes and not for treatment, and you have paid for the service in full out of pocket. If we agree to a restriction on other types of disclosures, we will state the agreed restrictions in writing and will abide by them, except in emergency situations when the disclosure is for purposes of treatment.
• Right to Request Confidential Communications – You have the right to request that GDT communicate with you about your PHI at an alternative address or by an alternative means. GDT will accommodate reasonable requests.
• Right to See and Receive Copies of Your PHI – You and your personal representative have the right to access PHI consisting of your laboratory test results or reports ordered by your physician. Within 30 days after our receipt of your request, you will receive a copy of the completed laboratory report from GDT unless an exception applies. Exceptions include a determination by a licensed health care professional that the access requested is reasonably likely to endanger the life or safety of you or another person, and our inability to provide access to the PHI within 30 days, in which case we may extend the response time for an additional 30 days if we provide you with a written statement of the reasons for the delay and the date by which access will be provided. You have the right to access and receive your PHI in an electronic format if it is readily producible in such a format. You also have the right to direct GDT to transmit a copy to another person you designate, provided such request is in writing, signed by you, and clearly identifies the designated person and where to send the copy of your PHI. To request a copy of your PHI, contact the Privacy Officer at [email protected].
• Right to Receive an Accounting of Disclosures – You have a right to receive a list of certain instances in which GDT disclosed your PHI. This list will not include certain disclosures of PHI, such as (but not limited to) those made based on your written authorization or those made prior to the date on which GDT was required to comply. If you request an accounting of disclosures of PHI that were made for purposes other than treatment, payment, or health care operations, the list will include disclosures made in the past six years, unless you request a shorter period of disclosures. If you request an accounting of disclosures of PHI that were made for purposes of treatment, payment, or health care operations, the list will include only those disclosures made in the past three years for which an accounting is required by law, unless you request a shorter period of disclosures.
• Right to Correct or Update your PHI – If you believe that your PHI contains a mistake, you may request, in writing, that GDT correct the information. If your request is denied, we will provide an explanation of the reasoning for our denial.

How to Exercise Your Rights

To exercise any of your rights described in this notice, you must send a written request to: HIPAA Privacy Officer, Global Diagnostics Technologies LLC, 6416 Wilton Dr, Fort Worth, TX 76133. Except, patients may update insurance and/or billing information through our website or by contacting the Patient Billing Department using the phone number indicated on the billing invoice.

How to Contact Us or File a Complaint

If you have questions or comments regarding the GDT Notice of Privacy Practices, or have a complaint about our use or disclosure of your PHI or our privacy practices, please contact: [email protected], or send a written request to: HIPAA Privacy Officer, Global Diagnostics Technologies LLC c/o David Shor, 6416 Wilton Dr, Fort Worth, TX 76133. You also may file a complaint with the Secretary of the U.S. Department of Health and Human Services. GDT will not take retaliatory action against you for filing a complaint about our privacy practices.

Changes to the GDT Notice of Privacy Practices

GDT reserves the right to make changes to this notice and to our privacy policies from time to time. Changes adopted will apply to any PHI we maintain about you. GDT is required to abide by the terms of our notice currently in effect. When changes are made, we will promptly update this notice and post the information on the GDT website at www.diagnostic.ly. Please review this site periodically to ensure that you are aware of any such updates.