Last Updated: November 15, 2023
Certain capitalized terms have the meaning as defined in our Terms of Service, incorporated herein by reference. If you have any questions about Broad’s privacy practices, please email:
1. Personal Data We Collect
We collect and use Personal Data through your use of the Services in the following ways:
1.a User Account Information/Personally Identifiable Information
When you register with us through the Services and during your use of the Services, we will ask you for Personal Data such as: your name, company or organization name, title, e-mail address.
1.b Information You Provide
When you interact with the Services, you may supply certain Personal Data, such as when you submit a request or post on the Community Forum. The information will vary depending on your interactions, but may include your name and email address and other information you include in the body of your request, post, comment, or other interaction.
When you Connect Content to the Services, such as uploading data for analysis, sharing with specified peers using the Services, developing software tools, or other scientific or research purposes.
1.c. Automatic Data Collection: Cookies and Similar Technologies
When you use the Services, we automatically collect usage data such as the IP address of the device or internet service you use to connect to the Internet, browser type and version, operating system and platform, and referring URLs, which may, in some instances, constitute Personal Data (“Usage Data”).
Do Not Track (“DNT”) is a privacy preference that Users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. We do not currently use technology that recognizes “do not track” signals from your Web browser.
2. Protected Health Information
With respect to Terra, Broad is not a Covered Entity as that term is defined under HIPAA. You may not use Terra to Connect Content that includes PHI. You will Deidentify data prior to Connecting it to Terra.
3. How Your Personal Data May be Used
We use Personal Data as described below:
We may use your Personal Data to provide and improve Terra and our other products and services, to ensure contact information is up to date and accurate, to improve our customer service, to reduce risk and prevent fraud, to provide you with a personalized experience on our Services and to communicate with you regarding new service features and related products and services provided by our Collaborators or other partners, events, and other information and notices we believe you may find interesting or useful. We will not sell or provide your information to third parties other than the Collaborators for their own direct marketing purposes.
We use Usage Data collected to provide, maintain, secure, and improve our Services, and to understand your interests when visiting our Services. We may generate statistical information regarding our User-base and use it to analyze our Services or business. Usage Data, such as IP address, may be shared with third-party tools leveraged by Terra in order to enable us to understand how you are using Terra and to improve your user experience by providing onboarding prompts to help you use Terra effectively.
4. With Whom May Broad Share Your Personal Data?
We share Personal Data with the following categories of recipients:
We may rely on various third-party service providers and contractors to provide services that support the Services and our operations, including, without limitation, maintenance of our databases, distribution of emails and newsletters on our behalf, data analysis, payment processing and other services of an administrative nature. Such third parties may have access to your Personal Data for the purpose of performing the service for which they have been engaged.
Compliance with Laws and Law Enforcement
Broad cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and other User information when we, in our sole discretion, have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may (either intentionally or unintentionally) be causing injury to or interference with our rights or property, Users of our Services, or anyone else who could be harmed by such activities. We may also disclose User information when we believe, in our sole discretion, that such disclosure is required by applicable law. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
Vendors and Service Providers
We use various third-party service providers, such as Google Cloud, Microsoft Azure, AppCues, and MixPanel, that assist us in providing Terra. For example, we may use third-party vendors to store and authenticate account credentials, store and analyze system logs, send email communications, and for hosting and storing information collected through our Platform. We may need to share your information with these vendors and service providers to enable them to provide these services to us. These service providers and vendors are required to only use your information to provide their services to us and in a manner consistent with this Policy.
If any of the Collaborators sell all or part of their business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, the Collaborator may transfer your Personal Data to a third party as part of that transaction.
5. Information You Share With Other Users; Forums
Our Services allow you to share Content you Connect to the Services with other Users of the Services and third parties who are not Users of the Services, including but not limited to, service providers. Broad is not responsible for such other Users’ and third parties’ use of your Content. You understand and acknowledge that, if you choose to share Content you Connect to the Services with other Users of the Services or third parties, such Connected Content might be copied or redistributed by those authorized Users and third parties. Any copies, relevant metadata, and derived results made by authorized Users will persist in the authorized User’s account, and thereby may continue to be accessible to third parties such as service providers, even after you remove information from your account or delete your account. Please review our Terms of Service for additional information relating to Connecting Content to the Services.
6. Links and Third Party Applications; Other Privacy Terms and Conditions
On the Services, we may provide links to websites or applications maintained by third parties, which we believe you may find useful. Broad is not responsible for the privacy practices of these other websites or applications and we encourage you to review the privacy policies of each of those other websites or applications before using such websites and applications. If you click on these third-party links, these other websites or applications may place their own cookies or other files on your computer, collect data, or solicit Personal Data from you. Other websites and applications will have different policies and rules regarding the use or disclosure of the Personal Data you submit to them. We make no representation with regard to the policies or business practices of any websites or applications to which you connect through a link from the Services, and are not responsible for any material contained on, or any transactions that occur between you and any such website or application.
As a processor, Broad stores the Content you Connect to the Services, which can include genomic sequence data (DNA, RNA, etc.), derived from humans or other organisms, that you submit to the Services along with metadata and other information related to such sequence data. You agree to and accept full responsibility for obtaining all necessary permissions and informed consents from the donors of all samples from which your submitted sequence data is derived.
7. Children’s Privacy
We are committed to protecting privacy of young people using our Services. We do not knowingly collect Personal Data on the Services from children under age 13. We believe children should get their parents’ or guardians’ consent before giving out any Personal Data. If you become aware that we have collected Personal Data from a child without parental consent, please notify us promptly. If we become aware that a child under age 13 has provided us with Personal Data without parental consent, we will take steps to remove it.
8. Data Processed in the United States
9. Notice to Individuals Located in the European Economic Area, United Kingdom, or Switzerland
Legitimate business interests that we rely on in processing your Personal Data include (i) improving and customizing the Services for you, (ii) understanding how the Services are being used, (iii) exploring ways to develop and grow our Services, (iv) ensuring the safety and security of the Services, and (v) enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks. Without the ability to collect and process your Personal Data, we would not be able to achieve those interests. We may also use your Personal Data for purposes, including scientific research, that are compatible with the purposes for which such data were initially collected.
If our processing is based solely on consent, you have the right to withdraw your consent. You may withdraw your consent by contacting us as set forth in the “Contact Us” section below. Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent, if we have a legal basis to do so. For example, we may retain certain information if we need to do so to comply with an independent legal obligation, or if it is necessary to do so to pursue our legitimate interest in keeping the Services safe and secure, or if deleting the information would undermine the integrity of a research study in which you are enrolled.
If your Personal Data is processed for GDPR Processing Activities, you have the right to (1) confirm with us whether your personal data is processed, and if it is, to request access to that personal data, (2) object to the processing of your personal data, (3) obtain a copy of the Personal Data Broad holds about you in an easily accessible format and receive any details required to be provided to you under applicable law, (4) correct or update your Personal Data, if inaccurate or incomplete, (5) limit collection and use of your Personal Data under certain circumstances (for example, if you think it is inaccurate), (6) request deletion of your Personal Data, subject to Broad’s need to keep such data to comply with legal requirements, to preserve the integrity of a research study, or to allow itself to defend itself from legal claims, among other bases for denying a request to delete, and (7) ask us not to process your personal data for direct marketing purposes, including profiling if it is related to such direct marketing. In addition, if you are based in the EU, you have the right to lodge a complaint with the relevant supervisory authority, details of which are on the European Data Protection Board (EDPB) website, depending on the country in which you are based (https://edpb.europa.eu/edpb_en). If you are based in the UK and you have concerns about our handling of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk), which is the UK’s supervisory authority for data protection issues.
Please note that the rights described are not all absolute and we reserve all of our rights available under applicable laws. If you have questions about the processing of your Personal Data or rights associated with your Personal Data, see the section “Contact Us” below.
In some instances, the provision of your personal data is required in order for us to enter into a contract or comply with our legal obligations and if you do not provide this personal data, we may not be able to provide our Services to you. In all other cases, your provision of personal data is voluntary.
We do not use automated decision making processes. We use certain registration data, including demographics, for the purposes of product improvement and user research for the legitimate interests of running and developing our business.