Privacy Notices

GRAIL, LLC and its subsidiaries and affiliates (collectively, ​“GRAIL”) is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully in line with all relevant privacy legislation. The purpose of this Privacy Policy is to set out the principles governing our use of personal information that we may obtain about you through one or more of our websites at which this Privacy Policy is posted (our ​“Sites”) and in connection with our business (the ​“Business”). Our Sites include Grail.com (the ​“GRAIL Site”), provider.grail.com (the ​“Provider Portal”), my.grail.com (the ​“Patient Portal”) and Galleri.com (the ​“Galleri Site”). If you are outside the European Economic Area (“EEA”) or the United Kingdom (“UK”), by using our Sites, you agree to our use of the personal information that we obtain about you.

If you are in the EEA or the UK, this Privacy Policy is provided for informational purposes only. Users in the EEA and UK should also read the Privacy Notice for European Users, which provides additional information about how GRAIL processes, stores and transfers your personal information and the rights that you have in respect of such personal information.

Please read this Privacy Policy carefully. We may change our Privacy Policy from time to time. We therefore ask you to check it occasionally to ensure that you are aware of the most recent version that will apply each time you access our Sites. In the event of material changes to this Privacy Policy, we will notify you. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/​or upon implementation of the new changes on our Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of our Sites, products and services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy. IF YOU ARE OUTSIDE THE EEA OR THE UK, BY USING OUR SITES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, DO NOT USE OUR SITES.

For your convenience, our Sites may contain links to a number of other websites that we do not own or operate. If you access those links, you will leave our websites. This Privacy Policy does not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies. Any reference to a linked site or any specific third party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.

Your Data

We may collect, process, use, store, and transfer the following information to provide, improve and protect our Sites and in connection with our Business.

The Data we Collect and Process. We may collect personal information when you visit or interact with our Sites, fill in forms on our Sites, interact with our Business, correspond with us by phone, e‑mail, or otherwise, or when you inquire about or apply for employment opportunities at GRAIL. This personal information generally refers to information that relates to an identified or identifiable individual or household, such as a name, contact details, or address, and includes the following information which are referred to in this Privacy Policy as ​“personal information” generally, and ​“personal data” in the Privacy Notice for European Users:

• Information You Provide Us. When you interact with our Sites, for example when you complete one of our online forms such as a job application form, you may provide us with information that we collect, including:
  
  
  • Contact Information such as your name, title, company, mailing address, email address, phone number, password, resume information, professional credentials, institutional affiliations, feedback, and any other information you choose to provide to us;
    
    
  • Health / Test Order Information such as certain health information related to cancer status or cancer risk, demographic information, email address, and address;
    
    
  • Biographical and demographic information such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians;
    
    
  • Testimonials such as any information you provide related to your experiences with our products and services;
    
    
  • Marketing and communication data which tells us your preference in receiving marketing from us and our third parties and your communication preferences;
    
    
  • Sensitive personal information such as your race or ethnicity, or criminal offenses. Please note that we do not ask for any sensitive personal information through our Sites (except for responses to job postings that are collected by a third party) and request that you omit any such information in any communications with us. If you send us sensitive personal information, we will delete it unless you provide your specific consent to having us include it in your account, as it will be processed with the rest of your personal information; and
    
    
  • Payment-related information such as credit card and financial account information.
    
    

• Information that We Collect Automatically When You Visit our Sites. When you visit our Sites, we automatically collect the following information from your computer or other electronic device:
  
  
  • Technical data such as your internet protocol (“IP”) address, your login data, the web page you visited before visiting our Sites, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Sites; and
    
    
  • Usage data which tells us how you use our Sites.
    
    

Purposes for Which We Will Use Your Data

We will use your personal information consistent with applicable law. Most commonly, we will use your personal information in the following circumstances:

• To provide services to you or to perform the contract we are about to enter into or have entered into with you.
  
  
• To manage our relationship with you.
  
  
• To process your registration on our Sites and send you information about changes to our Terms of Service and other policies.
  
  
• To communicate with you and respond to your service-related requests, questions, and feedback.
  
  
• To verify your identity or provide you with the information, products and services that you request. For example, we provide information or respond to your questions when you contact us.
  
  
• To facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
  
  
• To provide, evaluate, improve, protect, and promote our Sites and our products. Note that we use your usage data and technical data, including the actions you take in your account (such as visits to our Sites, page interaction information, and search history) as well as cookies and other technologies for these purposes.
  
  
• To comply with a legal or regulatory obligation, such as a subpoena, court order, warrant, or similar legal process.
  
  
• Where you have given your consent and as described to you when we collect your personal information.
  
  
• Where it is necessary for our legitimate interests (or those of a third party) and, where consistent with applicable laws.
  
  
  • To provide you with access to content and features on our Sites and develop our Business and our Sites;
    
    
  • To personalize and enhance your experience when you visit our Sites, such as tailoring content and advertising and remembering your preferences. We may also use your personal information to provide you with information about our Business we feel may interest you, market new products to you, and send you communications about new features. If you do not want us to use your data in this way, select the ​‘unsubscribe’ link in any email communication, or text ​‘STOP’ to opt out of any SMS communication, from us;
    
    
  • To monitor the use of our Sites and use personal information to help us provide, evaluate, improve, protect, and promote our Sites and our products, both online and offline;
    
    
  • To ensure the security of our Sites, by preventing unauthorized or malicious activities;
    
    
  • To investigate any complaints received from you or from others about our Sites or our Business;
    
    
  • To enforce compliance with our Terms of Service and other policies and to help other organizations (such as copyright owners) enforce their rights;
    
    
  • To protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); and
    
    
  • To investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
    
    

Sharing Your Data

We may share information as discussed below.

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service Providers and Contractors. GRAIL uses trusted third parties (e.g., IT services, analytics services, etc.) to help us provide, improve, protect, and promote our Sites and our Business, and to perform business operations, such as determining eligibility for our products. These third parties may contact you on our behalf to perform these business operations. These third parties will access your personal information only to perform tasks on our behalf in compliance with this Privacy Policy.

Other Applications and Third-party Links. The Sites 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 policies. When you leave our Sites, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.

The Public. We may make available functionality that enables you to disclose information to the public. We do not control how other individuals or third parties use any personal information that you make available to the public. If you gave us consent to post a testimonial on our Sites and/​or social media pages but wish to update or delete it, please contact us at privacy@​grailbio.​com.

Advertising Partners. We may share personal information with third party advertising companies that collect information about your activity on certain portions of the GRAIL Site and other online services for advertising purposes.

For Compliance, Fraud Prevention and Safety. We may share personal information for the compliance, fraud prevention and safety purposes described above and to comply with legal requirements and processes.

Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Legal Purposes. We will disclose your personal information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant, or similar legal process; or if necessary to assert or protect our rights or assets.

Other Parties. To another party or parties for any other purpose disclosed by us when you provided your personal information, with your consent or authorization, or as otherwise permitted or required by applicable law.

Protecting Your Data

We have implemented reasonable measures and procedures designed to protect your personal information. These measures include pseudonymization, anonymization, information security controls, and data retention protocol. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Children

Consistent with the United States Children’s Online Privacy Protection Act of 1998 (“COPPA”), we do not knowingly request personally identifiable information from anyone under the age of 13 without requiring parental consent. Any person who provides their personal information to GRAIL through our Sites represents that they are 13 years of age or older. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us at privacy@​grailbio.​com.

Where We Store and Transfer Your Data

The Sites are controlled by GRAIL from its offices in the United States. GRAIL may store and use information in the United States, the UK and other jurisdictions; any personal information provided to GRAIL will be transmitted to or within those jurisdictions. GRAIL also may transfer information and personal information to other jurisdictions to facilitate GRAIL’s third party processors’ access to and/​or processing of information and/​or personal information. Such jurisdictions may have privacy laws not as protective as those in your jurisdiction. Users in the EEA and the UK should read the important information provided in the Privacy Notice for European Users about transfer of personal information outside of the EEA and UK.

GRAIL makes no representation that materials on our Sites are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited. Those who choose to access our Sites from other locations do so on their own initiative and are responsible for compliance with applicable local laws.

Your Choices

Update Your Information. If you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you may contact us at privacy@​grailbio.​com.

Marketing Communications. You may opt out of marketing-related emails by clicking the ​“Unsubscribe” link at the bottom of each such email, or by sending an email with the subject line ​“Unsubscribe” to privacy@​grailbio.​com. You may continue to receive service-related and other non-marketing emails.

Do Not Track. Some internet browsers may be configured to send ​“Do Not Track” signals to the online services that you visit. We currently do not respond to ​“Do Not Track” or similar signals. To find out more about ​“Do Not Track,” please visit https://allaboutdnt.com/.

Testimonials. If you gave us consent to post a testimonial on our Sites and/​or or social media pages, but wish to update or delete it, please contact us at privacy@​grailbio.​com.

Use of Cookies and Other Technologies

Certain of our Sites use ​“cookies” to gather general information about the browsing activities of visitors to those Sites. This allows us to constantly improve our Sites’ design by arranging the content in the most user-friendly manner and to continually meet the users’ needs. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. (Nevertheless, we cannot guarantee that cookies will not be accessed by other persons.)

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of our Sites that depend on cookies. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.

We may use the following types of cookies:

Strictly Necessary Cookies: Our Sites use strictly necessary cookies. These cookies are necessary for our Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Analytics Cookies: The GRAIL Site, the Provider Portal, and the Patient Portal use analytics cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Sites. They help us to know which pages are the most and least popular and see how visitors move around the Sites. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our Sites, and will not be able to monitor our Sites’ performance.

For example, we use Google Analytics, and other tracking technology tools, such as Pardot, Hotjar, Pendo, and Intercom, to collect information about usage of our Sites, which allows us to receive information about general usage statistics. In order for Google Analytics to function, when you use our Sites, Google will place cookies on your device. Google Analytics may also collect information through other methods in addition to cookies. Information collected by Google Analytics when you use our Sites, and the way it is used, is described in the applicable Google Privacy Policy and Google Terms of Service.

Advertising Cookies: Certain portions of the GRAIL Site use advertising cookies. These cookies may be set through our Sites by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not directly store personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Retaining Your Personal Data

We seek to only retain personal information for as long as necessary to fulfill the purposes for which we collected such information, as set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, subject to your rights, in certain circumstances, to have your personal information erased. We may be required in law to hold certain personal information for specific periods. In other cases, we will retain your personal information for an appropriate period after our relationship ends to protect ourselves from legal claims or to administer our business. 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 unauthorized 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.

GRAIL’s processing of your personal data may be subject to applicable privacy laws in the EEA and the UK, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018 (“DPA18”).

For the purposes of this privacy notice, ​“personal data” means any data or information that relates to and can identify a living individual. The data controller of your personal data is GRAIL, Inc., which can be contacted by post at 1525 O’Brien Drive, Menlo Park, California 94025 (Attn: Legal Department), by email at privacy@​grailbio.​com and by telephone at +1 – 833-694‑2553

Provision of Personal Data. We only process personal data where we have a legal basis for doing so. The legal bases are described in the section of our Privacy Policy titled ​“Purposes for which we will use your data”. Where we use your personal data to provide our products or services, in relation to your application for employment or to comply with our legal obligations, the provision of this personal data is mandatory. The failure to provide the requested personal data means that we may not be able to provide these products or services or process your application. The provision of all other personal data, such as the details you provide so we can send marketing communications, is optional.

Your Rights. If you are an individual in the EEA or the UK, or GRAIL’s processing of your personal data is otherwise subject to the GDPR or the DPA18, you may have certain rights with respect to your personal data. You can exercise these rights at any time by contacting us at privacy@​grailbio.​com.

• Request Access to your Personal Data. You can request a copy of the personal data we hold about you.
  
  
• Request Correction of Your Personal Data. You can ask us to correct any incomplete or inaccurate personal data we hold about you.
  
  
• Request Erasure of your Personal Data. You can ask us to delete your personal data where there is no legitimate reason for us continuing to process it.
  
  
• Request Restriction of Your Personal Data. You can ask us to suspend the processing of your personal data (such as when you want us to establish its accuracy or the reason for processing it).
  
  
• Request Portability of Your Personal Data. You can ask us to transfer your personal data to another data controller in a machine-readable form. This right will only apply where we process your personal data based on your consent or where the processing is necessary for the performance of a contract between us.
  
  
• Object to the Processing of Your Personal Data. You can object to our processing where we are relying on a legitimate interest (or those of a third party) as our legal basis. You can also object at any time to our use of your personal data for direct marketing purposes.
  
  
• Withdraw Your Consent. Where we are relying on your consent to process your personal data, you can withdraw consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent. However, where we are relying on your consent as the legal basis for processing, we may not be able to provide certain products or services to you following the withdrawal of such consent.
  
  
• You also have the right to complain to an EEA or UK data protection authority in the place you live, work or where you believe a breach of the GDPR or the DPA18 occurred. However, GRAIL would appreciate the opportunity to address your concerns before you do this, so please contact us in the first instance at privacy@​grailbio.​com.

If necessary, we will notify any other parties (such as our suppliers or service providers) to which we have transferred your personal data of any changes that we make when you make a request under the GDPR or the DPA18. While we communicate to these parties, we are not responsible for the actions they take to answer your request. In some cases, you may also be able to access your personal data held by these third parties and correct, amend or delete it where it is inaccurate.

Your rights under the GDPR and the DPA 18 may be limited, such as where fulfilling your request would reveal personal data about another person or would infringe the rights of a third party (including our rights), or if you ask us to erase personal data that we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

Transferring Your Personal Data. When we transfer your personal data outside the EEA and the UK, and to the extent required by the GDPR and the DPA18, we rely on appropriate or suitable safeguards to transfer your personal data, including:

• Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards for personal data;
  
  
• Obtaining your consent to transfer personal data after first informing you about the possible risks of such a transfer;
  
  
• When the transfer is necessary for the performance of a contract between you and us or if the transfer is necessary for the performance of a contract between us and a third party that is entered into in your interest; and
  
  
• Where the transfer is necessary to establish, exercise or defend legal claims.
  
  

For further information, including to obtain a copy of the documents used to protect your personal data, please contact us at privacy@​grailbio.​com.

Retaining Your Personal Data. We seek to only retain personal data described in this Privacy Policy, for as long as necessary to fulfill the purposes for which we collected such data, as set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, subject to your rights, in certain circumstances, to have your personal information erased. We may be required in law to hold certain personal information for specific periods. In other cases, we will retain your personal information for an appropriate period after our relationship ends to protect ourselves from legal claims or to administer our business. 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 unauthorized 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.