Strata Oncology Privacy and Security Policy, Effective Date of March 13, 2017.

Strata Oncology, (“Strata Oncology”) is committed to protecting the privacy of Your Information (defined below). This Policy describes Strata Oncology’s privacy practices for the use of its Physician Portal.  The Physician Portal is intended for licensed physicians in the United States.  Do not register for or use the Physician Portal if:  (1) you are not a licensed physician practicing in the United States; (2) you do not want Strata Oncology to use Your Information as stated in this Policy; or (3) you are barred from providing services under the laws of the United States or any state or other applicable jurisdiction. 

Information Collected:  When you register to use the Physician Portal, you will be required to provide your personal contact and verification information, such as name, company name, address, phone number, NPI, fax number and email address (“Your Information”). Once you are registered, you may provide us with health information of patients you are treating (“Patient Information”).  When You provide us with Patient Information, you represent you are doing so in compliance with the requirements of the HIPAA Privacy Rule and state privacy laws and that you have obtained any necessary consents and/or authorizations necessary prior to providing us with Patient Information. 

Use of Information Collected:  Strata Oncology uses Your Information and Patient Information to perform the services requested, which allow us to provide you with access to the Portal, to order the Strata Test for patients who qualify for and enroll in the Strata Trial, and to allow you to access Strata Test reports and other information we provide.  We will not sell, share or rent the information that is collected to others in ways different than from what is disclosed in this Privacy and Security Policy. 

Sharing of Information with Third Parties:  (1) Business Partners: Strata Oncology may work with business partners in making our services available to you. Our policy is to require companies with whom we do business to support the same privacy policies we do. We will share information only as necessary for the third party to provide related services or assist us in providing the Physician Portal. These parties are not allowed to use Your Information or Patient Information except for the purpose of providing these services. 

De-Identified/ Aggregate Information: On occasion, Strata Oncology may share certain de-identified aggregate information as permitted by our Strata Trial protocol and patient informed consent.  De-identified information is information about a person presented in a form where information about one anonymous person would be indistinguishable from information relating to other anonymous people. De-identified individual information is not in a form that allows anyone studying the information to personally identify any individual.  Aggregate information is information that describes the habits, usage patterns and/or demographics of people as a group but does not reveal the identity of particular people.  Your anonymous data is combined with the anonymous data of other Physician Portal users and becomes statistics.

Law Enforcement and Protection of Users and the Site:  If required by law, Strata Oncology may disclose Your Information or Patient Information to governmental authorities or third parties pursuant to a legal request, subpoena or other legal process.  Strata Oncology may also use or disclose Your Information as permitted by law to apply or enforce the Terms of Use, or to protect the rights, interest, or property of Strata Oncology or our affiliates.  Following such disclosure to any third party, Your Information may be accessible by others to the extent permitted or required by applicable law.

Security:  Strata Oncology uses robust security measures to protect Your Information and Patient Information from unauthorized access, maintain data accuracy, and help ensure the appropriate use of Your Information and Patient Information. When you access the Physician Portal using modern web browsers, Secure Socket Layer (.SSL.) technology protects Your Information and Patient Information using both server authentication and data encryption, to help ensure that Your Information and Patient Information is safe, secure, and only available to the applicable treating physician to whom the information belongs. Strata Oncology also implements an advanced security method based on dynamic data and encoded session identifications, and hosts its Web sites in a secure server environment including firewalls, intrusion detection systems, and other advanced technology to prevent interference or access from unauthorized users. However, no Web site, server or database is completely secure. Strata Oncology cannot guarantee that Your Information or Patient Information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. You are responsible for maintaining the security and confidentiality of your Strata Oncology usernames and passwords.

Changes to this Policy:  Strata Oncology may change this Policy from time to time, and will update the effective date of the new version at the top of this Policy accordingly.

Assignment:  Your Information and Patient Information will remain subject to the terms of this Policy even if we undergo an organizational transition. We may transfer Your Information and Patient Information to a successor entity upon a merger, consolidation, or other reorganization. You hereby consent to such transfers and Strata Oncology may assign and transfer all of the rights, benefits, duties, and obligations of this Policy, under the circumstances described in this paragraph.

Contacting Us:   Questions regarding this Policy or the information practices of the Physician Portal should be directed to clinops@strataoncology.com.