Privacy Policy

Last updated Oct 22, 2025

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Solu Healthcare Oy, Kalevankatu 31 A 13, FI-00100 Helsinki.
  • Data Protection Officer (DPO) refers to Jonatan Lehtinen, support@solugenomics.com
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to Finland
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Solu Platform and the Website operated by Solu Healthcare Oy, including all associated services accessible at www.solugenomics.com or through the Solu Platform.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Customer Data refers to microbial genomic data and related analytical results uploaded by users of the Solu Platform. Customer Data does not contain personal data from Solu Healthcare Oy’s perspective, but may be associated with identifiable individuals by the customer organization.
  • Website refers to Solu, accessible from www.solugenomics.com
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.‍

Our Role in Data Processing

Solu Healthcare Oy acts in two different roles depending on the type of data being processed:

1. Data Controller

We act as the data controller for personal data that you provide directly through the Solu Platform or our Website — such as account information, contact details, billing information, and usage data. In this role, we determine the purposes and means of processing this data, and our processing is governed by this Privacy Policy.

2. Data Processor

When you upload data to the Solu Platform that consists of microbial genomic data or related analytical results (“Customer Data”), we act as a data processor on behalf of the organization that owns or controls that data.

Although microbial genomic data uploaded to the Solu Platform may, in some contexts, relate to samples collected from natural persons, Solu Healthcare Oy has no access to any information that would allow us to identify such individuals. Based on the data available to us, microbial genomic data processed through our platform does not constitute personal data under the GDPR. However, our customers may act as data controllers in relation to such data if they hold additional information that enables re-identification.

We handle all Customer Data with the same technical and organizational safeguards that we apply to sensitive personal data. These include encryption at rest and in transit, strict access controls, audit logging, and secure backups. As a data processor, we process Customer Data only in accordance with our customers’ documented instructions and the applicable Data Processing Agreement (DPA), which is available to customers upon request. We do not access or use such data for any purpose other than providing the Solu Platform and related services, including customer support and troubleshooting, and only in accordance with our customers’ documented instructions.

3. Third-Party Service Providers

When we engage third-party providers (for example, for cloud hosting, analytics, or communication services), they may process personal data or Customer Data on our behalf. In such cases, we ensure that these providers act under written agreements, maintain confidentiality, and implement appropriate technical and organizational measures consistent with the GDPR.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Organization
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies
  • Type: Session Cookies
  • Administered by: Us
  • Purpose: These Cookies are essential to provide You with services available through the Service and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies identify if users have accepted the use of cookies on the Service.
  • Functionality Cookies
  • Type: Persistent Cookies
  • Administered by: Us
  • Purpose: These Cookies allow us to remember choices You make when You use the Service, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Service.

When you use our Services, you can choose to accept or reject non-essential cookies via the cookie banner. You can change your preferences at any time.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Legal Basis for Processing Personal Data

The following legal bases apply to Solu Healthcare Oy in its role as data controller. When we act as a data processor (for example, for Customer Data uploaded to the Solu Platform), we process that data solely on behalf of and under the lawful basis determined by our customers.

We process personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. The legal bases for our processing activities are as follows:

  1. Performance of a Contract (Article 6(1)(b) GDPR) We process personal data when it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract. This includes, for example:
    • Creating and managing user accounts on the Solu Platform
    • Providing access to and use of the Solu Platform and related services
    • Providing customer and technical support
  2. Compliance with Legal Obligations (Article 6(1)(c) GDPR) We may process personal data where necessary to comply with legal obligations, such as:
    • Complying with tax, accounting, or reporting requirements
    • Responding to lawful requests from authorities
  3. Legitimate Interests (Article 6(1)(f) GDPR) We process personal data based on our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include:
    • Improving and developing our services and user experience
    • Ensuring the security and integrity of our website and platform
    • Preventing fraud and misuse of our services
    • Communicating with users regarding updates or service-related matters
  4. Consent (Article 6(1)(a) GDPR) In certain cases, we process personal data based on your consent. This applies, for example, when:
    • You subscribe to our marketing communications
    • We use non-essential cookies or similar tracking technologies
    • You have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  5. Protection of Vital Interests (Article 6(1)(d) GDPR) Although rare, we may process personal data when necessary to protect someone’s vital interests, for example in case of a security incident involving personal data.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Your Rights Under Data Protection Law

As a data subject under the General Data Protection Regulation (GDPR), you have several rights regarding your personal data. We are committed to ensuring that you can easily exercise these rights.

  1. Right of Access You have the right to obtain confirmation as to whether we process your personal data and, if so, to access that data and receive information about how it is processed.‍
  2. Right to Rectification You have the right to request the correction of any inaccurate or incomplete personal data we hold about you
  3. ‍Right to Erasure (“Right to be Forgotten”) You may request the deletion of your personal data where there is no longer a lawful basis for us to process it, for example if you withdraw your consent or the data is no longer needed for the original purpose.‍
  4. Right to Restrict Processing You have the right to request that we temporarily or permanently stop processing all or some of your personal data, for example if you contest its accuracy or object to our processing.‍
  5. Right to Object You have the right to object to the processing of your personal data based on our legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is required for legal claims.‍
  6. Right to Data Portability You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.‍
  7. Right to Withdraw Consent If we process your personal data based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.‍
  8. Right to Lodge a Complaint If you believe that we have processed your personal data in violation of data protection laws, you have the right to lodge a complaint with your local supervisory authority. In Finland, this is the Office of the Data Protection Ombudsman (Tietosuojavaltuutetun toimisto) — https://tietosuoja.fi.

How to Exercise Your Rights

To exercise any of the above rights, please contact us at support@solugenomics.com. Our typical response time is within 1-3 business days.

We may need to verify your identity before responding to your request to ensure that your data is protected.

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. The retention period depends on the nature of the data and the context of its processing, as outlined below:

  1. Account Information Personal data associated with your Solu Platform account (such as name, contact details, and account credentials) is retained for as long as your account remains active. If you close your account, we will delete or anonymize your personal data within a reasonable period, unless we are required to retain it for legal or regulatory reasons.‍
  2. Service and Usage Data Data generated through the use of our services (such as log data, device information, or actions performed in the platform) is retained for operational, security, and analytical purposes. Such data is typically retained for up to 12 months after collection, unless a longer retention period is necessary for security or legal compliance.‍
  3. Microbial Genomic and Analytical Data Microbial genomic data and related analysis results uploaded or generated through the Solu Platform are retained according to the terms of your subscription or service agreement. You may delete your own data at any time through the platform interface. Although microbial genomic data is not considered personal data under GDPR, we handle it with the same security standards as personal data, including encryption and access controls. Encrypted backups may be retained for up to 90 days for recovery purposes.‍
  4. Billing and Financial Records Billing information, payment details, and related financial records are retained for the period required under applicable accounting and tax laws — typically six (6) years from the end of the financial year in which the transaction occurred.‍
  5. Support and Communication Records Communications with our support team or other correspondence are retained for up to two (2) years to help resolve ongoing issues and improve our services.‍
  6. Legal and Compliance Obligations We may retain certain data longer if necessary to comply with legal obligations, resolve disputes, enforce agreements, or protect our legitimate interests.

After the applicable retention period has expired, we securely delete or anonymize the data so that it can no longer be linked to an identifiable individual.

International Data Transfers

By default, we store and process data — including personal data and Customer Data — on Google Cloud Platform (GCP) servers located in the United States.

Where personal data is transferred to or stored in the United States, it is handled in accordance with the EU–US Data Privacy Framework, under which Google LLC is certified, ensuring an adequate level of protection for such transfers as required by the GDPR.

Upon customer request, we can host Customer Data exclusively within the European Union (EU), using GCP data centers located in the EEA.

Regardless of the storage location, we apply the same technical and organizational safeguards — including encryption, strict access controls, and audit logging — to all data we process.

You may contact us at support@solugenomics.com for further details on data storage locations or to request EU-only data residency.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use encryption at-rest, in-transit and access control measures to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

  • By email: support@solugenomics.com

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