Vanguard Genetics Corporation Privacy Policy

ADL respects individual privacy and values the confidence of its customers, employees, consumers, business partners and others. Not only does ADL strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, it also has a tradition of upholding the highest ethical standards in its business practices.

ADL recognizes that the European Community has established a data protection regime which applies to the European Economic Area (“EEA”) and restricts companies in the EEA in transferring personal data about individuals in the EEA to the United States, unless there is “adequate protection” for such personal data when it is received in the United States. To create such “adequate protection,” ADL adheres to US Department of Commerce guidelines with respect to personal data about individuals in the EEA that we receive from our customers and other business partners.

This Notice addresses data subjects residing in the EU (“EU Persons”) whose data we may receive from one of our customers, suppliers or other business partners in the EU e.g., referral partners, integration partners, etc. When ADL receives Client Personal Data for processing pursuant to instructions of clients or their partners, we are acting as an agent for our client and do not provide notice to individuals regarding the collection and use of their personal data. Our clients remain responsible for providing notice, if and to the extent they believe such notice is necessary under applicable EU law.

Business Purposes for the Collection and Use of Personal Data

ADL sells laboratory services largely to small and enterprise businesses, as well as direct to the consumer. We receive mostly business-related information from the EU or Swiss, including contact information of individuals and representatives of businesses with whom we or our customers are dealing, including, without limitation, names, addresses, work phone numbers, work email addresses, etc. of EU Persons (“EU Data”) or Swiss individuals. In connection with some services, e.g., ADL’s Lead Management services, our customers use our hosted technology platform to store and process EU Data at their own discretion. ADL will not use Client Personal Data for any other purposes than for the purposes that ADL clients provide such information.

ADL collects and uses EU Data and/or Swiss for purposes of providing products and services to our customers, communicating with business partners about business matters, processing EU or Swiss Data on behalf of corporate customers, providing information on our/their services, and conducting related tasks for legitimate business purposes.

Accountability of Onward Transfer

ADL recognizes potential liability in cases of onward transfer to third parties. ADL does not transfer Client Personal Data to unrelated third parties, unless lawfully directed by a client, or in certain limited or exceptional circumstances in accordance with law. For example, such circumstances would include disclosures of Client Personal Data required to meet national security or law enforcement requirements, or disclosures made in the vital interest of an identifiable person such as those involving life, health or safety.

In the event that ADL is requested to transfer Client Personal Data to an unrelated third party, ADL will ensure that such party is subject to similar laws providing an adequate and equivalent level of privacy protection, or will enter into a written agreement with the third party requiring them to provide protections consistent with such law. Should ADL learn that an unrelated third party to which Personal Data has been transferred by ADL is using or disclosing Personal Data in a manner contrary to this Policy, ADL will take reasonable steps to prevent or stop the use or disclosure.

Contact information and Client Personal Data is accessible only by those ADL employees and consultants who have a reasonable need to access such information in order for us to fulfill contractual, legal and professional obligations. All of our employees and consultants have entered into strict confidentiality agreements, and/or have been subjected to thorough criminal background checks requiring that they maintain the confidentiality of Client Personal Data.

You have the right of access to a copy of the information comprised in your personal data and may at any time request the destruction of all records associated with your casework by sending a notarized letter detailing the request for records destruction to:

Attn: General Counsel
3655 Research Road
Las Cruces, NM 88003


ADL is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

With respect to marketing emails, EU Persons or Swiss individuals may opt-out of receiving further email communications from ADL or ADL clients by following opt-out instructions that are contained in the bottom of the email communication you received.

Access, Review & Update

If you are an EU Person or Swiss individual about whom we hold EEA or other personal or private Data on a client’s behalf, you may request access to, and the opportunity to update, correct or delete, such EEA or other personal or private Data. To submit such requests or raise any other questions, please contact the business that provided your EEA or other personal or private Data. We reserve the right to take appropriate steps to authenticate an applicant’s identity, to charge an adequate fee before providing access and to deny requests.

Privacy Complaints

ADL commits to resolve complaints about your privacy and our collection or use of your personal information. US, European, and Swiss individuals with inquiries or complaints regarding this privacy policy should first contact ADL at:

Attn: Chief Operating Officer
3655 Research Road
Las Cruces, NM 88003