Global Privacy Notice
Last Updated: May 30, 2025
We at Othram, Inc., a Delaware corporation, and our affiliates and subsidiaries (“our,” “us”, or “we”) respect your privacy. This Global Privacy Notice (this “Notice”) describes the processing of Personal Information (defined below) that is provided, collected, or disclosed while providing our products or services to you (“Services”) and on (1) othram.com, (2) dnasolves.com, (3) totaltreecall.com, (4) websleuths.com, and (5) any other websites, applications, and online platforms that link to this Notice (the “Sites”). This Notice also describes rights you may have under applicable data protection laws.
For further information on how we may collect, use, and disclose your genetic or other health-related data, please review our Consumer Health Data Supplemental Privacy Notice, which supplements this Notice.
We may provide you with a different privacy notice or policy in certain specific situations, in which case that privacy notice or policy will apply to the Personal Information collected or processed in that specific situation, rather than this Notice.
If you provide us with Personal Information related to anyone other than yourself — including genetic information, deoxyribonucleic acid (“DNA”) profiles, or genealogical information — you are responsible for complying with all privacy and data protection laws prior to providing that information to us (including obtaining consent, if required).
Personal Information We Collect
We collect several categories of Personal Information from and about users of our Sites and Services. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you. The categories of Personal Information we collect may include:
Contact Information - If you submit an inquiry, register for an account, or provide information on or through our Sites or Services, we may collect your contact information, including your name, mailing address, email address, and phone number.
Commercial Information - If you submit an inquiry, or provide information on our Sites, we may collect commercial information including information about your purchases, subscriptions, and Services in which you have shown interest.
Usage Information - When you use our Sites, we may automatically record information, including your Internet Protocol address (IP Address), geolocation of your device, browser type, referring URLs (e.g., the website you visited before coming to our Sites), domain names associated with your Internet service provider, and any other information regarding your interaction with our Sites.
Communication Information - We may collect Personal Information contained within your communications with us via email, chat, forum or blog posts, social media, telephone, or otherwise, and in certain cases we may use third-party service providers to do so. Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.
Genetic or DNA Information - In connection with certain Services, we may collect your genetic information, physical DNA samples, or DNA profile.
Genealogical Information - In connection with certain Services, we may obtain your genealogical information, such as names, dates, and locations of birth and death and other family history, including through certain Services allowing users to submit genealogical information to us.
Financial Information - If you make a purchase though our Services, we may collect financial information, such as credit card or bank details, including through our payment processing providers. In some instances, we may also transmit payments to certain users, in which case we will collect financial information, such as bank details and other bank account information, necessary to make direct payments to you by us or one or more third party service providers.
How We Collect Personal Information
Directly From You - We collect Personal Information you provide to us directly. Examples include if you choose to contact us, request information from us, sign up to receive updates, or otherwise utilize our Sites or Services.
From Users of Our Services - We may obtain your Personal Information from users of our Services, including in the following circumstances:
Total Treecall. Users of Total Treecall totaltreecall.com may provide us Personal Information derived from public sources for the purposes of genealogical research.
Request System. We may receive DNA, DNA profiles (such as that derived from unidentified human remains, including suspected missing persons, or criminal suspects), or other Personal Information from users of our Request System request.othram.com that are either (1) law enforcement agencies and organizations, (2) other governmental or quasi-governmental agencies and organizations, (3) those acting on behalf of, or at the direction of, such agencies and organizations, and (4) other authorized users of our Request System (collectively, “Investigators”). We contractually require Investigators using the Request System to comply with all applicable laws when providing DNA or DNA profile information to us. To learn more about the Request System and how we receive and process the DNA and DNA profiles, please see our Request System Supplemental Terms of Use and our Request System Supplemental Privacy Notice.
From Other Third Parties - We may collect Personal Information from other third parties, including business partners, advertising networks, social networks, data analytics providers, mobile device providers, public databases, or Internet or mobile service providers.
- Through Online Tracking Technologies - We use cookies and similar technologies to collect Personal Information automatically as you navigate our Sites. For additional information regarding our use of these technologies, see the Cookies and Tracking Technologies section below.
How We Use Personal Information
To the extent permitted by applicable law, we use Personal Information:
To provide and personalize our Sites and Services, such as processing or fulfilling transactions, providing and personalizing our Services, processing payments, providing customer service, maintaining or servicing accounts, providing financing, verifying customer information, creating and maintaining business records, verifying eligibility, and undertaking or providing similar services.
To optimize, improve, and maintain our Sites and Services, including understanding how users interact with our Sites and Services, gauging user interest in certain Sites or Services functionality, and troubleshooting problems.
For internal research and development, such as testing, verifying, and improving the quality of our Sites or Services or developing new ones.
For marketing and advertising, including using your information to send you messages, notices, newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and services that may be of interest to you. You can unsubscribe from any marketing emails or text messages that we may send you by following the instructions included in the email or text correspondence or emailing us at solve@othram.com.
For communicating with you, such as responding to your questions and comments or notifying you of changes to our Sites or Services.
For legal, security, or safety reasons, such as (1) protecting our and our users’ safety, property, or rights, (2) complying with legal requirements, (3) enforcing our terms, conditions, and policies, (4) detecting, preventing, and responding to security incidents, and (4) protecting against malicious, deceptive, fraudulent, or illegal activity.
As part of a corporate transaction, such as in connection with the sale of part or all our assets or business, the acquisition of part or all another business or another business’ assets, or another corporate transaction, including bankruptcy.
To aggregate and de-identify information, such as for analytics, research, and compliance purposes and for all other purposes.
To fulfill any other purpose for which you provide it, including purposes described when you provide the information or give your consent.
How We Disclose Personal Information
We may disclose without restriction aggregated information about our users and information that does not identify any individual.
We may disclose your Personal Information with your consent or in the following circumstances:
Employees and Other Personnel – We may share Personal Information with our employees and personnel (such as contractors) who have a need to know the information for our business purposes.
Affiliates and Subsidiaries – We may share Personal Information within our family of companies for their and our business and marketing purposes, including providing you with information about the Services we think may be of interest to you.
Law Enforcement – Certain of our Sites or Services may involve the collection of information relevant to law enforcement investigations. We may, therefore, provide access to certain Personal Information to Investigators or those involved in law enforcement investigations.
Other Users – To the extent a user posts Personal Information on forums, blogs, or other public- facing areas of our Sites, users of our Sites and Services will be able to see such Personal Information.
Service Providers – We disclose your Personal Information with the service providers we use to support our business, including data analytics providers, website hosting providers, and other technology providers. If you are applying for a job with us, this may include service providers such as background check providers and human resource providers.
Business Partners – We may disclose Personal Information with trusted business partners. For example, we may disclose your Personal Information with a company whose products or services we think may be of interest to you or who we co-sponsor a promotion or service with.
Ad Tech Companies and Other Providers – We may share or make available limited Personal Information (such as a mobile device identifiers) with ad tech companies and other online service providers. When we share your Personal Information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.
Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party when we have a good faith belief such disclosure of Personal Information is reasonably necessary to (1) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (2) enforce or investigate a potential violation of any agreement you have with us, (3) detect, prevent, or otherwise respond to fraud, security or technical concerns, (4) support auditing and compliance functions, or (5) protect the rights, property, or safety of us and our employees and clients or protect the public against harm.
Merger or Change of Control – We may disclose Personal Information to third parties in preparation for, or upon consummation of, a merger, acquisition, or any other transaction involving a change of control in our business, including a bankruptcy or similar proceeding. Where legally required, we will give you notice prior to such disclosure.
Aggregated and De-Identified Information – We may disclose aggregated, anonymous, or de-identified information about users for analytics, research, and compliance purposes and for any other purposes.
Other – We may disclose Personal Information to third parties when explicitly requested by or consented to by you or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
We and our service providers may use cookies and similar technologies to collect usage and browser information about how you use our Sites and Services. The technologies we use for this automatic data collection may include cookies and web beacons that permit us to verify system and server integrity and generate statistics around the popularity of certain content. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of our Sites and Services, to enhance your experience through personalization, and to help us better understand the features of our Sites and Services that you and other users are most interested in.
Website Delivery and Appearance – We may use third party providers to enable certain customer interaction opportunities, content delivery (like audio or video), or other service capabilities. Examples include the following functionality:
- Content Delivery: We partner with service providers to host our Sites and deliver specific content in support of our Services. For example, we use Adobe Typekit to serve fonts on our Sites, which is governed by Adobe Typekit’s Privacy Policy.
Website Analytics and Session Replay – We use analytics and session replay services that use cookies and other technologies which collect your Personal Information to assist us with analyzing our Sites’ traffic and Sites’ usage to optimize, maintain, and secure our Sites and inform subsequent business decisions (including advertising). These include the following third-party services:
Microsoft Clarity: We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our Sites through behavioral metrics, heatmaps, and session replay to improve and market our products and services. Sites usage data is captured using first and third- party cookies and other tracking technologies to determine the popularity of products and services and online activity. Additionally, we use this information for Sites optimization, fraud and security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.
Meta Pixels: We use Meta pixels to track user activity on our Sites and improve downstream offerings for our services and those of our partners and service providers.
Selling or Sharing Personal Information – While we do not sell Personal Information in exchange for monetary consideration, we do share Personal Information for other benefits that could be deemed a “sale” under various data protection laws, because they are sometimes broadly defined to include activities such as allowing third parties to receive certain information, such as cookies, IP addresses, or browsing behavior. It is in this context we have provided advertising networks, data analytics providers, social networks, and video sharing platforms with Personal Information, such as your IP address, device information, Internet and other electronic network activity information, and geolocation information in the last 12 months.
Cookie Choices – To manage your preferences with respect to these technologies, you can:
Visit our preferences page or customize your browser settings to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable certain cookies, please note some parts of our Sites may not function properly. These settings may be lost and require reconfiguration if you delete your cookies.
Review and execute any provider-specific instructions to customize your preferences or opt-out of certain processing by third party service providers. For example, to limit Google’s collection or use of your data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Meta also offers an Ad Preferences center to customize your settings, as well as a Privacy Policy with additional information on how you can exercise your rights.
How Long We Keep Your Personal Information
We retain your information for as long as needed to (1) conduct business with you, (2) fulfill the purposes outlined in this Notice, and (3) comply with our legal obligations, resolve disputes, and enforce any agreements.
Criteria we will use to determine how long to retain your Personal Information include (1) the nature and length of our business relationship with you, (2) our legal rights, obligations, and retention requirements, and (3) if we have an ongoing business purpose for retaining your Personal Information, such as communicating with you about ongoing or prospective Services you requested.
Links to Third-Party Websites
We are not responsible for the practices employed by any websites or services linked to or from our Sites, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be handled in accordance with the applicable third party’s privacy policy.
In some cases, we offer links to social media platforms (like Facebook, X (formerly known as Twitter), and YouTube) that enable you to easily connect with us or share information on social media. Any content you post via these social media pages is subject to the Terms of Use and Privacy Policies for those platforms.
International Use and Cross-Border Data Transfers
If you are visiting our Sites from outside of the United States, please note our Sites are hosted in the United States. Where permitted by applicable law, we may transfer the personal data we collect about you to the United States and other jurisdictions, which may not be deemed to provide the same level of data protection as your home country, as necessary for the purposes set out in this Notice.
How We Protect Personal Information
We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. Despite these efforts to store Personal Information in a secure environment, we cannot guarantee the security of Personal Information during transmission or storage on our systems.
Exercising Your Privacy Rights
Depending on where you live, you may have the following rights with respect to your Personal Information under applicable data protection laws:
Access – The right to request access to, and obtain a copy of, any Personal Information we may have about you.
Deletion – The right to delete your Personal Information we have collected or obtained, subject to certain exceptions.
Correction – The right to request we correct any inaccuracies in your Personal Information, subject to certain exceptions.
Opt Out of Certain Processing – The right to (1) opt out of the processing of your Personal Information for purposes of targeted advertising, (2) opt out of the sale or sharing of your Personal Information, (3) limit the use of your sensitive Personal Information (if applicable), and (4) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. We do not collect or process sensitive Personal Information outside of purposes permitted by law (such as Section 7027(m) under the California Consumer Privacy Act Regulations), so we do not offer the option to limit use of sensitive Personal Information. We also do not profile you or other individuals in a manner that would result in legal or similarly significant effects, so we do not offer an opt out.
Objection/Restriction of Processing – The right to object or restrict us from processing your Personal Information in certain circumstances.
Withdraw Consent – The right to withdraw your consent where we are relying on your consent to process your Personal Information.
Automated Decision-Making – The right to know when you are subject to automated decision- making, the Personal Information used to render the decision, the principal factors and parameters involved in the decision, and human review or correction of the decision (or the decision’s underlying data, where appropriate). You may also have the right to consent or opt out of this automated decision-making, depending on your location.
Lodge a Complaint – The right to lodge a complaint with a supervisory authority or other regulatory agency if you believe we have violated any of the rights afforded to you under applicable data protection laws. We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so.
If you have registered for an account with one or more of the Services, you may exercise certain of these rights through your online profile. Additionally, to exercise any of the privacy rights afforded to you under applicable data protection laws, you may e-mail us at solve@othram.com. You may also exercise your opt out rights by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC). We honor Opt-Out Preference Signals, including GPC. If you choose to use an Opt-Out Preference Signal, you will need to turn it on for each supported browser or browser extension you use.
You will not be discriminated against in any way by virtue of your exercise of the rights listed in this Notice. However, should you withdraw your consent or object to processing of your Personal Information, or if you choose not to provide certain Personal Information, we may be unable to provide some, or all, of our Services to you.
Only you, or an authorized agent that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. We must verify your identity before fulfilling your requests, and if we cannot verify your identity, we may request additional information from you. If you are an authorized agent making a request on behalf of another person, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney. We endeavor to respond to requests within the period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your requests unless they are excessive or repetitive. If we determine a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We may deny certain requests, or only fulfill some in part, as permitted or required by law. If you are not satisfied with the resolution of your request and you are afforded a right to appeal such decision, you will be notified of our appeal process in our response to your request.
Children’s Privacy
We do not knowingly collect or solicit any Personal Information from children, as defined under applicable law, without verified written parental consent, and we have no actual knowledge of selling such Personal Information of minors under 16 years of age. If we learn we have collected Personal Information from a child, we will promptly take steps to delete that information. If you believe we might have any information from a child, please contact us at solve@othram.com.
California Residents
This section provides additional information regarding our practices pursuant to the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CCPA”), where “Personal Information” has the definition set forth in the CCPA.
Please see the chart below for detailed information about the categories of Personal Information we have collected from California residents during the 12 months preceding the date on which this Notice was last updated and the categories of third parties to whom we sell or share Personal Information. For each category of Personal Information set forth in the chart below, the categories of third parties to whom we disclose it for a business or commercial purpose are set forth in the How We Disclose Personal Information section above.
| Personal identifiers, including real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. | California Customer Records Personal Information (Cal. Civ. Code § 1798.80(e)), including name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, etc. | Characteristics of protected classifications under California or federal law. This may include age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion. | Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Internet and other electronic network activity information, including browsing history, search history, and information about individual interactions with an Internet website, application, or advertisement. | Geolocation data, such as your IP address. | Sensory data including audio, electronic, visual, thermal, olfactory, or similar information. | Professional or employment- related information. | Inferences drawn from any of the information identified in this table to create a profile about a consumer. | Sensitive Personal Information as set forth in Cal. Civ. Code § 1798.140, including social security number, driver’s license number, genetic information, state identification card, or passport number, citizenship or immigration Information; racial or ethnic origin; account access credentials (like usernames or account numbers combined with password or other security/access code to access an account); | |
| Users of our Services | X* | X* | X* | X* | X* | X | X | X | X | |
| Third Parties - General† | X | X | X | X | X | X | X | |||
| Third Parties – Total Treecall+ | X | X | X | X | X | X | ||||
| Third Parties – Request System# | X | X | X | X | X | X |
* We disclose this category of information with third-party marketers, analytics providers, and other third parties that set cookies and other online tracking technologies on our Sites in a manner that may be deemed a “Sale” or “Sharing” under the CCPA.
† ”Third Parties - General” includes persons whose Personal Information may be collected in connection with any of the Sites.
+ ”Third Parties – Total Treecall” includes persons whose genealogical and other Personal Information is submitted to the us through Total Treecall.
# “Third Parties – Request System” includes persons whose DNA, DNA profile, or other Personal Information is submitted to us by Investigators through the Request System
Notice of Financial Incentive – In connection with certain of our Sites and Services, we may collect, share, and retain Personal Information about participating users as part of these Services, which may be considered financial incentives under the CCPA. For example, we may offer monetary or other compensation (“Compensation”) to users who contribute certain Personal Information to certain Services (“Compensated Services”). The value of your Personal Information to us is related to the costs and expenses associated with making the relevant Compensated Services available to users (including IT, administration, direct costs, third-party costs, and service development costs). With respect to your participation in the Compensated Services, your Personal Information is collected and retained and may be shared with our affiliates and other third parties as described in this Notice, including (1) to administer the Compensated Services, (2) for research and analytics purposes, (3) to improve our Services, and (4) to send you news, updates, and offers by email, postal mail, and text message (in accordance with your communications preferences). You may withdraw from participating in a Compensated Service at any time by contacting us using the designated method set forth in the applicable Compensated Services terms. Please note if you withdraw from a Compensated Service (or you submit a CCPA request to delete your Compensated Service data), your participation in Compensated Services may be terminated, which means, generally, you will no longer be eligible to earn Compensation subject to the applicable Compensated Service terms.
California Shine the Light – Under California Civil Code Section 1798.83, individual customers who reside in California and who have an existing business relationship with us may request information about our disclosure of certain categories of Personal Information to third parties for the third parties’ direct marketing purposes, if any. To make such a request, please contact us at solve@othram.com. Please be aware not all information sharing is covered by these California privacy rights requirements and only information on covered sharing will be included in our response. This request may be made no more than once per calendar year.
Changes
We may change this Notice from time to time, so please be sure to check back periodically. We will post any changes to this Notice on othram.com. If we make material changes to how we treat Personal Information, we will notify you according to applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to our Sites. You are responsible for periodically visiting our Sites and this Notice to check for any changes.
Interpretation
In the interpretation of this Notice, except where the context otherwise requires, (1) “including,” “include,” or “such as” does not denote or imply any limitation, (2) “or” has the inclusive meaning “and/or,” (3) “and/or” means “or” and is used for emphasis only, (4) “U.S.” or “United States” means the United States of America, (5) the singular includes the plural, and vice versa, and each gender includes each other gender, (6) captions or headings are only for reference and are not to be considered in interpreting this Notice, (7) references to any federal, state, local, or foreign statute or law shall be deemed also to refer to all rules and regulations promulgated thereunder, and (8) “Section” refers to a section of this Notice, unless otherwise stated in this Notice.
Contact Us
If you have any questions about our practices or this Notice, please contact us at solve@othram.com