Privacy Policy

Effective Date: 12/2/2025

This Privacy Policy describes our policies on the collection, use, and disclosure of your information.

The Pango Network ("Pango," "we," "us," or "our") is committed to protecting your privacy and advancing open science. This Privacy Policy explains how we handle information, including Personal Data and Research Data, when you use our Pango.Network platform (the "Platform").

1. Introduction and Scope

This policy applies to all information collected through the Platform. It describes the types of information we collect, the legal bases for its processing, how we use and share it, and your rights regarding your data. By using our Platform, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We collect several different types of information for various purposes to provide and improve our Service to you.

A. Data You Provide Directly

  • Research Data: Any genomic sequences, associated metadata (e.g., collection date, location), and other scientific information you voluntarily upload to the Platform. You are responsible for ensuring this data is properly de-identified and that you have the necessary rights to share it.
  • Account and Profile Information: When you register for an account, we collect your name, email address, institutional affiliation, and other information you provide.
  • Communications: We collect information when you communicate with us, such as when you report a problem, submit questions, or otherwise contact us.

B. Data We Collect Automatically

  • Log Data: Our servers automatically record information created by your use of the Platform. This Log Data may include your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, and device information.
  • Cookies and Tracking Technologies: We use cookies and similar technologies to operate and analyze our Platform. Cookies are small data files stored on your hard drive or in device memory. We may use both session cookies (which expire when you close your browser) and persistent cookies (which stay on your device until you delete them). You can instruct your browser to refuse all cookies, but some parts of our Platform may not function properly.

3. How and Why We Use Your Information (Legal Basis)

Our use of your information is grounded in specific legal bases:

  • To Provide the Service (Performance of a Contract): We process your Account Information and User Data to operate the Platform and fulfill our obligations under the Terms and Conditions.
  • For Scientific Research (Public Interest & Legitimate Interest): The core purpose of our Platform is to advance scientific research for public benefit. We process and share Research Data based on our legitimate interest in, and the public interest of, conducting open scientific inquiry into pathogens.
  • To Improve the Platform (Legitimate Interest): We analyze Log Data and usage patterns to understand how our Platform is used, allowing us to improve its functionality, security, and user experience.
  • With Your Consent: In some cases, we may ask for your consent to process your information for a specific purpose. Where you have given consent, you have the right to withdraw it at any time.

4. Information Sharing and Disclosure

We do not sell your Personal Data. We may share your information in the following circumstances:

  • For Open Science: Research Data, along with a limited set of associated metadata, may be made publicly available through the Platform and shared with the global research community, including public health organizations and other scientific databases, to maximize its utility for public health.
  • Service Providers: We engage third-party companies and individuals to perform services on our behalf (e.g., cloud hosting, data storage, and analytics). These third parties have access to your information only to perform these tasks and are obligated not to disclose or use it for any other purpose.
  • Legal Requirements: We may disclose your information if we believe it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security, or technical issues; or to protect our or our users' rights or property.

5. Data Security

We are committed to protecting the data entrusted to us. We implement a variety of administrative, technical, and physical security measures designed to protect your information from unauthorized access, use, or disclosure. These measures include data encryption, access controls, and secure software development practices.

However, please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that your information will be completely secure.

6. Data Retention

We retain your Account Information for as long as your account is active or as needed to provide you with the Services. You may request deletion of your account by contacting us.

Retention of Research Data: To ensure the long-term integrity, reproducibility, and historical record of scientific research, Research Data submitted to the Platform may be retained indefinitely as part of the scientific record. Requests to delete Research Data will be evaluated on a case-by-case basis but may be denied to protect the integrity of the dataset and research findings that rely upon it.

7. Your Data Protection Rights

Depending on your geographic location and applicable law, you may have certain rights regarding your Personal Data, such as:

  • The right to access, update, or correct your Account Information.
  • The right to object to the processing of your Personal Data.
  • The right to request the restriction of processing of your Personal Data.
  • The right to data portability.

Limitations: Please note that these rights are not absolute. They may be limited where they adversely affect the rights and freedoms of others, compromise the integrity of scientific research, or conflict with our legal obligations. To exercise any of these rights, please contact us.

8. International Data Transfers

Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. By using the Platform, you consent to the transfer of your data to the United Kingdom and other locations where we or our service providers operate.

9. Policy Towards Children

The Platform is not intended for individuals under the age of 18. We do not knowingly collect Personal Data from children. If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers.

10. 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 and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes.