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We will be transparent with what Information we hold, collect and Process, and, to the extent possible, we will also give you control of the Information you provide us with.
"Anonymised Information" - means any Information that we have anonymised in a manner to result in the Information no longer being able to identify you, whether directly or indirectly, and is therefore no longer Personal Information.
"Data Subject" means the person who is the subject of Personal Information.
"DNAfit", "we", "us" and "our" - means DNAfit Life Sciences Limited (United Kingdom company registration No. 08834823) whose registered address is TMS House, Cray Avenue, Orpington, Kent, BR5 3QB, United Kingdom, email: firstname.lastname@example.org.
“DPA 2018” – means the Data Protection Act 2018
"EEA" – means European Economic Area
"GDPR" - means the European Union's General Data Protection Regulation, 2016/679.
“Processing", "Process" and "Processed" - means any operation or set of operations which is performed on Information, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.
“Pseudonymised” - means replacing the identifying markers of your Information with artificial identifiers to reduce the association between the data subject and the Information during processing.
"Purpose" - means the purposes for which we Process Information.
"Sensitive Personal Information" - means Biomarker Information and any Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under Applicable Law.
"Terms of Service" - means the specific terms that apply to our relationship when we provide you with Services.
"Controller" means a person who (either along or jointly or in common with other persons) determines the Purpose for which and the manner in which any Information is, or are to be Processed.
"Processor" means in relation to personal data, any person or organisation (other than an employee of the Controller) who Processes the data on behalf of the Controller.
DNAfit does not provide direct to consumer Services directly to anyone under the age of 18 (eighteen) years old or as otherwise provided by the rules of Applicable Law, and therefore does not knowingly collect information for such Data Subjects as detailed in the ‘PREREQUISITES’ section of the TOS.
DNAfit will act as a Controller for your Personal Information and may be collected from the following sources:
DNAfit collects the following categories and types of Information:
Device and IP locations collected will determine the regional version of Our Site to be displayed relevant to the country from which you are accessing Our Site. You can manage your location settings from your device or computer but please note if these are switched off, the default version of Our Site (United Kingdom version) will be displayed.
TO PROVIDE YOU WITH SERVICES:
We will process your Information to provide you with our Services, creating your account, dispatching your kit, processing your payment, analysing your Biological Sample and providing your DNAfit results.
PROCESSING OF YOUR SENSITIVE PERSONAL INFORMATION:
We will only Process your Sensitive Personal Information with your prior, written and express consent in order to provide you with the Services in terms of the agreement entered with you.
On receipt at the returns centre, your sample will be validated against your online activation to ensure we have your consent before any laboratory processing begins. Samples returned without activation will be securely held at the returns centre until activation is successful, or for no longer than 3 months when the sample will be securely destroyed.
At the lab, Blood samples are securely destroyed as soon as the analysis is complete due to the limited life of the sample quality. Saliva samples may be retained for a maximum of 4 weeks should any necessity arise to re-analyse during that time, after which the sample is then securely destroyed.
Sensitive Personal Information processed by our lab and further stored on the DNAfit database is maintained in a Pseudonymised format.
MARKETING AND ADVERTISING:
From time to time we may send you communications not directly related to the provision of the Services, but about new services available to you, discounts, events, invite you to participate in relevant DNAfit Research or obtain testimonials for promotional purposes.
RESEARCH AND DEVELOPMENT:
We may Process your Information if you have provided prior, express and voluntary consent for your Biomarker Information and Self-Reported Information to be used in any DNAfit product developent and R&D. This Processing may include sharing your Information with contracted suppliers for Purposes of DNAfit Research and R&D only. We assure you that your information is not sold to any third parties for any other purposes.
For any DNAfit Research you will be contacted beforehand to opt in as a participant for any studies we hope to perform. We will obtain your consent before authorising any scientific publications that includes your Information, even if only Anonymised Information, and for any such scientific publication, this will be subject to full IRB (Institutional Review Board) approval.
IMPROVING OUR PRODUCTS OR SERVICES:
We collect Information when you send, receive, or engage in messaging with DNAfit. We do this to delegate your inquiries to the correct department. We may use your Personal Information to investigate, respond to and resolve complaints and Service issues.
If you interact with DNAfit via telephone, your call may be recorded for training and monitoring purposes.
We also use analytics to determine ongoing service and resource needs and perform quality control checks to maintain best standards of practice.
We will only share your Personal Information with those categories of third parties listed below and under these circumstances or as detailed in the Consent Document:
SELF-DIRECTED SHARING AND DISCLOSURE:
We may provide you with the ability to engage with other Users and share your Information through Our Site and social media channels.
You may choose which Information to share in this manner and may include your Sensitive Personal Information, such as your Genetic Information. Sharing Information in terms of this clause is voluntary and you control what you share. Please do not post any Information that you do not want publicly accessible.
INFORMATION DISCLOSURE AS REQUIRED BY LAW:
Under some circumstances, we may need to disclose certain information when required by law, subpoena, or other legal process or if we believe that disclosure is reasonably necessary.
These details that we may share in terms of this clause may include your Sensitive Personal Information. You understand and accept that DNAfit will only share these details if we are compelled by law to do so, or in good faith believe that such disclosure is necessary in such cases, but this disclosure is not limited to:
Unless prohibited by law or court order, and where time permits, we will let you know when we must share any Information in terms of this clause. We will verify demands as genuine and challenge demands if we feel the request is not appropriate.
CROSS-BORDER TRANSFERS OF INFORMATION:
We make Our Site and Services available to Users globally and similarly, make use of service providers in jurisdictions outside the EEA. Therefore, your Information may be transferred outside the EEA to Processors for various Processing Purposes.
Where we transfer Information to countries outside the EEA, the Processors who Process the Information will be required to enter into a data processing agreement setting out how they may Process the Information and further requiring them to comply with the GDPR and DPA 2018 as well as other relevant Applicable Laws to protect your individual rights. We require all Processors to have appropriate technical and security safeguards and measures to protect that Information.
Providing Personal Information other than Registration Information is voluntary. You can access and control your Personal Information through your MyDNAfit account profile, set your browser settings to determine how we track your web behaviour and opt-out of direct marketing.
You can read more about our legal basis for processing at https://dnafit.zendesk.com/hc/en-gb/categories/200928812-Data-Protection
Subject to Applicable Law, you may have certain rights regarding the Processing of your Information, including:
NOTE: Before we can give effect to these rights, we will contact you to verify your identity and discuss your needs fully before completing your request within 30 (thirty) calendar days from the date of our validation process. Any request to access your Information might be limited and/or subject to a reasonable fee in terms of Applicable Law where the request is manifestly unfounded or excessive.
RETENTION OF INFORMATION:
Upon closure all Information will be deleted from your account and the DNAfit database with the following exceptions:
All Processors will be instructed to delete any Personal Information stored by them with the exceptions as mentioned above.
While we cannot guarantee that unauthorised access, disclosure, misuse or loss of Information will never occur, DNAfit is certified to ISO/IEC 27001:2013 Information Security Management System Standard and frequently reviews and implements physical, technical, and administrative measures to prevent information security incidents and to maintain the confidentiality, integrity and availability of information.
All connections to Our Site and our mobile applications are encrypted using Secure Socket Layer (SSL) technology and internal systems protected with anti-virus software.
Only authorised personnel of DNAfit and contracted third parties have access to Information that is necessary for them to perform their jobs or services.
You must keep your account credentials secure and not share them with anyone. Your password for your account will be used only for online login. We will not ask for your password under any other circumstances. Inform DNAfit immediately of any unauthorised use of your account. Should you wish to reset or change your password, you can do so by clicking on the relevant links on Our Site.
Sharing Self-Reported Information through surveys, or other features on Our Site, is voluntary and done at your sole risk. DNAfit cannot take responsibility for Information that you release or that you request us to release publicly.
In the event of a security incident, DNAfit's internal procedures and those prescribed by the GDPR and DPA 2018 will be followed. You will be notified of any material impacts or direct consequences to you as a User without undue delay
If you do not agree to any changes, you may request to discontinue your use of the DNAfit Services and Our Site.
If you have questions regarding how DNAfit handles your Information, or to request access or deletion of your Information held by DNAfit, please email our Data Protection Officer at email@example.com.
If you are dissatisfied with how DNAfit handles your information or would like to provide any other feedback relating to your experience with us, then please contact firstname.lastname@example.org
In terms of Applicable Laws, you have the right to lodge a complaint about how we handle your Information with your relevant regulatory authority in terms of the applicable law that applies to you.
|Regulatory authority||Contact details|
|The European Commission||
Online complaint procedure: https://ec.europa.eu/info/about-european- commission/contact/problems-and-complaints_en
Address: European Commission, Secretary-General
|The independent Data Protection
Authority per member state
Website listing all DPA's per member state: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
|The Information Commissioner's Office||
Tel: 0303 123 1113