Privacy

Sano Genetics Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website, and tell you about your privacy rights and how the law protects you.

Last updated date: 2/2/2024

Table of Contents

Sano’s Privacy Policy

1. Important information and who we are

1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how Sano Genetics Limited collects and processes your personal data through your use of our website. Our website is not intended for children and we do not knowingly collect data relating to children, other than from their parents or legal guardians where they choose to give it to us. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.2 Data Controller
Sano Genetics Limited is the data controller, which means that Sano Genetics is responsible for the personal data we collect from and about you (collectively referred to as “Sano Genetics”, "we", "us" or "our" in this privacy notice). We have appointed a data privacy officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy officer using the details set out below.

1.3 Contact details

Full name of legal entity:

Sano Genetics Limited

Contact details:

dataprivacyofficer@sanogenetics.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.4 Changes to the privacy notice and your duty to inform us of changes
This version was produced in February 2024. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

2.1 Personal data, or personal information
This means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.2 On our website
We collect the personal data of users of our website directly through questionnaires and prompts but also passively, through cookies.

2.3 Collection, use, transfer and storage
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

2.3.1 Identity Data includes first name, last name, username or similar identifier, date of birth, place of birth, place of residence, and gender.
2.3.2 Contact Data includes delivery address, email address and telephone numbers.
2.3.3 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this website.
2.3.4 Profile Data includes your username and password, your feedback and survey responses.
2.3.5 Usage Data includes information about how you use our website.
2.3.6 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.3.7 Special Category Data includes health, race, ethnicity, sexual orientation, and genetics information. We would only collect this with your explicit consent.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

2.4 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

3.1 Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

3.1.1 fill out a contact form;
3.1.2 create an account on our website;
3.1.3 request our newsletter to be sent to you;
3.1.4 give us some feedback.
3.1.5 fill out a survey or questionnaire from us, or one of our research partners
3.1.6 upload your genetic data from a third party, or complete a genetic test provided by us.

3.2 Automated technologies or interactions
This Cookie Policy explains how Sano Genetics (“Company,” “we,” “us,” or “our”) uses cookies and similar technologies to recognize you when you visit our websites at https://sanogenetics.com (“Websites“). It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases we may use cookies to collect personal data, or that becomes personal data if we combine it with other information.

What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, or to work more efficiently, as well as to provide reporting information.

Why do we use cookies?
We use cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance their experience. Our Website uses only essential cookies.

What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enables us to recognize when someone has visited our Websites or opened an email including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

How often will you update this Cookie Policy?
We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?
If you have any questions about our use of cookies or other technologies, please email us at dataprivacyofficer@sanogenetics.com or by post to:

Sano Genetics Limited
3rd Floor, 86-90 Paul Street
London, EC2A 4NE
United Kingdom

3.3 Third parties or publicly available

3.3.1 Publicly available data from genealogy websites;
3.3.2 Publicly available genetic data;
3.3.3 Information from health care providers (only with your explicit consent); and
3.3.4 Genetic data from third parties (only with your explicit consent).

3.4 Technical Data from the following parties:

3.4.1 analytics providers such as Hubspot, Meta and Google based outside the EU;
3.4.2 advertising networks such as Reddit, Meta, and Google based outside the EU; and
3.4.3 search information providers such as Google, Microsoft Bing, and DuckDuckGo based outside the EU; and
3.4.4 customer support and live chat tools, including Intercom that may be based outside the EU.

4. How we use your personal data

4.1 We will only use your personal data when the law allows us to.

Most commonly, we will use your personal data in the following circumstances:

4.1.1 Where we have your consent to using your personal data for a particular purpose.
4.1.2
Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.3
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
4.1.4
Where we need to comply with a legal or regulatory obligation.

4.2 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose One

Purpose/Activity: 
To register you as a new customer

Type of data: 
(a) Identity (b) Contact

Lawful basis for processing including basis of legitimate interest: 
Performance of a contract with you

Purpose Two

Purpose/Activity: 
To carry out a genetic test that you have requested

Type of data: 
(a) Identity (b) Contact

Lawful basis for processing including basis of legitimate interest: 
Performance of a contract with you

Purpose Three

Purpose/Activity: 
To collect other information about you relevant to a research project in which you have requested to participate    

Type of data: 
(a) Identity (b) Contact

Lawful basis for processing including basis of legitimate interest: 
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (Good Clinical Practice)

Purpose Four

Purpose/Activity:
To process and deliver your order

Type of data:
(a) Identity (b) Contact (c) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you

Purpose Five

Purpose/Activity:
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey

Type of data:
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Purpose Six

Purpose/Activity:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data:
(a) Identity (b) Contact (c) Technical

Lawful basis for processing including basis of legitimate interest:
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

Purpose Seven

Purpose/Activity:
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data:
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Special Category Data

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Purpose Eight

Purpose/Activity:
To use data analytics to improve our website, marketing, customer relationships and experiences

Type of data:
(a) Technical (b) Usage

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Purpose Nine

Purpose/Activity:
To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data:
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Special Category Data

Lawful basis for processing including basis of legitimate interest:
Necessary for our legitimate interests (to develop our products/services and grow our business)

Purpose Ten

Purpose/Activity:
To inform you of clinical research studies that you might want to participate on based on your genetic testing results

Type of data:
(a) Identity (b) Contact (c) Special Category Data    

Lawful basis for processing including basis of legitimate interest:
Performance of a contract with you

4.3 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can view and make certain decisions about your personal data use when you are logged into our site: https://portal.sanogenetics.com/account.

4.4 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

4.5 Third-party marketing
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.

4.6 Opting out
You can ask us or third parties to stop sending you marketing messages by contacting us at any time or by selecting to unsubscribe from marketing messages

4.7 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

5.1 Sharing your data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

5.1.1 Third parties who are carrying out various services on our behalf, such as kit distribution, genetic testing, and generating reports whilst using identifiable personal data.
5.1.2 Third parties who are conducting legitimate research activities using anonymised and de-identified genetic and health data.
5.1.3 Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

5.2 Third parties
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International data transfers

We do not transfer your personal data outside the European Economic Area (EEA) without utilising an appropriate international transfer mechanism such as the Standard Contractual Clauses, your consent, an international adequacy assessment or a permitted general situation exists (e.g., serious threat to life, health or safety, establish, exercise or defend legal claims.)

7. Children

Sano Genetics website(s) are typically directed at adults, but in some limited circumstances, we will collect personal data about children.

When doing so we will ensure that the required parental consent has been obtained by parents of children under the age of 14 who are registering on our site.

7.1 We collect a child's personal data when they:

  • Create an account on our website
  • Enter their personal details (e.g. name and contact information)
  • Enter Special Categories of personal data (e.g. health information)
  • Interact or correspond with us by letter, phone, email or via our website.


7.2 Parental Rights

As the parent of the child whose information we are collecting, you have the following rights:

  • To withdraw consent for our further use of your child's information
  • To review what data we hold about your child
  • To amend the data we hold about your child to make accurate
  • To request a copy of the data we hold about your child

8. Data security

8.1 Security Measures
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Sano operates to ISO27001, an international standard on information security management and is audited annually. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.2 Suspected breaches
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

9.1 How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. For example, Good Clinical Practice requires that while we can fulfill your request to delete your data, we are required to keep your study-specific data.

10. Your legal rights

10.1 Personal data rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. The various rights afforded to you are listed in paragraph 11.3. If you wish to exercise any of them, please contact us.

10.2 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

10.3 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10.4 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

11.1 Lawful Basis

11.1.1 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

11.1.2 Performance of Contract means processing your data where 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 such a contract.

11.1.3 Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

11.2 Third Parties

11.2.1 External Third Parties

(a) Professional advisers including lawyers, bankers, auditors and insurers.
(b) HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

11.3 Your Legal Rights

You have the right to:

11.3.1 Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
11.3.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
11.3.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, Good Clinical Practice requires that while we can fulfill your request to delete your data, we are required to keep your study-specific data.
11.3.4 Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
11.3.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
11.3.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
11.3.7 Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.