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.
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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.
Sano Genetics Limited is the controller and responsible for your personal data (collectively referred to as “Sano Genetics”, "we", "us" or "our" in this privacy notice). We have appointed a data privacy manager 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 manager using the details set out below.
1.3 Contact details
|Full name of legal entity:||Sano Genetics Limited|
|Name or title of data privacy manager:||William Jones|
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 June 2018. 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.
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 and gender.
2.3.2 Contact Data includes billing address, delivery address, email address and telephone numbers.
2.3.3 Financial Data includes bank account and payment card details.
2.3.4 Transaction Data includes details about payments to and from you.
2.3.5 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
2.3.6 Profile Data includes your username and password, your feedback and survey responses.
2.3.7 Usage Data includes information about how you use our website.
2.3.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.3.9 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 purchase a genetic test from us.
3.2 Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
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 Facebook and Google based outside the EU;
3.4.2 advertising networks such as Reddit, Facebook, and Google based outside the EU; and
3.4.3 search information providers such as Google, Microsoft Bing, and DuckDuckGo based outside the EU.
3.5 Contact, Financial and Transaction Data
From providers of technical, payment and delivery services such as Stripe 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/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity (b) Contact||Performance of a contract with you|
|To carry out a genetic test that you have requested||(a) Identity (b) Contact||Performance of a contract with you|
|To collect other information about you relevant to a research project in which you have requested to participate||(a) Identity (b) Contact||Performance of a contract with you|
|To process and deliver your order including: (a) Manage payments fees and charges (b) Collect and recover money owed to us.||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(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|
|To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical (g) Special Category Data||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)|
|To use data analytics to improve Our website, marketing, customer relationships and experiences.||(a) Technical (b) Usage||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)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Special Category Data||Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To inform you of clinical research studies that you might want to participate on based on your genetic testing results||(a) Identity (b) Contact (c) Special Category Data||Performance of a contract with you|
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://sanogenetics.com/settings
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.
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 conducting legitimate research activities using anonymised and de-identified genetic and health data.
5.1.2 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
6.1 We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
7.1 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. 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.
7.2 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.
8. Data retention
8.1 How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil 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.
9. Your legal rights
9.1 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 10.3. If you wish to exercise any of them, please contact us.
9.2 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.
9.3 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.
9.4 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.
10.1 Lawful Basis
10.1.1 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
10.1.2 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.
10.1.3 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.
10.2 Third Parties
10.2.1 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.
10.3 Your Legal Rights
You have the right to:
10.3.1 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.
10.3.2 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.
10.3.3 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.
10.3.4 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.
10.3.5 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.
10.3.6 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.
10.3.7 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.