PRIVACY POLICY

We take your privacy seriously. This Privacy Policy explains how we treat your Personal Data when you are using the Services. Unless specified differently herein, Personal Data should be understood broadly, including also Sensitive Personal Data and Genetic Data. The Privacy Policy does not apply to entities that we not own or control, or persons that we do not employ or manage. All pre-defined (incl. capitalized) terms used in this Privacy Policy should be defined as in our Terms of Service unless expressly defined otherwise in this Privacy Policy.

By accepting this Privacy Policy you consent to the processing of your Personal Data (including Genetic Data and other Sensitive Personal Data) provided to us as described herein.

1. Responsible Person

The Services are owned, operated and offered by GeneWix OÜ, a private limited company incorporated in the Republic of Estonia, registry code 14091673, address Narva mnt 3/9, 51009 Tartu, Republic of Estonia, who is responsible for the processing of your Personal Data.          

2. Collecting Your Personal Data

We may collect the following Personal Data in the following ways:

You may provide us your Personal Data yourself upon:

We also collect certain data by automated means:

Please note that the Personal Data that we collect may also include, either alone or in combination Personal Data and Sensitive Personal Data. First and foremost, the Genetic Data transmitted to us is considered Sensitive Personal Data. Also other information you may choose to provide us may be considered Sensitive Personal Data as it may be related to your state of health or disability, or reveal your ethnic or racial origin. Sensitive Personal Data may also be included in the Results created by us upon analysing your Genetic Data and other Personal Data.

Some Personal Data we collect is necessary for the performance of the Agreement (e.g. the Personal Data provided upon registration), some Personal Data is processed based on your consent (e.g. the data provided upon contacting us or otherwise using the Services, especially Sensitive Personal Data, including Genetic Data). By accepting this Privacy Policy you consent to the processing of your Personal Data (including Sensitive Personal Data and Genetic Data) you choose to provide to us as described herein. Note that we only require the provision of some Personal Data upon registration or contacting us (e.g. your name and e-mail address). The provision of other Personal Data, especially Sensitive Personal Data, and the consent for the processing thereof, is voluntary. You acknowledge, however, that the Results and the accuracy thereof depend on the Personal Data you provide us.

You have the right to withdraw your consent at any time by notifying us thereof on the contact details below. The withdrawal of consent shall not, however, affect the lawfulness of processing based on consent before its withdrawal.

3. Using Your Personal Data

We may use your Personal Data for the following purposes:

We use your Personal Data for any other purposes only with your prior consent.

4. Service Providers (Data Processors)

We use service providers in order to provide you the Services. Such service providers may also process your Personal Data as data processors for the limited purpose of providing you the Services under the Agreement. However, we remain responsible for your Personal Data and take all necessary measures to protect your Personal Data as required herein and the applicable law. The list of data processors is available upon request.

5. Disclosing and Sharing Your Personal Data

We only disclose and share your Personal Data to third parties and the public without your prior consent if and as provided in the Privacy Policy, our Terms of Service, or the law. We may disclose and share your Personal Data to the following third parties:

You may independently decide to disclose or share your Personal Data with third persons (e.g. friends, family members, doctors, health care professionals, etc.) or the public, including through third-party services such as social networks and third-party applications. Always review the privacy policies of such social networks and third-party applications before sharing your Personal Data, especially Genetic Data and other Sensitive Data. Please note that the Results may include Sensitive Personal Data and you should therefore handle the further distribution of the Results with care. We are not responsible for when you yourself decide to disclose and share your Personal Data to third parties or the public.

6. International Data Transfers

We (including our service providers) do not transfer or store your Personal Data in any third country outside the EU.

7. Data Retention

We only store your Personal Data as long as necessary for the purposes of the collected data and as long as required by applicable law (e.g. for tax purposes). In general, we store your Personal Data as follows:

At the end of the retention period, we permanently delete the data from our databases. Please make sure that you have a copy of the Genetic Data and the Results saved for your own purposes if needed. Please note that deleting the data from our backup databases may take a bit longer.

8. Security

We implement appropriate organisational, technical and physical safeguards to protect your Personal Data against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access and against all unlawful forms of processing.

Regardless of the foregoing, you should also exercise proper care and security measures yourself and prevent any unauthorised persons from accessing your device containing your Personal Data. You should be especially careful in protecting your Sensitive Personal Data, including Genetic Data, as disclosing thereof may bring about serious consequences for you.

9. Your Rights

You have all the rights of a data subject as provided in the applicable law. This includes the right to obtain information and Personal Data concerning you and to demand the correction of inaccurate Personal Data. If processing of Personal Data is not permitted on the basis of law, you have the right to demand termination of the processing of the Personal Data, termination of the disclosure or enabling access to the Personal Data and/or deletion or closure of the collected Personal Data. You also have the right to turn to the Data Protection Inspectorate or the court to safeguard your rights.

Please note, however, that this does not apply to any processing done by any other entities besides us. You should familiarise yourself with the data processing practices of any other entities that process your data, including your rights therein.

10. Direct Marketing

We and our partners only send you direct marketing messages upon your prior consent. You have the right to refuse from receiving any further direct marketing messages at any time by clicking on the ‘unsubcribe link’ at the end of each message or by contacting us at: info@genewix.com. The list of our partners who may also send you our or their own direct marketing messages is available upon your request.

11. Changes to this Privacy Policy

Should we decide to make changes to this Privacy Policy we will notify you thereof as provided in the Terms of Service. Such changes may be a result of changes in the applicable law or in our data processing practices.

12. Personal Data in the User Content

Note that if your Content includes any personal data of others, you are solely responsible for such personal data and considered the data controller thereof. We, on the other hand, act in the capacity of the data processor as regards such personal data.

13. Contact

If you have any questions, comments, complaints or requests related to the Privacy Policy or the processing of your Personal Data, you can contact us via: info@genewix.com.