Last updated: November 2021
2. What types of data we collect?
We may collect two types of data from our Users: Personal Data (“Personal Data“) and non-Personal Data. This section explains the meaning of these data types and how we may collect them.
Personal Data means any information that may potentially allow your identification within reasonable means (for example, email address or name). We may collect your Personal Data in a few ways.
- When you register as a User of our Services: We may collect and store the information you provided us within the process of registration. This may include your full name and email address.
- When you install our mobile application: Subject to your permission, we may process your location data and additional device data from Apple Healthkit, Google Fit or Samsung Health. In addition, we will process the information provided by you as part of the registration flow.
- When you communicate with us: When you send us an email or contact us via our website, we may collect the Personal Data you provided for us. This includes your contact details and any other information you chose to include in your communication.
- When you make a purchase with us: We collect your contact details as well as your payment and shipping information in order to fulfil your order. This information may include your full name, physical address, credit card (or other payment methods) information.
Special Categories of Personal Data
- When you purchase an EndoDNA kit through our Service: We will collect your genetic information (i.e. the DNA test result), name, email address, BMI information, and other information related to your health condition, including your diet, fitness and health.
- When you use the transdermal optical imaging scan feature offered through our Service: We will collect your biometric information and health data resulting from that biometric information (e.g., stress level, heart rate variability, etc.), photo, phone number.
Non-Personal Data can be defined broadly as any information that does not relate to an identified or identifiable natural person. This may include your aggregated usage information and technical information transmitted by your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time, and the website’s domain name from which you linked to the Services). We may collect non-personal data about you as well in order to enhance the functionality of our Services.
As mentioned above, we may collect your data in two ways: first, when you communicate with us and provide us with personal information (such as email address and name); second, when you visit our website or app, we collect information about your use of our Services through the use of tracking technologies. This section focuses on the latter.
Types of cookies
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Our website may use the following types of cookies.
- Essential cookies: Essential cookies are automatically placed on your computer or device when you access our website or take certain actions on our website. These cookies are essential to enable you to navigate around and use the features of our website and app, or to provide a service you requested. We do not need to obtain your consent in order to use these cookies.
- Functionality Cookies: Functionality cookies collect information about the choices you make (such as your user name, language, or the region you are in) and allows us to tailor our website to you. For example, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
- Performance cookies: These cookies collect information about how you use a website, for example, which pages you visit most often. It may also record difficulties you may experience while using the website (e.g., error messages). All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
- Targeting Cookies or Advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.
How can you manage your cookies?
There are various ways in which you can manage and control your cookie settings. Please remember that by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
For other browsers, please consult the documentation that your browser manufacturer provides
You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party web pages:
- The Interactive Advertising Bureau (US)
- The Interactive Advertising Bureau (EU)
- European Interactive Digital Advertising Alliance (EU)
4. Why and how we use your Personal Data?
- To identify and authenticate your access to the Services.
- To market our website, products, and Services including serving you personalised advertisements.
- To support and troubleshoot the Services and to respond to your queries.
- To investigate and resolve disputes in connection with your use of the Services.
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardise or negatively affect the integrity of the Services.
- To investigate violations and enforce our policies (as required by law, regulation, or other governmental authority), to comply with a subpoena or similar legal process, or respond to a government request.
- Processing of Special Categories of Personal Data
Our processing of your Personal Data may also involve “special categories of personal data” (as defined under Article 9 of the Regulation (EU) 2016/679 (“GDPR“)), such as your biometric data or genetic data, as set out in section 2 (“What types of data we collect?”) of this policy. We will process such data for the purpose of providing you with specific services that you request. We will process such data only where you have given your explicit consent to the processing of this particular purpose.
5. With whom we share your data?
- Compliance with laws and law enforcement entities: We may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate so we can respond to claims and legal processes (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities including meeting national security or law enforcement requirements.
6. Your Rights (EU residents)
This section addresses the specific disclosure requirements applying to EU residents under the GDPR.
As an EU resident, you may request to:
- Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data with supplementary information.
- Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
- Request rectification of your Personal Data that is in our control.
- Request erasure of your Personal Data.
- Object to the processing of Personal Data by us.
- Request to restrict processing of your Personal Data by us.
- Lodge a complaint with a supervisory authority.
However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.
7. Transfer of data outside the EU
8. How we protect your data?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorised access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Services or website (and app), and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our website or through the contact details available below.
We do not knowingly collect or solicit personal information from minors below the age of 18, or as otherwise determined under the applicable laws of your jurisdiction (“Minor“). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. In the event that we learn that we have collected personal information from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, please contact us via our website or through the contact details available below.