Our Privacy Statement

1.1 This Privacy Policy sets out how DNApal. with registered office The 1929 Building, Merton Abbey Mills, 18 Watermill Way, London, UK, SW19 2RD (“DNApal”) and its subsidiaries, related bodies corporate and franchisees (collectively referred to in this policy as “DNApal”, “we” or “us”) protects the privacy of your Personal Information (as defined below) and the basis on which any Personal Information we collect from you, or that you or third parties provide to us, will be processed and used by us.

1.2 DNApal is committed to ensuring that your privacy is protected and to ensuring that your Personal Information is processed in accordance with applicable laws and regulations (as amended or replaced from time to time) protecting the privacy of Personal Information in the jurisdictions in which we operate (“Applicable Laws“).  For the purposes of this Privacy Policy, “Personal Information” means information that is about you as an identifiable individual, such as personal health information or other personal information as defined by the Applicable Laws. DNApal will only collect, use, store, disclose and transfer your Personal Information in accordance with this Privacy Policy, any related Privacy Notices and Applicable Laws.

1.3 Please read the following carefully to understand DNApal’s views and practices regarding your Personal Information and how we will treat it.  By using our nutrition and wellness service which provides software applications to read and analyse your genetic test data to provide you insights to personalise your nutrition, diet and exercise, and assist in making it easy to take actions on those insights in your daily life (the “Service”), you confirm that you have read, understood and agree with the collection, use, storage, disclosure and transfer of your Personal Information in accordance with this Privacy Policy and the related Privacy Notice.  If you do not agree or withdraw your consent, you should not use the Service.

1.4 If you are under the age of 18, you must not use the Service or submit Personal Information to us unless you have the consent of and are supervised by a parent or guardian.  We do not knowingly collect information from people under the age of 18 without such consent.

1.5 This Privacy Policy was last updated on, and is effective as of, September 23, 2019. DNApal reserves the right, in its sole discretion, to modify, revise, delete and update this Privacy Policy from time to time.  We will use reasonable endeavours to notify you in advance of any modifications to the terms of this Privacy Policy. If you do not agree with the modifications, revisions, deletions or updates, your exclusive remedy is to cease using the Service. By continuing to use the Service after those changes are made, you shall be deemed to have accepted and agreed to the changes.

2. THE PERSONAL information THAT WE COLLECT FROM YOU

2.1 When you use the Service, we collect the following Personal Information about you:

  1.  Information you give us: You may give us information about you by using the Service, such information may include, but is not limited to:
    1. your name, gender and date of birth;
    2. your email address;
    3. your genetic information from your raw data file or directly from your genetic test provider; and
    4. your behavioural information, such as smoking, drinking or exercise;
    5. Family and / or personal health history 
  2. Information we collect about you:  In order to provide you with our Service, we collect the following information about you from you or third parties:
    1. genetic and biological health information, including information regarding your genetic profile generated by third parties (“Genetic Information”).
  3. Cookies and Mobile Analytics
    1. We and our third-party partners use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to help us recognise you, customise and improve your experience, provide security, analyse usage of our Service (such as to analyse your interactions with the results, reports, and other features of the Service), gather demographic information about our user base, to offer our products and services to you, to monitor the success of marketing Services, and to serve targeted advertising on our site and on other sites around the Internet. We and our third-party partners do not use your sensitive information, such as Genetic Information, for targeted advertising. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
    2. In addition to the above, when interacting with our website, we gather certain information automatically about the website’s users and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you, such as your user profile ID or order number. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.
    3. When you access our website by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
    4. We use mobile analytics software to allow us to better understand the functionality of our mobile application on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any Personal Information you submit within the mobile application.

3.1 WHAT WE DO WITH YOUR PERSONAL INFORMATION

3.1 DNApal (and third party data processors who may be acting on our behalf) may collect, store and process your Personal Information described above for the following purposes:

  1. to administer and operate the Service, and any services and programs provided in connection with the Service, including:
    1. opening your account, communicating with you and implementing your requests;
    2. running our mobile application and website, authenticating your visits, providing custom, personalised content and information, and tracking your usage of our Services
    3. processing and analysing your Genetic Information and other Personal Information; and
    4. providing health, nutritional and wellness analysis and recommendations related to your Genetic Information and other Personal Information, analysis regarding weight gain risk, exercise behaviours, exercise motivation, favourable macronutrient percentages for weight loss, and micronutrient deficiency risks, as well as providing you a targeted point score to allow you to follow certain behaviours to reduce your genetic risk;
  2. to connect you with other individuals using our Service who have similar conditions such as you to allow you and such other individuals to share information, approaches and other information regarding with each other
  3. conduct analytics to improve and enhance our Service;
  4. offer new products, programs or services to you, including through emails, promotions or contests, subject to applicable laws;
  5. for our internal record keeping requirements including collection of anonymized details about use of the Service to compile aggregate statistics or produce internal reports;
  6. to share your Personal Information with selected third parties in accordance with Section 4 of this Privacy Policy;
  7. to provide you, or permit selected third parties acting on DNApal’s behalf to provide you with information by SMS, e-mail or other electronic messaging service about goods or services we feel may interest you including, without limitation brochures, details of promotions, events, new products and services, subject to applicable laws;
  8. to the extent we have a legal obligation, right or duty under the Applicable Law to use or disclose your information (including for crime and fraud prevention and related purposes); and
  9. to anonymise and aggregate the Personal Information (including Genetic Information) for any other purposes, provided that no identifiable personal information can be readily identified.

3.2 We will only retain your Personal Information for as long as reasonably necessary having regard to the purposes for which your Personal Information was collected and will delete such Personal Information after the expiry of such period unless otherwise required under the Applicable Law and any anonymised and aggregated information will be retained by DNApal. 

4. DISCLOSURE of your PERSONAL information

4.1 DNApal may share your Personal Information that it collects from you or that you provide to DNApal with selected third parties for the following purposes:

  1. to operate the Service and provide the programs in connection with the Services or any other purposes as set out in paragraph 3.1 above;
  2. to enforce or apply the Service’s Terms and/or other agreements and/or to investigate potential breaches of such agreements;
  3. to protect DNApal’s rights, property or safety or the rights, property or safety of other users of the Service or others (e.g., for fraud protection etc.); and
  4. to comply with any applicable laws, regulations, governmental and quasi-governmental requests, court orders or subpoenas.

4.2 For greater certainty, your Genetic Information and Personal Information will not be disclosed by us except to provide you with the Service unless we have obtained your express consent to do so. DNApal will not disclose your Genetic Information and Personal Information to insurance companies or marketing agencies without your express consent to do so.

4.3 DNApal may share your Personal Information with, without limitation:

  1. companies that provide statistical analysis services; and
  2. analytics and search engine providers, such as Google Inc, that assist us in the improvement and optimisation of our website.

4.4 DNApal will ensure that third parties who have received Personal Information from DNApal will maintain a comparable level of protection of the Personal Information as set out in this Privacy Policy by using contractual or other means. To the fullest extent permitted by Applicable Law, DNApal excludes all liability arising from the use of your Personal Information by third parties. DNApal can, on request, confirm the name of each third party that Personal Information is, or will be, transferred to. 

4.5 Except as set out in this Privacy Policy, we will not disclose, sell, distribute, rent or lease your Personal Information to third parties unless we have your permission or to complete a transaction for you. We do not share your identifiable Personal Information with third parties for their direct marketing use without your express consent.

4.6 In the event that a third party proposes to acquire all or some of our business and/or assets, we may disclose your Personal Information to that third party in connection with their proposed or actual acquisition. In the event that we become insolvent or we are in any similar situation, we may also disclose your Personal Information to third parties as part of a business or asset sale carried out where such disclosure is lawful and compliant with the Applicable Laws.

5. INTERNATIONAL TRANSFERS OF DATA 

5.1 DNApal may transfer and/or store the Personal Information collected from you to our overseas related entities, subsidiaries, related bodies corporate and franchisees in order to provide the Service. It may also be necessary for us to transfer and/or disclose your Personal Information to third parties located in the United Kingdom and Europe or other jurisdictions in connection with the purposes set out in this Privacy Policy.  

5.2 By submitting your Personal Information you consent to the transfer, storage and/or processing of your Personal Information outside the jurisdiction in which the information was originally collected. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. Where we have engaged international third parties to perform services in relation to the Service, we will use contractual or other means to ensure such third parties offer a comparable level of protection in respect of the Personal Information. However, Applicable Laws in some jurisdictions may not provide the same level of protection for your Personal Information as does your home jurisdiction.

6. security

6.1 DNApal has in place security measures to store all Personal Information collected and received securely. We use appropriate technical, organizational, administrative and physical measures to protect your Personal Information contained in our system against accidental damage, deletion, misuse, loss and unauthorized access or alteration.  Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted by a third party to us. Once we have received your Personal Information, we will use various procedures and security features (including by encrypting the Personal Information) to try to prevent unauthorized access, use or disclosure.

6.2 Protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Service. You should not disclose your authentication information to any third-party and should immediately notify us of any unauthorized use of your password. We cannot secure Personal Information that you release on your own or that you request us to release.

7. your rights

7.1 You may access, correct or update some of your Personal Information from our mobile application. You also have the right to access any and all details of your Personal Information that we hold about you by written request and to request rectification or erasure of such Personal Information, if the Applicable Laws allows you to do so.

7.2 You have the right to change your mind about consenting to the use, disclosure and transfer of your Personal Information in accordance with this Privacy Policy by contacting us at the address listed below. If you withdraw your consent for DNApal to process your Personal Information in accordance with this Privacy Policy, DNApal may not be able to provide you with all of parts of the Service.

7.3 You may choose to no longer receive communications from us by replying UNSUBSCRIBE to communications (if any) you receive from us. You may unsubscribe to any email from us using the instructions in the email you receive; this will not stop us from sending emails about your account or transactions with us or other information required for your use of the Service.

7.4 You have the right to make a complaint about a possible breach of the Applicable Laws to us. We will consider any complaints we receive and respond to your complaint within a reasonable period of time. You also may lodge a complaint about the treatment of your Personal Information with the supervisory authority located in you jurisdiction, if the Applicable Laws allows you to do so.  

7.5 You can exercise your rights above by contacting us at the address listed below:

DNApal.me Ltd. (DNApal) is registered at The 1929 Building, Merton Abbey Mills, 18 Watermill Way, London, UK, SW19 2RD. UK Company Registration Number: 12055354