At 24Genetics we know how important is the privacy of your data and we strive to protect it in the most appropriate way. For this reason, we confirm that we have begun to apply the new European Data Protection Regulation (GDPR), although many of the things that are now demanded by us have been done for a long time.
These are the main points in relation to the products and services you have contracted with 24Genetics:
• We will analyze the risks that each data processing can have, which will allow us to decide which security measures should be applied at all times.
• We have appointed a Data Protection Delegate (DPD), who will help us to comply with the data protection regulations advising and supervising all the treatments we perform. In addition, the DPD is at your disposal to answer any questions related to the processing of your personal data.
• At 24Genetics we take all measures at our disposal to prevent cyber attacks. However, if there is a breach in our security that affects your personal data, we will contact the Spanish Data Protection Agency to help us manage the incident and to you if the situation is serious. The measure that we believe is most effective and drastic is not to have our clients’ genetic data on our website, so if we had a cyber attack they could not find such data.
• Sometimes, to provide you with our services, we subcontract to specialized companies (for example, courier companies), which may have access to your personal data to carry out their work. In any case, we apply a rigorous process of selecting suppliers, to ensure that they comply with data protection regulations.
• In the case of your DNA sample, from the moment your sample arrives, it becomes anonymous; that is, no one in our team or in our laboratories or collaborators know which person corresponds to the sample, they only know a code and do not have access to see who this code corresponds to. Once the sample is sequenced, the genetic information remains anonymous and, as if that were not enough, all the genetic information travels encrypted. Only at the time of sending the reports, the codes are crossed with the client to whom they belong. Also, unlike other laboratories, your results and your genetic map are not published online, we do not store the information on our website, therefore they are not available to any hacker.
Taking into account these developments, we have changed our Data Protection Policy. The essential aspects of the data processing we do have not changed, but we have included more information so you can know all the details.
Who is responsible for the processing of your personal data?
The responsible for the processing of your personal data is Bou Trade Labs SL (24Genetics) and address: Paseo de la Castellana 95 Planta 15A, 28046 de Madrid.
As we have said, we have appointed a Data Protection Delegate that will ensure that your data is properly treated and will resolve any doubt, query or suggestion that you may have. You can contact him by sending a letter to his attention, to the address that we have indicated in the previous paragraph or through the email DPD@24genetics.com
How have we obtained your data and what data will we use?
The personal data we treat comes from the interested party.
Some of these data are these:
1.- Email: through it we can communicate with you and keep you informed of the news and updates of the platform. You will always have the possibility to unsubscribe from our emails or even unsubscribe exclusively in certain communications from your user profile.
2.- Name and Surname / Company name: with these data we can invoice our services or that you invoice us yours within the platform. It is important that these data are completely real given the legal and fiscal obligations that we must fulfill.
3.- DNI / NIF: as in the previous case, it helps us to invoice you or to invoice us your services.
4.- Postal / fiscal / social address: it is essential that we know your address for tax and logistic purposes.
5.- Contact telephone: to have a better communication with our advertisers, we can request a contact number and thus offer you a personalized attention.
6.- Payment data: these data are necessary to perform the payment transactions of our services or to pay the amounts against invoice that the editors send us.
The means of payment we use are the following:
7.- Tracking ID through tracking programs: usually each of our users is assigned a tracking ID that helps us understand how it behaves when browsing our website or platform. These data help us improve our user experience and in no case are they used for other purposes.
8.- Number of KIT: is the label that you will paste in the DNA sample and in the documents that you will send us and in which you will remain.
9.- Order numbers: with which we will identify each of your orders.
What are we going to use your Personal Data for?
We will use your Personal Data for the following purposes:
1. Provision of the Service: The processing of your Personal Data is necessary so that we can provide you with our Service, otherwise you will not be able to enjoy it. The provision of the Service includes the following issues:
Manage the creation of your user account and allow you to use or modify it. To enjoy the Service, it is necessary that you create an account and that you identify yourself as a user. You can modify the Personal Data that you have provided at any time through the section “My account” included in the bottom menu of the website. Facilitate you through the email address that you have provided us with the corresponding invoices. Offer you the best care and assistance. Through our Help Center we offer assistance at any time for any doubts, comments, suggestions or incidents related to the Service that you want to ask us.
2. Carry out marketing actions: We will use your Personal Data to send you news, products and promotions related to 24Genetics.
In any case, keep in mind that you can unsubscribe from these communications at any time. To do this, you simply have to click on the “Unsubscribe” link in any of the communications.
3. Improve our service: At 24Genetics we work permanently on the improvement of the Application and the Website and, for this reason, we carry out tests, investigations and analytical studies and develop new products that end up improving the quality of the Service. They allow us to optimize it, make it more functional and adapt it to your needs (by offering, for example, the option to enter your preferences, the chosen configuration or your frequent places). Such works require many times the use of some of your Personal Data.
4. Prevent fraud: To prevent potential fraud against you and against 24Genetics, we have implemented measures that make our Platform a safe place.
5. Consult your opinion about 24Genetics: We find it very useful to know your opinion about 24Genetics in order to make strategic decisions that make us a company aligned with the interests and concerns of our users. Therefore, in some moments we can ask you to respond to a simple survey to know what your perception is about us. Keep in mind that we are interested in knowing the opinion of our users in a statistical way. Therefore, when we receive your opinion we will proceed to pseudonymize it, that is, your answers will only be associated with a code. Afterwards, we will deliver the pseudonymized information to the entity that helps us to carry out these studies so that it can analyze it together with the opinions of many other users and can elaborate a statistical study about the image and perception that you have about 24Genetics.
Of course, you will not have to give us your opinion if you do not want to.
How long will we keep your Personal Data?
The period of conservation of your Personal Data depends on each of the purposes for which we use them. In the following paragraph we indicate you during how long or until what moment we will conserve your data in relation to each one of the purposes:
1. Provide the Service: We will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. While you do not unsubscribe, we will continue to treat your Personal Data for this purpose. Please note that, if there is an issue pending resolution related to the Service, we will try to resolve it before you can unsubscribe.
2. Perform marketing actions: We will use your Personal Data until you request that we stop doing so, regardless of whether you continue to use our Service or have unsubscribed. Keep in mind that you can ask us to stop sending you news, offers and personalized promotions at any time; You simply click on the “Unsubscribe” link in any of our communications.
3. Improve our service and opinion on 24Genetics: We will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. While you do not unsubscribe, we will continue to treat your Personal Data for this purpose.
4. Prevent fraud: As in the previous case, we will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. While you do not unsubscribe, we will continue to treat your Personal Data for this purpose.
Why is it permissible for us to use your Personal Data?
In 24Genetics we only use your Personal Data in a lawful manner, as required by the applicable regulations in the matter. For this, we need to have a sufficient legal basis. Below we indicate what is the legal basis, that is, why is it permissible for us to use your Personal Data for each of the purposes described in the previous section.
1. Providing the Service: Using your Personal Data is necessary to be able to execute the contract that unites us with you from the moment you accept our Terms and Conditions. Otherwise, you will not be able to enjoy the Service.
2. Perform marketing actions: We will use your Personal Data to send you news, offers and promotions based on your profile only if you have given us your consent to do so. The communications that we send you can be made through email, SMS, apps, etc. Remember that you can ask us at any time to stop sending you these personalized communications.
3. Improve our service: We consider that in 24Genetics we have a legitimate interest to carry out tests, investigations and analytical studies that improve the quality of our Service, allow us to make it more functional and adapt it to your needs. In our opinion, this treatment also benefits you directly, since you will be able to enjoy a Service that resolves your mobility needs with greater precision.
4. Prevent fraud: We also understand that in 24Genetics we have a legitimate interest to try to prevent potential fraud related to the Service. This treatment is positive for 24Genetics and also for you, since it will allow us to use procedures that try to avoid fraudulent use of the Service.
5. Consult your opinion on 24Genetics: We believe that we have a legitimate interest to know the perception that you have about 24Genetics, since it will allow us to make strategic decisions that adapt to the needs and concerns of all our users. In addition, we understand that the use of your Personal Data for this purpose is compatible with the provision of the Service.
Will we share your Personal Data with third parties?
Yes. In order to provide the Service with the highest quality, we need to share your Personal Data with, for example, messaging companies and with other collaborating entities of 24Genetics, with external providers that help us with different issues related to the Service and with third parties. The volume and type of personal data that we share is minimal: it is limited to those strictly necessary for the fulfillment of our service, and comply with the rest of its legal obligations. We make sure that all our suppliers that can access any of your Personal Data act in a confidential, loyal and scrupulously complying with the applicable data protection regulations. To this end, we require you to formalize with us specific agreements that regulate the use by you of your Personal Data.
What are your rights in data protection issues?
As a user of 24Genetics, you have a series of rights so that you can decide and control at all times how we use your Personal Data. You can exercise these rights at any time and for free (unless your request is excessive or unfounded). To exercise one of your rights, you simply have to do it through the email firstname.lastname@example.org. So that we can meet your request, we need to make sure that it really is you, so it is possible that we request some type of document; we would also appreciate if you could indicate the right you wish to exercise. If your request does not meet the above requirements, we will ask you to fill it out.
In particular, you have the following rights:
Access. You can ask us to indicate if we are using your Personal Data or not; In case we are using them, we will also transfer additional information such as what personal information we have about you, what we are using them for, the entities with which we share them, the period during which we will keep your data or if we are doing profiles, among other issues.
Rectification. You can ask us to modify some of the Personal Data we have about you to be accurate and up-to-date. In fact, keep in mind that you must keep the Personal Data that appear in your user account updated at all times. You can do it in the “My account” section accessible from the lower menu.
Suppression. You can ask us to delete the Personal Data we have about you when they are no longer necessary for the purpose for which we use them, when you withdraw your consent, in the case that we only try to develop purposes based on it.
Portability. You can ask us to give you directly or to deliver to another entity, whenever technically possible, a structured file, commonly used and readable by a computer system, containing the Personal Data related to the contracted products.
Claim. You can file a claim with the competent control authority on data protection. In your case, the competent authority is the following: Spanish Agency for Data Protection:
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