PRIVACY POLICY

Last updated: 25/10/2022

This Privacy Policy applies to your access and use of the Website, the Services, and purchase of Physical products as defined below in the Definitions.

Our Privacy Policy is designed to help you better understand (i) the type of personal data we collect about you; (ii) the purpose of collection and processing of your personal data as well as the legal basis for the processing; (iii) the recipients (or categories of recipients) of your personal data and the purpose of their use of your personal data; (iv) The rights and your choices on your personal data; (v) The way you can conduct us for any matter related to your personal data collected and/or processed by us; (vi) any data transfer outside the EU, (vii) the security measures taken for the protection of personal data, (viii) period during which data are processed. 

To make the policy more user friendly we use “we”, “us”, “our” or “Company” etc. to describe Genelle. When we refer to “you” we mean you as a user/customer of our Website, Services and/or Physical products. 

Genelle is your Data Controller and is responsible for the processing of your personal data in accordance with this policy. Here is our information:

Genelle Genomics Ltd
6 Temasek Boulevard #09-05 Suntec Tower Four, Singapore (038986)
Company registration number: 201715693D
Email: support@genelle.com

1. DEFINITIONS

"Aggregate information" is Genetic and Self-Reported Information that has been stripped of Registration Information and combined with data from a number of other users sufficient to minimize the possibility of exposing individual-level information while still providing scientific evidence.

“De-identified information” is information that has been stripped of any identifying data (for example your name, surname, email) such that you cannot reasonably be identified as an individual.

“DNA Kit” or “DNA Discovery Kit” is a sample collection kit that contains a DNA test to take your inner cheek buccal sample for DNA extraction and processing. The DNA Kit is sent to you in order for us to obtain your genetic information and to be able to provide you with the Services contracted. 

“Genetic Roadmap” is a digital personalized reports of your DNA results prepared based on the Genetic Information and Self-Reported Information, that can include, depending on the contracted Service, nutrition, fitness, skincare, personality and/or health.

"Genelle", means Genelle Genomics Ltd, having its principal place of business at: 6 Temasek Boulevard #09-05 Suntec Tower Four, Singapore (038986), and/or its related companies that operate under the trademark or brand name “Genelle”.

"Genetic Information" is information regarding your individual’s genotypes and genetic characteristics, generated through the processing of your DNA samples from inner cheek cells by Genelle or by its contractors (laboratories).

"Personal  Data" is information that can be used to identify you, either alone or in combination with other information, including information such as Genetic Information, Self-Reported information and others.

“Personalised Plans” means customized plans for each user based on the particular genetic analysis, including health, cuisine meal and/or fitness plans. 

“Physical products” means any physical product offered on the Website which can be purchased separately from the Services, such as skin care products or supplements. 

"Registration Information" is the information you provide about yourself when registering for and/or purchasing our Services (e.g. name, last name, email, password, date of birth, sex, address and payment information).

"Self-Reported Information" is all information about yourself as required from Genelle in surveys, forms or questionnaires while signed into your Genelle account in order to provide you with our Services.

“Sensitive Data” means information about your genetic data, biometric data, data concerning health, other health-related information, ethnicity, family history and background information, which may be part of Genetic Information and Self-Reported Information.

"Services” means genetic testing services and any related digital products, services, content and support such as processing payments, shipping DNA Kits to customers, creating customer accounts and authenticating logins, analyzing DNA results, reviewing your genetic results, preparing and delivering the genetic trait reports and plans, amongst others. The scope of the Services depends on the Service you purchase. Our Services may be one-time purchases (such as Starter package) or automatically renewing subscription services, like our cuisine meal and fitness plans.

“Starter package” Genelle offers two enrolment Starter packages: (i) Wellness that includes the DNA Kit, Genetic Action Plans (nutrition, fitness, skincare action plans) and 90 days access to cuisine meal and fitness plans; or (ii) Premium that includes the DNA Kit, Genetic Action Plans (nutrition, fitness, skincare, personality, health action plans) and 365 days access to cuisine meal and fitness plans.

“Subscriptions” means automatically renewing subscription services, like our cuisine meal and fitness plans that are either included for a limited period of time in the Starter package or can be purchased separately without providing your inner cheek sample for genetic analysis.

"User Content" is all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials (excluding Genetic Information and Self-Reported Information) generated by users and transmitted, whether publicly or privately, to or through Genelle.

"Website" means www.genelle.com.

2. LEGAL BASES FOR YOUR PERSONAL INFORMATION PROCESSING

We collect and process your Personal Data based on the following legal basis:

  1. You have given us your consent including the explicit consent in cases where Sensitive Information is collected;
  2. To provide you with our Services that you have contracted or to take steps at your request prior to contracting our Services,
  3. To deliver you with Physical products that you have purchased or to take steps at your request prior to purchasing them,
  4. As we reasonably believe is permitted by laws and regulations and as reasonably necessary to comply with laws and regulations
  5. For our legitimate interests that is not overridden by interests you have to protect the information to protect the security and safety of our company, employees, customers and others.

If you consent to it, we can also use your Personal Data (except any Sensitive Information) for direct marketing purposes, to send you online marketing campaigns and for targeted advertising. We may also use your Personal Data for commercial communication purposes with our users that have submitted an order on our Website, since there is a legitimate interest in processing such data. In this regard, we may use your email for sending you our newsletter, new products, services, promotions, offers related to services or products that you purchased, unless you have opted out from receiving such commercial communication. In these cases, you can request the opt-out by pressing the unsubscribe button in your email or by contacting Customer Care Team.

We might collect publicly accessible information about you for the purpose of being able to carry out marketing activities. You can always opt-out from receiving any marketing communications at any time by contacting our Customer Care Team. 

We understand and respect the sensitive nature of the Personal Data you may provide to us, including information about your genetic characteristics, health conditions and social profile, etc. To that end, we strive to be transparent in our collection, use and disclosure of this information and will never share your Sensitive Information Data with third parties, unless we have obtained your explicit consent priorly to do so. We are committed to providing a secure and safe environment for our Services.

In general terms, we use your Personal Data to provide you with our services at the best quality, including:

  1. Creating and operating customer accounts: giving you access to functions and services of your member account, using services/functions of your account, managing the account, authenticating logins.
  2. Receipt, development, performance and execution of the order placed on the Website: submitting orders, transmitting orders to the Affiliates or other partners, registering orders, processing and managing payments, transmitting data to payment providers, performance and operation of requests for money return, transmission of requests for cancellations, returns etc. received form customer care to the Affiliates or other partners, contacts with client for related to the delivery of the orders matters, operation of fraud detection mechanisms, operation and management of coupons, discounts and other loyalty schemes.
  3. Providing Services: shipping DNA kits to customers, analyzing inner cheek samples and extracting DNA, collecting information through surveys, such as Lifestyle Questionnaire, delivering DNA Reports and Genetic Action Plan, preparing cuisine meal and fitness plans, communicating with you, implementing your requests.
  4. Allowing purchases of Physical products: shipping Physical product to customers, communicating with you, implementing your requests. 
  5. Customer care and management: communication initiated by the customer (via email or call center, or in multimedia e.g. viber or other means e.g. social media),  communication at the request of the customer, customer care in general for matters related to your use of the Website, its services and its products, your account, the programs, the guarantees we may provide, the social media of the company, complaints or clarifications, exercise of consumer rights and / or rights deriving from applicable law, overall management and optimization of user experience and service on our Website, resolve disputes
  6. Website operation: hosting our Website, authenticating your visits, providing custom, personalized content and information, and tracking your usage of our Services; conducting analytics to improve and enhance our Services, which includes fixing bugs or issues, analyzing the use of our Website to improve the customer experience, developing new products and services, identifying usage trends; monitoring, detecting, investigating and preventing prohibited or illegal behaviors on our Wesbsite, to combat spam and other security risks.
  7. Business analysis and improvements: for unceasing Application and Service operation, for technical excellence and security of transactions, for optimization of technical systems, for addressing technical issues, for compiling reports and keeping data.
  8. Advertising & Marketing: management registration in newsletter recipients list of the Company, to send newsletters generic and personalized, to send marketing communication via email, sms or other multimedia, push notifications etc., data analysis and customers segmentation in accordance to buying behavior and preferences, operation and management of coupons, promotions and discounts., exploring the degree of satisfaction of the user from the provided products-services of the Company.

3. WHAT PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT

1. Registration Information

When you register an account with us or purchase/redeem our Services or Physical products, we collect personal data you provide about yourself. More precisely we collect the following information: 

  • Name and Surname: is used for opening an account, to identify you to us, for personalization of the Services and for delivery of your DNA Kit and Physical products (supplements, skincare, etc.).
  • Email: is used for registration, identification account, getting in contact with you, to restore your login details when you have forgotten your password, to provide you with status updates (e.g.: tracking of the test results), send you invoices, yo send you the confirmation of the order, confirmation of withdrawal in case you have exercised the right electronically (see ToS), send you an activation code from our authorized affiliates or other partners, and, if you have consented to it, for marketing.
  • Billing address: is used for delivery of your DNA Kit and Physical products (supplements, skincare, etc.) and tracking the status of the shipment and, if you have consented to it, for marketing materials. If you purchase our Services via our Referrers that have DNA Kit stock and they hand in the DNA Kit to you directly at the moment of purchase, your billing address will be collected in case the laboratory cannot process your DNA sample and we need to send you a replacement DNA Kit. 
  • Region: is used to identify the region where the user is located. Before creating an account or purchasing our Services, you will have to select your “region”.
  • Date of Birth: is used to identify your age and verify that you are of legal age to contract our Services. User’s age will also be used in calculating the cuisine meal and fitness plans (if such Services are contracted by the user).
  • Genetic sex: is used to provide you with genetic reports, as well as cuisine meal and fitness plans (if such Services are contracted by the user). Since we provide genetic  services, the sex chromosomes (X and Y) are important for us to consider in our reports. 
  • Demographic data: is used for market analysis, product analysis and development, and for marketing purposes.
  • Payment information: is used by Foxycart, our external service payment provider located in the US, to process the payment for the Services and, if the subscription plan is selected, automate the payments. Genelle processes the payment details for the purpose of collecting payments, however, since the clearance takes place at Foxycart, Genelle does not store your payment information, unless you explicitly consent to it where such option is given to you

2. Self-Reported Information

If you subscribe to our Services, you have the option to provide us with additional information, which may be part of Sensitive Information, about yourself through surveys or questionnaires. For example, the information you reported through the Lifestyle Questionnaire will be used to provide you with cuisine meal and fitness plans (if such Services are contracted by the user) and supplements and skincare products (if such are purchased by the user). The questionnaire collects information about your personal lifestyle, your height, weight and dietary preferences, amongst others. The Lifestyle Questionnaire information is also used by Genelle to further customize your genetic reports. We may also use reported demographic data for market analysis, product analysis and development, and for marketing purposes. 

3. User Content

You may be allowed to create and post or upload content in your user account. Any such as data, text, software, photographs, graphics, messages, or other materials that you create or provide to us through your Genelle’s account will be processed by Genelle. For example, users can upload their photograph to their user account if they wish and this information will be processed by Genelle.

4. Customer Service

We use Personal Data to provide you with our Customer Service such as your name, surname, payment information, email, purchase data, etc. 

We collect information when you contact our Customer Care Team or correspond with us about our services, products or general questions pre and post purchase. We use such information to track and react to your query, investigate any infraction of our Terms of Service, Privacy Policy, or relevant laws or regulations, and analyze and improve our business operations.  

5. Genetic Information (Sensitive Information)

To use our genetic testing services, you must purchase a Starter package (that includes a DNA sample collection kit, certain Genetic Action Plans depending on the Package and temporal access to meal and fitness plans). As part of the services, you must perform a DNA test and collect a DNA sample according to the instructions provided and ship your inner cheek sample to our third-party laboratory according to the address provided to you either in the instructions package or in your Genelle account.

Each DNA Kit has a unique barcode that will associate you with your inner cheek sample and is needed to provide the laboratory services. The unique barcode identifies you to us but not to our third-party laboratory. Our third-party laboratory will receive the DNA sample with the unique barcode (without any other identifying information) and your sex. DNA will be extracted from your inner cheek sample for analysis. After analysing, the third-party laboratory will send scientific rough data to Genelle, who will produce a DNA report and certain Genetic Action Plans according to the Starter package you purchased. The laboratory will retain the DNA sample only for the maximum duration permitted under applicable law or regulation after which point it will be destroyed. In particular, the laboratory will regularly dispose of the DNA samples within three months when samples have been analysed at the laboratory and genetic data has been successfully delivered to Genelle. In this case Genelle will act as a Data Controller and the third-party laboratory as a Data Processor. We have a Data Protection Agreement in place between us and the third-party laboratory to protect your privacy rights. 

6. Session and other Cookies

We make use of browser cookies and similar automated means of data collection technologies to enhance your experience of visiting the Website, for example, to avoid displaying certain messages to you more than once, to save your login details so you won’t need to re-enter them each time you wish to log in, or to remember the display language or region you previously selected so you won't need to select it each time you visit the website, to identify your device when accessing the acount. You can disable or delete cookies from your computer if you wish. Please be aware that certain parts of our service may not work correctly or at all if you do so. For more information about our use of cookies and similar automated means of data collection, and how you can choose to disable or delete cookies, please see our Cookie Policy. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.

4. INFORMATION WE SHARE WITH THIRD PARTIES

1. General service providers 

We share the information described above in Section 3 with our service providers, as necessary to provide their services to us. Service providers are third parties (other companies or individuals) that help us to provide, analyse and improve our services and products. 

For example, we use third party platforms to process payments from you, to provide us with cloud storage services, to assist us in marketing and advertising, consumer research analytics, development of new algorithms and services, fraud prevention, security and the processing of customer support requests. 

In the case of DNA Services, we use third-party logistic companies to deliver you the DNA Kits and also work with third-party laboratories and contractors to process and analyse your inner cheek sample for purposes of generating your Genetic Information. We also use we use third-party logistic companies to deliver you the Physical products purchased. 

2. Affiliates 

When you purchase our Services via our authorized Affiliates (third party independent businesses that refer users to Genelle Services), we receive information from the Affiliates about your name, surname and email address, which they enter into Genelle’s internal Affiliate system when they enroll users by sending a personalised email inviting the customer to sign up to Genelle via their unique URL. Affiliate in this situation collects and processes your information (name, surname and email) in order to be able to send you the personalized email invite and refer you to our Website (via unique URL code) where you can purchase our Service. Genelle is the Data Controller for the first and any subsequent sale order. 

We do not share any other information about you with our authorized Affiliates. In case you would like to grant access to the Affiliate via which you purchase our Services to your Personal Data (including Sensitive Information), a separate consent mechanism will be implemented so you can give your informed and explicit consent for such access.

Affiliates are Independent Controllers in relation to user’s data, for different purposes, not connected with Genelle and the order cycle. If Affiliates offer you their own services or products, please take into account that these will be governed by Affiliates own terms and conditions and privacy policies and Genelle has no responsibility or liability towards you related to those third-party services or products.

3. Other Partners

Genelle can enter into partnership collaboration with third party entities such as resellers, distributors, handling agents and others for the purpose of expanding its products and services sales channels, growth markets or other reasons associated with commercial activity. We therefore may share some or all of your information with other partners, if you accept such information transfer. 

4. Information we share with commonly owned entities. 

We may share some or all of your information with other companies under common ownership or control of Genelle, which may include our subsidiaries, our corporate parent and other related companies that operate under the mark “Genelle”. We may provide additional notice and ask for your consent if we wish to share your information with our commonly owned entities in a materially different way than discussed in this Privacy Policy. The purpose of sharing this information might be for compliance, accounting, tax reasons, or in case we subcontract part of our services to a commonly owned entity, to provide you with the Services or Physical products.

5. Disclosures required by law

Your information may be disclosed in response to judicial or other government subpoenas, warrants, or orders, or in collaboration with regulatory agencies, in certain circumstances. If required by law or in the good faith judgment that such preservation or disclosure is reasonably necessary, Genelle will retain and disclose any and all information to law enforcement agencies or others, in order to: (i) comply with legal or regulatory process or obligations that Genelle may have under ethical and other professional rules, laws, and regulations; (ii) enforce the Genelle’s Terms of Service and other policies; (iii) respond to claims that any content infringes on third-party rights; or (iv) protect the rights, property, or personal safety of Genelle, its employees, its users, its clients, and the public. In such event we will notify you through the contact information you have provided to us in advance, unless doing so would violate the law or a court order.

5. PRACTITIONER'S ACCESS TO YOUR ACCOUNT 

When registering your account with Genelle, you may have an option to consent to allow your practitioner access to your account, including my genetic and health data, to assist you with your DNA results and personalised products. 
In case you have consented and granted the practitioner access to your account, your practitioner will be able to:

  • see your DNA reports,
  • access and modify meal and fitness plans, as well as other future products
  • register your DNA sample
  • track your DNA sample and they will be notified when the DNA results are ready

Your practitioner will not be able to see, access or edit information in your “Account settings” where personal information, payment information, passwords, billing information are managed.

The consent provided for your practitioner to access your account will be valid until you revoke that access. You can revoke access at any time in your “Account Settings”. If you experience any difficulties or need any assistance, please contact support@genelle.com/. You can find more about your privacy rights below in Section 11 “Your Privacy Rights”.

6. RETENTION PERIOD

We will retain your Personal Data only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws. This means that we store your Personal Data for as long as it is required to deliver our Services to you, except where we have a lawful basis for saving it for an extended period of time. We also retain the Personal Data we need for the execution of contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes, for our legitimate business interests, and to prevent harm.

We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. We keep other information, like your Self-Reported or Genetic Information, until you use the tools in your account to delete the data or your account because we use this data to provide you with the Services. 

7. SECURITY MEASURES

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, Genelle uses a range of physical, technical, and administrative measures to safeguard your Personal Data. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.

The Internet is not a 100% secure environment and that means we cannot guarantee the security of the data you transmit to us. Emails sent via the Internet might not be encrypted, so we advise you take special precaution when sending information to us.

Please recognize that protecting your Personal Data is also your responsibility. We ask you to be responsible for safeguarding your password of your Genelle account and other authentication information you use to access our Services, as well as of your email registered with your account where we can send you system emails. You should not disclose your authentication information to any third party and should immediately notify Genelle of any unauthorized use of your password or you have a suspicion that someone has entered your Genelle account. Genelle cannot secure Personal Data that you release on your own.

You acknowledge that in the event that you download your DNA Results: (1) such download will create a copy that is not protected by Genelle’s security and privacy settings; (2) such download and the storage of your DNA results after you have downloaded it, shall all be made at your own risk; and (3) Genelle will not have any control over the downloaded DNA results and shall not be liable to you or to any third party in connection with such download and/or storage.

8. INTERNATIONAL TRANSFERS

Genelle is a company established in Singapore and operates internationally. Therefore, your Personal Data can be transferred, stored and processed in outside the country you reside for the purposes described in the Privacy Policy and may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

Where your personal data is to be transferred to a third country, Genelle will comply with laws about transferring personal data between countries to help ensure that your information is protected everywhere. Genelle uses a range of measures to safeguard information, including the Data Protection Agreements and European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies. Genelle has implemented similar appropriate safeguards with our third party service providers and partners.

9. LINKED WEBSITES

On our website, in our emails and on our social-media profiles, we may have links to other companies, apps or websites that are not operated by Genelle. Genelle does not review or endorse, and is not responsible for, the privacy practices of third parties. We encourage you to read privacy policies of each and every website that you visit.

10. CHILDREN'S PRIVACY

Genelle is committed to protecting the privacy of children as well as adults. Genelle’s Services and website are not designed for, intended to attract, or directed toward children under the age of 18. When creating your account we ask the user to enter his or her date of birth in order to ensure that the users are not under the age of 18. You must also be old enough to consent to the processing of your information in your country.

11. YOUR PRIVACY RIGHTS

You can exercise your privacy rights by following the instructions below or contacting the Customer Care Team at support@genelle.com. Some options to exercise your rights might be provided to you in your Account in section “Data Privacy”. If the option that you are looking for does not appear on your Account, it means it is not available and you will have to contact the Customer Care Team to exercise your rights. We will handle your request under applicable law. When you make a request, we may verify your identity to protect your privacy and security. 

We will not charge you for the exercise of your rights in relation to personal data unless, as required by law, the request for access to information is unreasonable or excessive. In that case, Genelle may charge a reasonable fee under these conditions and we will notify you in case any of such charges are applicable before fulfilling the request.

1. Right to withdraw consent. 

To the extent Genelle requests and you provide your consent to the processing of your Personal Data, you can withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.

2. Right of information and access 

You can ask us to tell you whether or not we are using your Personal Data and provide you with additional information such as what personal data we have about you, what we are using it for, the entities with which we share it, the period for which we will keep your data, and whether we are profiling, among other things. The raw Genetic Information can be downloaded in your Genelle Account Settings. If the feature does not enable you to download the data, contact Customer Care Team and we will do our best to assist you without undue delay.

3. Right of rectification

Our site allows you rectify certain Registration Information within your Genelle Account Settings, and your Self-Reported Information by going to the surveys page, and other information as required by applicable law. If the feature does not enable you to correct, reset or delete information, contact our Customer Care Team and we will do our best to assist you without undue delay. We may reject part or all of your request if responding to your request could adversely affect the rights and freedoms of others.

Please note that you may not be able to delete User Content that has been shared with third parties, though we can work with you to prohibit your data from being shared with third parties in the future.

4. Right to erasure 

Please note that you can request erasure of Personal Data that: (a) is no longer necessary in relation to the purposes for which it was collected or otherwise processed; (b) was collected in relation to processing to which you previously consented, but later withdrew such consent; or (c) was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. If we have made your Personal Data public and we are required to erase such Personal Data, we will take reasonable steps, including technical measures, to inform controllers that are processing any links to or copies or replications of your Personal Data of your erasure request. Our assistance with your request for erasure is subject to limitations by relevant data protection laws, available technology and the cost of implementation.

Further, if you no longer wish to participate in our Services or no longer wish to have your personal data be used, you may close your account via Account Settings or by sending a request to our Customer Care Team.

When closing an account, we will remove all Genetic Information within your account. However, our contracted genotyping laboratory may retain your Genetic Information as required by local law and we may retain backup copies for a limited period of time pursuant to our data protection policies and our legal obligations. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) as long as your account is active or as needed to provide you services, as well as for accounting, audit and compliance purposes.

5. Right to data portability

If we process your Personal Data based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request your Personal Data in a structured, commonly used and machine-readable format. You may also request the transfer of your Personal Data directly to another controller, where technically feasible, unless choosing to exercise this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which alone or jointly with others, determines the purposes and means of the processing of your Personal Data.

6. Right to restriction of our processing 

You can restrict our processing of your Personal Data where one of the following applies: (a) you dispute the accuracy of Personal Data processed by Genelle (for a period enabling us to verify its accuracy); (b) the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; (c) Genelle no longer needs the Personal Data for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; and (d) you have objected to certain processing relying on legitimate interest, pending the verification whether Genelle’s legitimate grounds override your rights. Sensitive Information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will notify you if the restriction is lifted.

7. Right to object to processing. 

Where the processing of your Personal Data is based on consent, contract, or legitimate interests, you may restrict or object, at any time, to the processing of your Personal Data as permitted by applicable law. We may continue to process your Personal Data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

8. Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects on you, except as allowed under applicable data protection laws.

The rights described above may be limited by local laws. If you want to exercise one of the rights, please contact our Customer Care Team at: support@genelle.com. The law gives us one month to respond to you, but we’ll try to respond sooner.

12. RIGHT TO LODGE A COMPLAINT

You also have a right to lodge a complaint with a competent supervisory authority situated in the country of your habitual residence, place of work, or place of alleged infringement. 

If you reside in Singapore, your relevant supervisory authority is: Personal Data Protection Commission. Find contact details by visiting its website. 

If you reside in the UK, your relevant supervisory authority is: The Information Commissioner's Office. Find contact details by visiting its website.

If you reside in Hong Kong, your relevant supervisory authority is: Office of the Privacy Commissioner for Personal Data. Find contact details by visiting its website.

If you reside in the EU, you can find the relevant supervisory authority name and contact details here.

If you reside in the Middle East, please check locally what is your national relevant supervisory authority. 

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change the Privacy Policy at any time and such changes shall be effective from the date of their publication on the website. We will take reasonable steps to let you know about changes via our website or, if you are a registered user, via email. Persons intending to use the Services provided by the Company are always advised to familiarize themselves with the latest version of the Privacy Policy. If you continue to use our website or services after the notification, we will regard this as your acceptance of our privacy practices.

14. CONTACT INFORMATION

If you have questions about this Privacy Policy, please email our Customer Care Team at: support@genelle.com

Genelle is your Data Controller and is responsible for the processing of your personal data in accordance with this policy. Here is our information:

Genelle Genomics Ltd
6 Temasek Boulevard #09-05 Suntec Tower Four, Singapore (038986)
Company registration number: 201715693D
Email: support@genelle.com

The contact details of our Data Protection Officer are the following:

Name, surname: Timothy Crews
Email address: tim@genelle.com
 

NOTICE TO APPLICANTS TO GENELLE PARTNERS SCHEME AND ALREADY AUTHORIZED PARTNERS

Genelle collects personal data of the Partners that apply to the Genelle Partners Scheme via the form available on Genelle’s website. Sections 1 and 6 to 13 of this Privacy Policy apply in their entirety to the personal data collected from the applicants to Genelle Partners Schemes and authorized Partners. Please read those sections carefully. 

Additional terms applicable to personal data collected from applicants to Genelle Partners Scheme and already authorised Partners are listed below. 

Applicants to Genelle Partners Schemes: 

Genelle allows interested businesses to apply to Genelle Partners Scheme by submitting a form available on Genelle website. For the purpose of evaluating the eligibility to become part of the Partners Scheme and for communicating the acceptance or rejection decision, Genelle collects personal data from Partners. 

The personal data processed includes name and surname, email, phone number and address of the contact person to communicate additional information or questions required during the application process and to communicate electronically Genelle’s decision on the acceptance or rejection of the Partners’s application. If we reject the Partner’s application, we will delete your personal information within a reasonable period of time. If we accept your application, we will maintain your personal information and will use it for the purposes described below. 

Authorized Partners:

If the Genelle accepts the applicant Partners to Genelle’s Partners Scheme, Genelle will process Partners personal information for billing requirements, communication of related issues to the Partners Scheme, identification purposes or similar legitimate purposes. To operate within the Partners Scheme, the Partners will be required to create an account. 

The personal data processed includes name and surname, email, phone number and address of the contact person to communicate information about Partners Scheme, as well as billing information and bank account details to make corresponding commission payments.

Sharing of your personal information with commonly owned entities or for the purpose of disclosures required by law

We may share some or all of your information with other companies under common ownership or control of Genelle, which may include our subsidiaries, our corporate parent and other related companies that operate under the mark “Genelle”. We may provide additional notice and ask for your consent if we wish to share your information with our commonly owned entities in a materially different way than discussed in this Privacy Policy. The purpose of sharing this information might be for compliance, accounting, tax reasons, or in case we subcontract part of our services to a commonly owned entity, to provide you with the Services or Physical products.

Your information may also be disclosed in response to judicial or other government subpoenas, warrants, or orders, or in collaboration with regulatory agencies, in certain circumstances.