This Privacy Statement explains how ORG SERVICES LIMITED, a company registered under the laws of England, having its registered office at 15 Hanover Square, 6th Floor, London, W1S 1HS, United Kingdom (the “Company” or “we”) collects, processes and stores your Personal Information as you use our website www.originalgene.com
(the “Website”), Products and Services.
Personal Information is information that can identify you, such as your name, email or street address, or it may be information that could reasonably be linked back to you, including your Genetic Information. This Privacy Statement describes our practices for collecting, storing and processing your Personal Information and the controls we provide you to manage it within our Services.
This Privacy Statement forms an integral part of our Terms and Conditions (“T&C”). Capitalized terms herein, unless otherwise defined, shall have the meaning ascribed to them in the T&C.
2. Account Creation and Your Engagement with OriginalGene Services
The Personal Information required to create an account with OriginalGene is limited to your name, an email address, and a password. Access to OriginalGene records requires additional personal information, including payment details, and, for the DNA test, the test code (when you activate your DNA test kit) and a saliva sample from which our laboratory partners can extract Genetic Information.
Account creation also requires you to agree to our Terms and Conditions and this Privacy Statement.
By creating an account, you are confirming that you understand that OriginalGene will collect, process, and share your Personal Information (including your Genetic Information if you have taken the DNA test) as described in this Privacy Statement and in any other documents referenced in this Privacy Statement.
At any time, you can request the Company to delete information you have uploaded into your account, including your Genetic Information. You can also delete your entire account. Please see Section 10 below for specific details about deleting your data.
3. What Information Do We Collect From You?
The table below describes the information we collect from you to provide the Services and to sell you the Products. In this Privacy Statement, we refer to data that relates to you as “Personal Information.”
|Account Registration Information
- Your name and surname
- An email address
- A password that you provide us when you create an account
- A mobile phone number that you may voluntarily provide so we can notify you of DNA test result status, other updates you agree to, or when you contact our customer support services
|Credit Card/Payment Information
- Payment information, such as your credit card number, and your billing and shipping address, when you purchase our Products and Services.
|DNA Kit Activation Information
When you activate a DNA test kit, we collect
- Your DNA test kit code
- Your biological sex
- Your year of birth
- We extract your DNA from your saliva at one of our partner laboratories when you send it back to us in the tube provided with your DNA test kit.
- We convert your DNA into machine-readable code (“DNA Data”), which is used to provide you with the information about you in respect of which you have requested DNA testing.
- A note about your DNA and Saliva: Once our laboratory partner has produced your DNA Data, the DNA and saliva (also referred to as “biological samples”) may be stored so that they can be available for future testing and/or where the relevant laboratory is obliged to store such data for regulatory reasons. Sections 8 and 10 below describe how you can control both your DNA Data and your biological samples.
4. What Information Does OriginalGene Collect Through Your Use of the Services?
|Computer and Mobile Device Information
Information about how you access our Services, including the website you visited before and after OriginalGene Website.
The Internet protocol (“IP”) address of your computer, mobile device, or the proxy server that you use to access the Internet, in addition to other technical information, such as:
- Your computer operating system;
- Your web browser;
- Your mobile device identifier provided by your mobile device operating system and your mobile operating system.
- The name of your internet service provider or mobile carrier.
|Information from Cookies and similar technologies
|Information shared through social media features
||If you interact with social media through the Services, for example “Like,” “Tweet,” or “Follow Us” links to sites such as Facebook, Twitter, or Instagram, we shall collect these interactions and whatever account information these services make available to us.
Your interactions with these features are governed by the privacy statement of the applicable third-party company.
|Information from your use of the Services
||Information about your use of the Services, such as when you search or access records, which pages you view or links you click on.
5. Information We Collect From Other Sources
|Information from Third Parties
We may receive information about you from third parties. For example, we may supplement the data we collect with demographic information licensed from third parties in order to personalize the Services and our offers to you.
If you purchase a gift subscription, we will collect Personal Information to complete the gift and notify the recipient, such as the recipient’s name and email address.
6. How does OriginalGene use your Personal Information?
|Personal Information (general)
We use your Personal Information to provide, personalize, improve, update and expand our Services. This includes:
- Authenticating your access to the Services and improving our information security;
- Processing your payments for or Services and Products;
- Building new and improving existing Services;
- Issuing surveys and questionnaires for use in the Services, as well as facilitating product development and research initiatives;
- Conducting scientific research;
- Detecting and protecting against error, fraud, or other criminal or malicious activity and enforcing our Terms and Conditions.
- Conducting scientific research;
- Detecting and protecting against error, fraud, or other criminal or malicious activity and enforcing our Terms and Conditions.
We use your Personal Information to communicate with you about the Services, such as when we:
- Respond to your inquiries relating to our Services/Products;
- Alert you of the results of your DNA testing;
- Inform you of changes to Services or new Services;
- Ask you to participate in our media productions or testimonials; and,
- Provide you with information or request action in response to technical, security, and other operational issues.
|Market new products and offers from us or our business partners.
We use your Personal Information to market new products and offers from us. This includes advertising personalized to you based on your interests.
Note: You can control how we market to you by using the unsubscribe link in any email you receive, by changing your account preferences, or by following the instructions in any other marketing communications you receive.
||We use your Genetic Information for the following primary purposes:
- Delivering your test results, DNA matches from our database, and other information to help you learn more about yourself;
- Providing you other insights into what your DNA reveals about traits, personal health and wellness; we may also invite you to participate in surveys and questionnaires (entirely optional) based on your DNA data.
- Conducting scientific and statistical research;
- Improving features and functionality in our existing DNA-related Products, enhancing the customer experience across our Services, improving the quality of our laboratory processes and technology, and building new products and services, including services related to personal health and wellness.
We will seek additional consent from you before we collect and process additional sensitive Personal Information (for example, health history) as part of your interaction with the Services.
8. Your Choices and Access to Your Personal Information
Subject to certain exceptions, you have a right to request access to your Personal Information and to be provided with a copy of certain information you provided in a portable form, as well as to seek to update, delete or correct this information by using the tools described below or by contacting us. Details and options for accessing this information are listed below.
||You can access, update and delete the Personal Information (such as your email address, username, profile information, etc.) that you provide to us at any time in the My Account/Profile sections of your Account at our Website and Member’s area .
||If you do not want us to use your data to serve you targeted ads, you may change your settings in your Account at our Website.
|Genetic Information Download
||Your DNA Data belongs to you. You always have the option of obtaining from us a file with your DNA Data by submitting to us a request to that effect at email: [email protected]
9. What are our retention practices?
Our Services are fundamentally premised on the notion that the personal voyage of self-discovery is not a one-time event and continues over lengthy periods of time—possibly lifetimes. Additionally, and with particular regard to our subscribers and DNA customers who pay us for our Products and Services, the ongoing enhancement of our collections of historical records and DNA features provide benefits and insights to our customers over time. As a result, our retention practices reflect this ongoing value by retaining user accounts on our system until our customers inform us of their desire to delete their data or close their accounts.
|Category of Information
|Account and Profile
||OriginalGene will retain the Personal Information you provide while creating your account and your profile until such time as you ask us to delete it.
||OriginalGene retains your DNA Data as needed to provide you with the features and functionality you purchased (or were gifted), including continuously updated features such as DNA matches, as well as new other features based on your DNA Data.
||In some cases, we may retain usage information (e.g., visits to sites) in a depersonalized or aggregated form. Once aggregated, this information ceases to be personal and will not be subject to user deletion requests.
10. How can I delete my Personal Information?
You can delete your Personal Information in a number of ways.
||How to delete
||You can delete your Personal Information by logging into your Account Settings at our Website and Member’s Area.
We will consider requests for removal of Personal Information from the searchable indexes of the records we hold on a case-by-case basis in accordance with law.
||Note: If you request that OriginalGene delete your DNA Data, we will delete all Genetic Information, including any derivative Genetic Information from our production, development, analytics, and research systems within 30 days.
To request the destruction of your biological samples, you must contact our Support Team through out Website.
||Please note that there may be some latency in deleting your Personal Information from our backup systems after it has been deleted from our production, development, analytics, and research systems. Also, our laboratory partners may retain information they receive from us in order to comply with laws or regulations that may require them to do so. We may also retain certain information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.
OriginalGene maintains a comprehensive information security program designed to protect our customers’ Personal Information using administrative, physical, and technical safeguards.
The specific security measures used are based on the sensitivity of the Personal Information collected. We have measures in place to protect against inappropriate access, loss, misuse, or alteration of Personal Information (including Genetic Information) under our control.
The OriginalGene Information Security Team regularly reviews our security and privacy practices and enhances them as necessary to help ensure the integrity of our systems and your Personal Information.
We use secure server software to encrypt Personal Information (including Genetic Information), and we only partner with security companies that meet and commit to our security standards. While we cannot guarantee that loss, misuse or alteration of data will not occur, we use reasonable efforts to prevent this.
It is also important for you to guard against unauthorized access to your Personal Information by maintaining strong passwords and protecting against the unauthorized use of your own computer or device.
12. Data Transfer and Privacy Shield Notice
Any transfer of your Personal and Genetic Information between our EU-based company and our U.S.-based laboratory counterparties for processing in the United States is conducted pursuant to established transfer mechanisms such as Standard Contractual Clauses or Privacy Shield.
You can request a copy of any standard contractual clauses relating to your Personal Information that we may have executed by contacting us using the details below.
13. Changes to this Statement
We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Statement, such as posting a notice through the Services, on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using the Services.
We will also notify you of non-material changes to this Statement as of their effective date by posting a notice through the Services, on our websites, or sending you an email. Your continued use of our Services after notice of non-material changes means that you consent to the updated Privacy Statement.
If you object to any changes, you may delete your account as described in Section 10.
14. Legal basis for processing personal information of EU residents.
Where you have consented to data processing, your consent provides the legal basis to process your Personal Information. We rely on your explicit consent to process your Genetic Information. You have the right to withdraw consent at any time. Please note that your withdrawal of consent to collect and process your Personal Information will not affect the lawfulness of processing your Personal Information based on your consent before you withdrew your consent.
We may also process your Personal Information on the basis of contractual necessity to perform a contract we have with you. For example, we process your credit card details when you provide them in order to use our Services or purchase access to premium features such as our DNA testing services.
We may also process your Personal Information on the basis of our legitimate interests, including in providing and improving the Services. For example, OriginalGene has a legitimate interest in understanding your login history so we can assess your interaction with our Services. We also have a legitimate interest in providing and developing interesting features to provide to our Users. We use your Personal Information to keep our Services safe and secure and we do so as it necessary to pursue your and our legitimate interests in ensuring that our Services are secure, and to protect against fraud, spam and abuse.
Where we rely on legitimate interests to process your Personal Information, you have the right to object to such processing (meaning that you can ask us to stop). You can use your Privacy Settings in your account on our Website to control certain ways in which we process your data. You can also contact us, using the details below, to object to other forms of processing.
15. Identity and Contact Details of the Data Controller
ORG SERVICES LIMITED, a company incorporate under the laws of England, having its registered office at 15 Hanover Square, 6th Floor, London, W1S 1HS, United Kingdom, is your data controller.
Contact Details of the Privacy Officer:
Email: [email protected]