Privacy Policy

Privacy Policy

 

MYDNA LIFE PRIVACY STATEMENT

At myDNA Life your privacy is a top priority. We committed to being a good steward of your Personal Information, handling it in a responsible manner, and securing it with administrative, technical, and physical safeguards.

We also believe in being direct and transparent when it comes to your data.

We try to use easy-to-understand language to describe our privacy practices to help you make informed choices.

We give you control over the Personal Information you provide to us, including your DNA Data, and how it is used, shared, and retained.

You always maintain ownership of your DNA and DNA Data-you can manage and delete it as described in this Statement.

You may discover unexpected facts about yourself when using our services. Once discoveries are made, we can’t undo them.

You should feel confident and informed about how we use your Personal Information. Our full Privacy Statement is below and we expect you to read it before using our services.

Definitions

What is personal information?

Personal information is information or an opinion, whether it is true or not, about an individual whose identity is apparent, or can be reasonably ascertained, from that information or opinion.

For the purposes of this Privacy Policy, a reference to personal information should be read as including sensitive and health information, unless otherwise specified.

What is sensitive information?

Sensitive information is a subset of personal information which is afforded a higher level of protection. This includes information which relates to an individual’s race or ethnic origin, political opinions or memberships of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association or union, sexual preferences or practices, criminal record or health information about an individual.

What is health information?

Health information is personal information that is also information or an opinion about the physical, mental or psychological health of an individual, a disability of an individual, an individual’s expressed wishes for the future provision of their healthcare, or a health service provided to an individual. Health information also includes personal information that is collected to provide a health service or in connection with the donation of an individual’s body parts, organs or body substances, or personal information that is genetic information about an individual that is predictive of the individual’s health. For the avoidance of doubt, MyDNA Life also treats genetic and biometric information as health information.

How we handle your personal information

The APPs regulate how we may collect, use, disclose and store personal information and how individuals may access and correct personal information which we hold about you.

In order to provide you with the product that you order from us and the services that you have requested, we will need to collect and use your personal information. If you provide incomplete or inaccurate information to us or withhold personal information from us we may not be able to provide you with the products and or services you are seeking.

What personal information do we collect?

myDNA Life collects the following types of Personal Information:

  1. Registration Information – when registering for our services and/or purchasing a product an account will be set up with personal login credentials and will be used to provide you with your chosen services. You will be asked to provide details such as name, contact details and DOB to facilitate service delivery, communicate with you and perform identity verification during inbound and outbound contact;
  2. Payment information – card details will be taken at point of sale using card processing platforms to facilitate purchases. We do not store credit/debit card information as this is held by our card processing providers;
  3. Genetic Information – data related to your genotype generated through the analysis of your cheek swab test. The genetic variants identified enable our product to personalise your experience to your DNA;
  4. Self-Reported Information – Personal Information, including medical conditions, sports-related information, ethnicity, family history, and other information that you enter in surveys, forms or features while entering Our Site. Self-Reported Information may be used, anonymously, in approved myDNA Life research. Should we hope to use research for scientific publication, this would be subject to full Institutional Review Board approval and for this, we will issue a separate Consent Document to gain your permission to participate in these studies at a later date;
  5. Web behaviour information – information on how Users make use of Our Site or MyDNA Life backend portal or MyDNA Life software solutions, which is collected through log files; cookies; and web beacon, analytical and advertising technologies.

This information will be held by myDNA Life as Data Controller. Personal Information will only be used as described in the Privacy Policy and the Consent Document. You will agree to these uses when you formally acknowledge the consent document.

Providing your Personal Information other than Registration Information is voluntary and there are ways you can control your information held by myDNA Life. You can access personal details through your account profile, set your browser settings to determine how we track your web behaviour, opt out of direct marketing and (Research and Development) R&D and choose when to share information on public forums, discussion boards and social media.

myDNA Life does not provide direct to consumer services to anyone under the age of 18 years and therefore does not knowingly collect, process, share or store data for such individuals. All reasonable effort is made to ensure Users are not minors but should we discover a User to be under the age threshold then this would be considered a violation of the TERMS & CONDITIONS and all contracts will be terminated, services revoked and data will be deleted as detailed in ‘ACCOUNT CLOSURE AND DATA RETENTION’.

How do we use your information?

We will use the personal information collected for the purposes disclosed at the time of collection, or otherwise as set out in this Privacy Policy. Your personal information will not be used for any other purpose without first seeking your consent, unless authorised or required by law. Generally, we will only use and disclose your personal information:

a) To provide the products or services you have requested from MyDNA Life;
b) To answer your inquiry;
c) To assist us to make our products and services more valuable to our customers;
d) We may also use the information to offer new products and services to you, inform you about events, invite you to participate in relevant research projects; obtain testimonials for promotional purposes, perform quality control checks and to conduct other R&D.
e) For research and business development purposes; and,
f) Except as otherwise stated in our Privacy Policy and TERMS & CONDITIONS we will never release your information to a third party without asking and getting explicit consent from you to do so such as third parties where we have retained those third parties to assist us to provide products or services you have requested unless we are required to by law. If we are legally required to disclose such information, we will make reasonable efforts to notify you unless we are legally prohibited from doing so.

If we contact you in this way without obtaining your prior consent, we will provide you with the opportunity to decline any further marketing communications;

To receive your myDNA Life service, with the associated analysis from DNA testing, you will be required to create and access a free online account which will be subject to this Privacy Policy.

  • Genetic Information – myDNA Life, under the User’s approval, only uses relevant genetic information and details necessary to generate the User’s products. This information will then be stored securely on the myDNA Life database.
  • Aggregated Genetic and Self-Reported Information – We may disclose to third parties Aggregated Genetic and Self-Reported Information. If we use your information we will take steps to protect your privacy by making this information non-identifiable. To do so, we will take out any details that could identify you with ease, such as name and email address. Meaning that it would not be reasonably foreseeable that the information could be utilised, either alone or with other information readily available, to identify an individual or to connect an individual to any specific data. We will also use contractual means with third parties to protect the privacy and security of your Aggregated Genetic and Self-Reported Information.
    If you have provided consent for your Genetic and Self-Reported Information to be used in any myDNA Life Research and R&D, we can provide this information to third party researchers who will use it for scientific research.
    Giving consent to myDNA Life to use your Genetic and Self-Reported Information for myDNA Life Research and R&D is completely voluntary.
  • Web behaviour information – As you interact with MyDNA Life, web behaviour information will be captured to understand how Users make use of Our Site, for MyDNA Life research, R&D purposes, for quality control to improve our services, and to provide targeted advertising on our products and services. You can block and delete cookies through your device but please note this may alter your overall service experience.
  • Marketing and Advertising – From time to time we may wish to send you details about new services available to you, discounts and event invitation. We may also direct advertising to you via third party sites including social media. Marketing and advertising may be originated from User registration, point of sale or from observation of web behaviour. You will be able to select your preferences in the consent document or you can change your settings at any time by emailing us.
  • Location – We use device and IP locations to determine the regional site to be displayed relevant to the country of the User. You can manage your location privacy settings from your device or computer but please note if these are switched off, the default UK site will only be displayed.
  • Messages – We collect information when you send, receive, or engage in messaging with myDNA Life to delegate inquiries to the correct department and in analytics to determine ongoing service and resource needs.
  • Complaints – We may use your Personal Information to investigate, respond and resolve complaints and service issues.

How can myDNA customers ensure the accuracy of data quality and security in regard to their personal information?

All the information you have entered is collected and stored by us. Registered customers can view and alter this information by logging in with their username and password and accessing their account information. The information includes addresses, and past orders. Access to this information by MyDNA Life staff can only be performed by staff members with a secure password, with access only performed when required. Access to this information is recorded by log files to track unauthorised access and modifications.

We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.

We utilise the internationally recognised Secure Server certificate (SSL) technology to ensure customers’ security. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorised with special access rights to such systems, and are required to keep the information confidential.

MyDNA Life also uses PayPal Gateway Service. This system uses the industry’s best security methods and practises. All credit card numbers are housed within the secure environment of PayPal. We do not record a copy of your credit card details.

How can you correct or remove your personal information

If at any stage a myDNA customer would like their information removed or corrected from our database, we require an email with the username, password and identifying information and the patients file will be deleted from our records. Please send to: help@mydna.life.

Do MyDNA Life use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow cookies in your settings) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We use cookies to help us remember and process the items in your shopping cart.

If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings. Like most websites, if you turn your cookies off, some of our services may not function properly. However, you can still place orders by contacting customer service.

Collection of computer data

When you visit myDNA.life, our company servers will automatically record information that your browser sends whenever you visit our website. This data may include:

  • Your computer’s IP address;
  • The type of browser that you are using;
  • The webpage you were visiting before you came to our site;
  • The pages within myDNA that you visit; and,
  • The time spent on those pages, items and information searched for on our site, access times and dates, and other statistics.
  • This information is collected for analysis and evaluation in order to help us improve our site and the services and products we provide. This data will not be used in association with any other personal information.
  • Google Analytics and Google Adwords Remarketing
  • MyDNA Life uses Analytics Remarketing with Google Analytics, and AdWords Remarketing with Google AdWords to advertise online. Third-party vendors, including Google, may show myDNA ads on sites across the Internet. This could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the myDNA website.
  • myDNA and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on someone’s past visits to our website, and to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our site.
  • Any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.
  • You can opt-out of Google Analytics for Display Advertising and customise Google Display Network ads here.
  • You can also use this Analytics opt out tool here.

Do we disclose any information to outside parties?

We do not sell, trade, or otherwise transfer to outside parties your personal information. This does not include trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect ours or others’ rights, property, or safety. However, non-personal visitor information may be provided to other parties for marketing, advertising, or other uses.

Unsubscribing

Unsubscribing can be initiated at the link at the footer of each email, or by contacting us at help@mydna.life.

Information Disclosure

We will not share your Personal Information with any third party, except with those listed below under these circumstances and as detailed in the Consent Document:

  1. Nutrition information will be passed to our third-party application known as “Meal Planner”;
  2. Current or future MyDNA Life global entities. As the organisation grows, restructuring may take place and it may be appropriate for more than one entity to control and process the data. This Privacy Policy will apply to all MyDNA Life entities unless otherwise stated;
  3. Contracted consultants, suppliers and partners used to undertake fundamental activities to enable us to provide our services, enhance the User experience; and to effectively operate and manage our organisation;
  4. Card processing service providers;
  5. If you have given consent to participate in MyDNA Life Research and R&D projects then research contractors will be granted access to your Genetic and Self-Reported Information online and at MyDNA Life’s offices for scientific research purposes provided that these research contractors will be screened and will be subject to the rules established by MyDNA Life;
  6. We are required by law and by the appropriate authorities to do so (see the section “INFORMATION DISCLOSURE AS REQUIRED BY LAW”);
  7. You have provided us with explicit consent to do so.

Personal Information may be processed, transferred and stored outside the EU and UK for operational purposes. In doing so, relevant data protection regulations and directives will be observed to protect your individual rights and we require all Data Processors to have appropriate security measures to protect that information. You will provide consent allowing information to be transferred to our global teams to enable MyDNA Life to provide the services as requested.

Any Data Processors or other third-party service providers will be required to contractually comply with the principles and objectives of the MyDNA Life policies and will be asked to sign a confidentiality agreement to confirm that data will not be collected, used, shared or stored for any other purpose than that instructed by MyDNA Life at the consent of Users.

Self-directed sharing and disclosure

We provide you with the ability to engage with other Users and share your information through Our Site, including your Genetic Information. Sharing information is voluntary and you control what you share. Please do not post any information you do not want publicly accessible.

Information disclosure as required by law

Under some circumstances we may need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary. These details may include your Genetic Information. You understand and accept that MyDNA Life will only share these details if we are compelled by law to do so, or in the good faith that such disclosure is necessary in such cases but not limited to:

  1. Investigation, prevention or action regarding suspected or actual illegal activities or to assist with government enforcement agencies;
  2. enforce the MyDNA Life Terms of Service;
  3. respond to claims or allegations made by third parties against MyDNA Life;
  4. protect the rights, property or MyDNA Life’s safety and the public.

Unless prohibited by law or court order and where time permits, we will let you know when we must share information. We will verify demands as genuine and challenge demands if we feel the request is not appropriate.

Security

While we cannot guarantee unauthorised access, disclosure, misuse or loss of Personal Information, MyDNA Life frequently reviews and implements physical, technical, and administrative measures to prevent information security incidents and to maintain the integrity of information.

All connections to Our Site and our mobile applications are encrypted using Secure Socket Layer (SSL) technology and internal systems protected with anti-virus software.

Only authorised personnel of MyDNA Life and contracted third parties have access to data.

Please understand that protecting your Personal Information is also your responsibility. We ask that you keep your login credentials secure and not share them with any third parties. Your password for your account will be used only for online login. We will not ask for your password under any other circumstances. Inform MyDNA Life immediately of any unauthorised use of your account. Should you wish to reset or change your password, you can do so by clicking on the relevant links on your my myDNA Life.com portal.

Sharing self-reported information through surveys, or other website features, is voluntary and your liability. MyDNA Life cannot take responsibility for information that you release or that you request us to release publicly.

In the event of a security incident, MyDNA Life internal procedures and those prescribed by the EU data protection regulation will be followed. You will be notified of any material impacts or direct consequences to you as an individual.

Managing privacy settings, correcting personal information and information requests

If there are any changes in your Personal Information, you can correct or update them by accessing ‘Edit Profile’ in your account.

To change any other privacy settings from that specified during registration or consent, you should request this by emailing

You have the right to obtain access to your personal data any time by sending your request via email. We will contact you to undertake identity verification before any disclosure and discuss your needs fully. We will provide this within one month of your request or two months for complex requests.

Account closure and data retention

Accounts will be closed within 30 days upon request of the User. In circumstances where MyDNA Life terminate the agreement as detailed in the TERMS & CONDITIONS, account closure may be immediate but no later than 30 days.

All Genetic Information will be deleted from your account and the MyDNA Life database with the following exceptions:

  1. As stated in the appropriate Consent Document, Genetic Information and/or Self-Reported information that you have provided previously and for which you have given consent to use in MyDNA Life Research will not be removed from ongoing or completed studies that use this information; your data will be removed and not used in any future research;
  2. We keep Registration Information as it is related to your order history for accounting purposes;
  3. Any information required to meet legal or regulatory obligations.

All Data Processors will be instructed to delete any information stored unless subject to the above exceptions.

Your Genetic Information will not be used in any new MyDNA Life research or R&D after your account is closed.

Personal Information will be retained for as long as accounts are active and only thereafter in the exceptions as detailed in this section for as long as necessary.

Business transitions

If MyDNA Life or an entity of MyDNA Life is bought, sold, transferred, spun-out or merged with another entity, you will be given notice and your Personal Information will be transferred along with the other assets. In this case, your information would remain subject to the promises that were made to you in the Privacy Policy until such a time as a replacement Privacy Policy is issued. If you do not agree to new policies and terms, you will have the right to terminate your relationship and close your account.

Privacy policy changes

The Privacy Policy may change at any time in the future. Any material changes to the policy or how we use your data will be notified either via Our Site or services, by notice posted to User accounts or by email to existing Users if appropriate. If you do not agree to any changes, you may request to discontinue use of the MyDNA Life services. Please revisit your account and/or this page regularly and your continued access to or use of Our Site and/or services after effective date will mean that you agree to any changes.

Cross Border Disclosures

MyDNA Life may enter into arrangements with third parties to store data we collect, and such data may include personal information, outside of Australia. MyDNA Life will take reasonable steps to ensure that the third parties do not breach the APPs. The steps My DNA Life will take may include ensuring the third party is bound by privacy protection obligations which are the same (or substantially the same) as those which bind My DNA Life and requiring that the third party have information security measures approved by My DNA Life.

This policy was last modified on 25/04/18.

Contacting us

Questions regarding our Privacy Policy and how MyDNA Life handles your Personal Information, or to request your information held by MyDNA Life or change any of your privacy settings then please email help@mydna.life.

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