Introduction

This Privacy Policy applies to the DnaNudge service (the “Service”). This document outlines the type of personal data we collect from users of the Service (“Users” or “you”) in connection with the Service and how this data is protected, used and maintained.

The Service is operated by DnaNudge Limited, a company registered in England and Wales, with company number 09705888 whose registered address is at Level 11, The Translation And Innovation Hub, Imperial College White City Campus, London, England, W12 0BZ  (collectively referred to as “DnaNudge”, “we”, “us” or “our” in this Privacy Policy).

Commitment to the protection and security of personal information, including genetic information is of paramount importance to us.

Scope

The purpose of this Policy is to inform you about our privacy practices and to ensure that you understand the purposes for which we process your personal data. The following is a brief summary of our privacy practices.

This Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form which cannot be linked to a living individual (such as anonymised data, aggregated data, or coded data which, in a given form, cannot effectively be used to determine your personal data) ("Anonymised and Aggregated Data").

 

Who is responsible for processing your data?

DnaNudge is responsible for the processing of your personal data insofar as we collect it as part of the Service including personal data we obtain through registration forms or other communications with you, the genetic data we receive from Users for analysis and the genetic reports and product recommendations that we generate through the Service and give to the Users.

Questions and Complaints

If you have any questions or if you wish to make a complaint or have other queries relating to the Service, please write to us to the following address: DnaNudge Limited, Level 11, The Translation And Innovation Hub, Imperial College White City Campus, London, England, W12 0BZ, or by email to: customerservices@dnanudge.com.

Enquiries relating to our use of your personal data should be made for the attention of our data protection officer.

 

The type of personal data we collect and how we process it

Account information

Information about your account can be found in our subscription terms and conditions. To use our Service, you must create an account. To create an account, you are asked to submit details such as name (which may be a pseudonym of your choice), email address and telephone number, age, and a password you create.

Genetic Information

As outlined in our subscription terms and conditions we do not store your DNA. To enable us to generate your DnaNudge test report, users provide a DNA sample using a swab which is inserted into a DnaNudge Cartridge and analysed by the “on the spot” testing unit (NudgeBox). When the test is completed the cartridge containing the DNA sample is destroyed. There is no genetic information in the NudgeBox. Your DNA sample is tested against a location-coded pattern. The NudgeBox sends an encrypted format of the pattern measurement to the DnaNudge Cloud. The encrypted DNA test results are then analysed in our database where the general relationships between product ingredients, DNA information and certain corresponding traits have previously been stored. Your resulting traits are then sent to your Mobile App and/or DNA capsule so that product recommendations and alternatives are made by either scanning product barcodes or by a search facility on the App. Accordingly, there is no genetic code or genetic variation data transmitted or stored on the User’s DnaBand or DnaNudge App or in the DNA Cloud, only data relating to your traits that are relevant to product recommendations.

Note that only information such as product-recommendations can be shared between Users.

Information given by Users

This includes information that we may ask Users to provide from time to time for research processes, quality control and to improve the Service. For example, we may collect such information through direct correspondence, surveys, other activities through the Mobile App, Capsule or the website etc.

Device and Browsing Information

From time to time, we may use automatic data collection technologies to collect anonymised product data for research, development and statistical purposes.

 

The purpose for which we use your data

We use personal data for the following purposes:

 

The lawful basis for processing users’ personal data

The processing of your personal data is lawful based on the following:

 

When do we disclose your personal data to third parties?

Examples of cases where personal data may be shared with Related Parties (subsidiaries, parent companies and other affiliates, our subcontractors, service providers, representatives and agents that provide services to us or act for or on our behalf)

We also reserve the right to disclose and transfer personal data to other entities in connection with the sale or transfer of our business or those business activities relating to the Service.  We will ensure that such acquirer will continue to process the personal data in accordance with this Policy (as it may be updated from time to time).

Other circumstances in which your personal data may be used or disclosed include the following:

 

 

Transfer of personal data across borders

We may use servers and cloud services in other countries and may transfer the anonymized product/ DNA trait data to other countries for the purpose of storage and data management. Our Related Parties may have access to our database in different countries including, without limitation, the UK, the EU and the USA. We ensure that when personal data is transferred across borders, we do so in compliance with the law including (in the case of data exported from the EU) by putting in place, as between us and the party receiving the data, contractual terms for the protection of the interests of data subjects in the form approved by the European Commission. 

 

How do we protect your personal data?

We use a range of technical and organisational measures to protect your personal data including the following:

We cannot guarantee that these protections will always successfully prevent unauthorised access to, corruption or loss of personal data. Please bear in mind that transmissions over the Internet are not completely secure, and information you send to or from this Service may be accessible by others. More specifically, electronic communications sent to or from the Service may not be secure.  

We ask that you do not share your account password or log-in credentials with anyone. Please contact DnaNudge immediately if you suspect unauthorised use of your account.

 

 

How to access, edit or delete your information

You can contact our customer care team to request access to, edit or delete any personal information you have provided to us. We cannot guarantee we will be able to grant a request to change information, for example, if we believe granting such a request would violate the law or cause the information to be incorrect. It may not be possible to retrieve, remove or correct data from any database where the data had been de-identified and/or aggregated.

 

Account closure

If you no longer wish to receive the Service, you can close your account by sending an email request to customerservices@dnanudge.com. Your account including registration information and user profile will then be deleted.

 

Children’s Data

Children under the age of 16 require the consent of their parent or legal guardian to carry out the DNA test. The information in this Privacy Policy applies to children as well as adults.

 

Your legal rights

Users have the following legal rights in respect of their personal data:

  1. The right to require us to advise you of the categories of your personal data that we process, the purpose of any such processing, the identity of third parties who receive your data from us, the period for which your personal data is stored and whether any automated decision-making processes are being used in relation to your personal data. You also have the right to ask for a copy of your personal data records.

  2. The right to require us to rectify inaccurate personal data records.

  3. The right to request the erasure of your personal data records. You have the right to require us to erase your personal data records where:
    • The data is no longer necessary in relation to the purpose for which it was collected, such as where you choose to close your account (in which case, it is our policy to delete your data even without your request);

    • Where the processing of the data is based on your consent and such consent is withdrawn (provided that the other circumstances described in the sections ‘When do we disclose your personal data to third parties?’ and ‘Lawful basis for processing users’ personal data’ above no longer apply); or

    • You object to the processing of your data and there are no overriding legitimate grounds for justifying the data processing.

  4. The right to restrict the processing of your personal data in certain circumstances (for example, where an objection has been raised and is being investigated); and

  5. The right to object to the processing of your data in certain circumstances.

 

 

Links to third party sites and social media services

This policy applies only to the processing of personal data by us in connection with the Service. It does not apply to any processing activities carried out by operators of website, social media services such as Twitter or Facebook or other third parties whose sites or services may be accessible via our Service.  When you follow a link from the Service to any third-party site or service you are being transferred to a website or online service operated by someone other than us. The operator of that website or service will have a different privacy policy. We do not share your personal data with these third-party websites or services, and we are not responsible for their individual privacy practices. We encourage you to investigate the privacy policies of any such third-party sites or services.

 

Privacy Policy changes

This Policy was last changed on 22 January 2020. If we make changes to the Policy, the new version will be posted on the Service. We may change, modify, add or remove portions of this Policy at any time, and any changes will become effective immediately upon being posted unless stated otherwise.