Privacy policy

The purpose of the Privacy Policy of genEplanet (hereinafter: "Privacy Policy") is to familiarize the users of the services of genEplanet and other persons (hereinafter also referred to as: "individuals") with the purposes and basis of the processing of personal data by genEplanet, Cesta na Poljane 24, 1210 Ljubljana Šentvid (hereinafter: "GenePlanet") and the rights of individuals in this area.

To use any GenePlanet Services, you must agree to this Privacy Policy. You may not use our Services if you do not accept this Privacy Policy.

GenePlanet places particular emphasis on the security of your personal information. All transmitted personal data is handled confidentially and is used only for the legitimate purpose for which it was transmitted. We handle your personal data with utmost care, bearing in mind the applicable legislation and the highest standards of processing. In order to protect your personal data as effectively as possible, we use appropriate organizational measures, work procedures and advanced technology solutions, as well as external experts. We also use an appropriate level of protection and reasonable physical, electronic and administrative measures to protect the collected data from unintentional or unlawful destruction, loss, alteration, unauthorized disclosure or unauthorized access to personal data that has been downloaded, stored or otherwise processed.

At the same time, this Privacy Policy further explains the consent you have given for the processing of your personal information.

In compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter: "General Data Protection Regulation" or “GDPR”), the Privacy Policy covers the following information:

  • contact information of GenePlanet,
  • purposes, bases and types of processing of various types of personal data of individuals,
  • the time of retention of individual types of personal data,
  • the rights of individuals relating to the processing of personal data,
  • the right to lodge a complaint concerning the processing of personal data,
  • validity of the Privacy Policy.

What is GDPR?

The General Data Protection Regulation (EU) 2016/679 ("GDPR") is a regulation in EU law on data protection and privacy for all individuals citizens of the European Union (EU) and the European Economic Area (EEA). It also addresses the export of personal data outside the EU and EEA areas. The GDPR aims primarily to give control to individuals over their personal data collection, storage and processing.

What is Personal data?

Any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

What is Sensitive Personal Information?

The following personal data is considered ‘sensitive’ and is subject to specific processing conditions:

  • personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs;
  • trade-union membership;
  • genetic data, biometric data processed solely to identify a human being;
  • health-related data;
  • data concerning a person’s sex life or sexual orientation.

Personal data and Sensitive Personal Information collected by GenePlanet

If you are only a visitor to a website, we only collect your data using cookies. If you are a service user or a subscriber to a service provided by GenePlanet, we also collect other personal information that we need to provide the services you use or are subscribed to. This data is:

  • name and surname
  • contact e-mail address
  • contact phone number
  • IP address
  • genetic information
  • information to issue an offer according to your inquiry (your address, tax number).

We collect Personal Information from the following sources:

  1. from you directly;
  2. through your use of Our Site or Services;
  3. from any public sources where you have chosen to make your Information public, such as social media platforms;
  4. from content and advertising third parties with whom you have interacted on our Site; and
  5. from third parties who lawfully provide it to us.

The personal data controller

The controller of personal data processed in accordance with this Privacy Policy is GenePlanet.

Categories of individuals whose personal data are processed

This Privacy Policy applies to all individuals who use or are subscribed to our services, or have submitted inquiries, as well as everyone who visits our Website.

The Website provides direct to customer services only to persons who are legally competent to enter into a valid contract or have a written signature of a parent/legal guardian or as otherwise provided by the rules of a member state or other Applicable Law.

The purpose and bases for data processing

1. Processing on the basis of a contract:

In the context of the execution of contractual rights and the fulfilment of contractual obligations, GenePlanet processes your personal information for the following purposes:

  • identification of the individual,
  • preparation of an offer,
  • conclusion of a contract,
  • provision of ordered services,
  • notification of any changes,
  • additional details and instructions for the use of services to solve any technical problems, objections or complaints,
  • billing of services,
  • and other purposes as necessary for the implementation or conclusion of the contractual relationship between GenePlanet and an individual.

When calculating the services, based on the tax regulations, we obtain and process your address for the correct issue of accounts.

2. Processing on the basis of our legitimate interests:

On the basis of legitimate interest, we use your personal information to detect and prevent the fraudulent use and misuse of services, in the context of ensuring the stable and safe operation of our system and services, and also for the purpose of implementing information security measures, meeting the requirements regarding quality of services, and detecting technical system and service failures.

In accordance with the GDPR, in the event of suspected abuses, GenePlanet may process personal data in an appropriate and proportionate manner for the purpose of identifying and preventing any fraud or misuse, and may, if appropriate, also forward this information to other providers of such services, business partners, the police, the Public Prosecutor's Office, or to other competent authorities. For the purpose of preventing future abuse or fraud, data on the history of identified abuses or fraud in connection with an individual, including data on the subscription and, for example, IP address, can be kept for another five years after the termination of the business relationship.

We may also Process your Information on the basis of our legitimate interests to inform you about new products and Services, related products and Services, about any upcoming events, invite you to participate in relevant GenePlanet Research, obtain testimonials for promotional purposes, perform quality control checks and to conduct R&D. Where we rely on a legitimate interest to Process your Information, you have the right to object to such Processing and this can be stopped at any time via your GenePlanet account settings.
We will not rely on our legitimate interests to Process your Information where such Processing overrides your fundamental rights, interests or freedoms or where we have another legal justification for Processing your Information.

On the basis of legitimate interest, we also use your personal information for the purposes of potential enforcement, judicial and extra-judicial recovery.

3. Processing on the basis of consent to the processing of personal data:

Data processing can also be based on your consent, which you have provided to GenePlanet.

Consent may, for example, relate to the notification relevant GenePlanet Research participations, obtain testimonials for promotional purposes, perform quality control checks and to conduct R&D. The purpose of this information is to tailor the services to your needs and desires as closely as possible and to thereby increase the practical value for you. Communication is carried out via the channels that you have selected in your consent. You can revoke the communication at any time in the manner defined by the Privacy Policy.

Consent may also relate to our marketing and advertising efforts. From time to time we may send you communications not directly related to the provision of the Services, but about new services available to you, discounts and event invitations. We may also direct advertising to you via third party sites including social media. We will only send marketing material to you in accordance with this Privacy Policy, where we have a legitimate interest to do so, where you have opted-in to such communications or as determined by your web browser/cookie settings.

You can either revoke or alter your consent at any time, in the same way as you gave it or otherwise as defined by the Privacy Policy, whereby GenePlanet reserves the right to identify the customer. The amendment to the consent can also be sent by e-mail to [email protected] or by written request to the head office of GenePlanet.

The revocation or alteration of consent refers only to data processed on the basis of your consent. The most recent consent that has been received from you is valid. The possibility of revoking your consent does not constitute a resignation from the business relationship of the individual with GenePlanet.

The data for which your consent is given shall be processed, in the absence of cancellation, for up to two years after the termination of the business relationship with GenePlanet.

Processing of your Sensitive Personal Information:

  • In terms of your prior consent - We will Process your Sensitive Personal Information only with your prior, written and express consent in order to provide you with the Services in terms of the agreement entered with you. We will obtain this consent from you when entering into an agreement or in terms of the Consent Document, depending on the circumstances;
  • As required by a legal obligation - We may also Process your Sensitive Personal Information where the Processing is required or permitted by Applicable Law or for the detection or prevention of crime (including the prevention of fraud); or
  • When necessary for the establishment, exercise or defence of legal rights - Where the Processing is necessary for the establishment, exercise or defence of legal rights, we may Process your Sensitive Personal Information.

Processing to create Information:

  • We may Process your Information to create Anonymous Information which may be disclosed to third parties. If we use your Information in terms of this clause, your privacy will not be able to identify you.

Processing for GenePlanet Research and R&D:

  • We may Process your Information if you have provided prior, express and voluntary consent for your Genetic Information and Self-Reported Information to be used in any GenePlanet Research and R&D. This Processing includes sharing your Information with contracted third parties for Purposes of GenePlanet Research and R&D;
  • If we want to use any GenePlanet Research that includes your Information, even if only Anonymised Information, for scientific publication, such publication will be subject to full IRB (Institutional Review Board) approval and we will also obtain your consent with a Consent Document before authorising any such publication;
  • We will request your express written prior consent before sharing or publishing your Information for GenePlanet Research or R&D Purposes through a Consent Document.

Restrictions on the transmission of personal data

GenePlanet depends on other companies and individuals to perform certain tasks that complement our services. Therefore GenePlanet may also transfer personal data to carefully selected external processors who will enter into a contract for the processing of personal data with GenePlanet, or into an agreement or other binding document (hereinafter: "Processing contract") with the same substance as the contract. For external processors, such data will only be transmitted or made accessible to the extent required by a specific purpose. Such data may not be used by external processors for any other purpose, and the external processor must meet at least all the standards for the processing of personal data provided for in the applicable law. External processors are contractually committed to GenePlanet to respect the confidentiality of your personal information.

On the basis of a reasoned request, companies also provide personal data to the competent state authorities on a legal basis. GenePlanet will, for example, respond to requests from courts, law enforcement and other state authorities, which could also involve the state authorities of another EU Member State.

Period of retention of personal data

The data retention period is determined according to the category of the individual data. We keep the data for as long as necessary to achieve the purpose for which it was collected or further processed, or until the expiration of the limitation period for the fulfilment of the obligation or the statutory retention period.

For the purpose of fulfilling contractual obligations, the accounting data and the associated contact details of individuals may be kept until the full payment for the service or at the latest until the expiration of the limitation period in respect of an individual claim, which may legally last from one to five years. Invoices are kept for 10 years after the expiration of the year the invoice relates to in accordance with the law governing value added tax.

Other information that we have obtained on the basis of your consent is kept for the duration of the business relationship and for 2 years after the termination, unless the law provides for a longer retention period. If an individual who has given consent to the processing of personal data has not entered into a business relationship with us, their consent is valid for 2 years from its delivery or until its revocation.

After the expiry of the retention period, the data is deleted, destroyed, blocked or anonymised if the law does not specify otherwise for the particular type of data.

The rights of individuals relating to the processing of personal data

We guarantee the exercise of your rights regarding the processing of your personal information without undue delay. We will decide on your request within one month of receiving it. In case of complexity and a greater number of requests, the deadline may be extended by up to two additional months. If we extend the deadline, we will notify you of any such extension within one month of receiving the request along with the reasons for the delay.

We accept requests regarding the exercise of your rights at [email protected], or by post at genEplanet d.o.o., Cesta na Poljane 24, 1210 Ljubljana-Šentvid. When submitting an application by electronic means, we will, whenever possible, provide you with information electronically, unless you request otherwise.

Where there is reasonable doubt as to the identity of the individual who submits a claim relating to one of their rights, we may request the provision of additional information necessary to confirm the identity of the data subject.

Where requests from a data subject are manifestly unfounded or excessive, in particular because of their repetitive character, GenePlanet may:

  • charge a reasonable fee considering the administrative costs of providing the information or communication or taking the action requested; or
  • refuse to act on the request.

You have the following rights regarding the processing of your personal information:

  1. the right to access data
  2. the right to rectification
  3. the right to erasure ("right to be forgotten")
  4. the right to the restriction of processing
  5. the right to data portability
  6. the right to object

(i) The right to access data

You are always entitled to know whether personal data is processed in relation to you and, if so, you are also entitled to access your personal information, as well as the following information:

(ii) The right to rectification

You have the right to have any correction of inaccurate personal information relating to you performed without undue delay and, considering the purposes of the processing, the right to complete any incomplete personal data, including the submission of a supplementary statement.

(iii) The right to erasure ("right to be forgotten")

You have the right to have your personal information deleted without undue delay, if one of the following reasons applies:

  • when the personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
  • when you revoke the consent on the basis of which the processing takes place and there is no other legal basis for processing;
  • when you object to the processing of data and there are no overriding legitimate reasons for processing it;
  • if personal data has been processed unlawfully;
  • when personal data has to be deleted in order to fulfil a legal obligation in accordance with EU law or Slovenian law.

(iv) The right to restriction of processing

You have the right to limit the processing of your personal information when one of the following applies:

  • when you are contesting the accuracy of the data, for a period enabling us to verify the accuracy of the personal data;
  • the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
  • we no longer need your personal data for the purposes of the processing, but it is required by yourself for the establishment, exercise or defence of legal claims;
  • you have filed an objection regarding processing based on the legitimate interests of GenePlanet, until it is verified whether our legitimate reasons outweigh your reasons.

If the processing of your personal data has been restricted in accordance with the preceding paragraph, such personal data, with the exception of its storage, shall be processed only with your consent or for the establishment, enforcement or defence of legal claims or for the protection of the rights of another natural or legal person.

Before cancelling the processing limit of your personal information, we are obliged to inform you of this.

(v) The right to data portability

You have the right to receive your personal information, which you have provided us, in a structured, widely used and machine-readable form, and the right to forward this information to another controller without GenePlanet hindering you from doing so, when the processing is based on your consent and the processing is carried out using automated means. At your request, when technically feasible, personal data may be transferred directly to another controller.

(vi) The right to object

Whenever your data is processed on the basis of a legitimate interest for marketing purposes, you may object to such processing at any time.

We will stop processing your personal data unless we prove necessary grounds for processing that prevail over your interests, rights and freedoms, or to establish, enforce or defend legal claims.

Cross-Border Transfer of Information

We make Our Site and Services available to Users across the world, and similarly, make use of service providers in jurisdictions outside the European Economic Area ("EEA"). Therefore, your Information may be transferred outside the EEA to Processors for various Processing Purposes.

Where we transfer Information to countries outside the EEA, the Processors who Process the Information will be required to enter into a data processing agreement setting out how they may Process the Information and further requiring them to comply with the GDPR and other relevant Applicable Laws to protect your individual rights.

We require all Processors to have appropriate technical and security safeguards and measures to protect that Information.

The right to lodge a complaint concerning the processing of personal data

Any complaint regarding the processing of your personal data may be sent to the e-mail address [email protected] or by post to the address of genEplanet d.o.o., Cesta na Poljane 24, 1210 Ljubljana.

If we do not decide on your request within the legal deadline or if we reject your request, you have the option to lodge a complaint with the Information Commissioner.

You also have the right to lodge a complaint directly with the Information Commissioner if you believe that the processing of your personal data violates Slovenian or EU regulations in the field of personal data protection.

If you have exercised the right of access to the information and if, after receiving the decision, you believe that the personal data you received is not the personal information you requested or that you did not receive all the required personal information, you can lodge a reasoned complaint before submitting a complaint to the Information Commissioner with GenePlanet within 15 days. We need to decide on your complaint as a new request within five business days.

Security

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 GenePlanet and contracted third parties have access to Information that is necessary for them to perform their jobs or services.

Sharing Self-Reported Information through surveys, or other features on Our Site, is voluntary and done at your sole risk. GenePlanet cannot take responsibility for Information that you release or that you request us to release publicly.

In the event of a security incident, GenePlanet's internal procedures and those prescribed by the GDPR will be followed. You will be notified of any material impacts or direct consequences to you as a User without undue delay.

Final Provisions

Any matter not governed by this Privacy Policy is subject to applicable laws.

GenePlanet reserves the right to change this Privacy Policy. We will inform you about any changes on the official website of GenePlanet 30 days before their entry into force.

In the case of questions about the Privacy Policy or the information we keep about you, please contact us at [email protected].

These Privacy Policy were last updated on 10/07/2019

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