הרשמה

Privacy Policy

At GenePlanet, your privacy is a top priority. GenePlanet is 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 honest, direct and transparent when it comes to your data. GenePlanet follows three guiding principles when it comes to your privacy:

• Transparency. We work hard to be transparent about what Personal Information we collect and process.
• Simplicity. We try to use easy-to-understand language to describe our privacy practices to help you make informed choices.
• Control. We give you control over the Personal Information you provide to us -  how it is used and retained.

Other Important Things for You to Understand When You Use Our Services

You can manage and delete your data as described in this Privacy Policy.

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

When you make new discoveries with us, you should feel confident and informed about how we use your Personal Information. Our full Privacy Policy is below and we encourage you to read it.

We will not use your sensitive information without your consent unless: (i) the information has been anonymized or aggregated so that you cannot reasonably be identified as an individual; or (ii) a legal obligation requires us to use it in some way e.g. a court order requires us to disclose the information.

SUMMARY REGARDING PRIVACY POLICY AND PERSONAL INFORMATION

1. By agreeing to our Privacy Policy and General Terms & Conditions, you consent to the storing and processing of your personal information, including sensitive information, in the Slovenia and countries outside of the country you live in. We use a range of measures to safeguard information, but these countries may have laws that are different from those of your country of residence. You also consent to your personal information, including sensitive information, being transferred in the event of a business transition such as a merger, acquisition by another company, or other transaction or proceeding. In such a case, your information would be used as set out in any pre-existing Privacy Policy.
2. We will not sell, lease, or rent your individual-level information (i.e., information about a single individual's genotypes, diseases or other traits/characteristics) to any third-party or to a third-party for research purposes without your explicit consent.
3. We may share anonymized and aggregate information with third-parties; anonymized and aggregate information is any information that has been stripped of your name and contact information and aggregated with information of others or anonymized so that you cannot reasonably be identified as an individual.
4. We will use your genetic information and/or self-reported information and share it with third-parties for scientific research purposes only if you sign the appropriate Consent Document. Note that we will disclose your individual-level information only if we obtain additional explicit consent from you.

Effective Date: May 23, 2018

1. Key Definitions

Aggregate Information: information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.

Anonymized Information: information that has been stripped of your Registration Information (e.g., your name and contact information) and other identifying data such that you cannot reasonably be identified as an individual.

Individual-level Information: information about a single individual's genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.

Personal Information: information that can be used to identify you, either alone or in combination with other information. GenePlanet collects and stores the following types of Personal Information:

• Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, user ID and password, and payment information).
• Genetic Information: information regarding your genotype (e.g. the As, Ts, Cs, and Gs at particular locations in your genome), generated through processing of your saliva by GenePlanet or by its contractors, successors, or assignees; or otherwise processed by and/or contributed to GenePlanet.
• Sensitive Information: information about your health, Genetic Information, and certain Self-Reported Information such as racial and ethnic origin.
• Web Behavior Information: information on how you use the GenePlanet website (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology which is described with more detail in Cookie Policy.

Service or Services: GenePlanet’s products, software, services, and website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by the user, regardless if the use is in connection with an account or not.

2. Introduction

At GenePlanet, we enable journeys of self-discovery. As a result, we collect, process and store your Personal Information as you use our websites, mobile applications, and services (collectively the “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 Policy describes our practices for collecting, storing and processing your Personal Information and the controls we provide you to manage it within our Services. In addition, we have a Cookie Policy that describes our use of browser cookies and similar tracking technologies.

3. Account Creation and Your Engagement with GenePlanet Services

The Personal Information required to create a basic GenePlanet account is only your email address and a password. Access to Genetic Information to help you understand yourself better requires additional personal information and, for the DNA test, the test code (when you activate your DNA test kit) and a saliva sample from which we can extract Genetic Information.

Account creation also requires you to agree to the General Terms & Conditions and this Privacy Policy by clicking “Continue”, “Register” or “Accept” on the account creation and claim kit page

By clicking “Continue”, “Register” or “Accept” you are telling us that you consent to GenePlanet collecting, processing, and sharing your Personal Information (including your Genetic Information) as described in this Privacy Policy and in any other documents referenced in this Privacy Policy.

At any time, you can request GenePlanet to delete information you have provided or your Genetic Information. Please see below sections for specific details about deleting your data.

If you no longer wish to have GenePlanet account, please contact us and we will help you close your account.

4. What Information Does GenePlanet Collect From You?

The table below describes the information we collect from you to provide the Services. In this Privacy Policy, we refer to this as your “Personal Information.”

5. What Information Does GenePlanet Collect Through Your Use of the Services?

6. How does GenePlanet use your Personal Information?

7. When Do We Share Your Information and Who are the Recipients?

GenePlanet does not share your individual Personal Information (including your Genetic Information) with third-parties without your additional consent other than as described in this Privacy Policy. In particular, we will not share your Genetic Information with insurance companies, employers, or third-party marketers without your express consent. The circumstances described below explain when sharing might occur:

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 GenePlanet. Details and options for accessing this information are listed below.

9. What are GenePlanet retention practices?

GenePlanet 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, the ongoing enhancement of GenePlanet features provide benefits and insights to our users over time. As a result, GenePlanet’s retention practices reflect this ongoing value by retaining user accounts and Personal Information on our system until our users inform us of their desire to delete their data or close their accounts.

10. How can I delete my Personal Information?

You can delete your Personal Information from GenePlanet in following ways.

11. Security

GenePlanet 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.

GenePlanet 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 latest standard security mechanisms while processing and storing 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.

Your password for your account will be used only for online login. We will not ask for your password under any other circumstances. Inform GenePlanet immediately of any unauthorized use of your account. Should you wish to reset or change your password, you can do so by clicking on the relevant links on GenePlanet web page.

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

12. Data transfer

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside EU and choose to provide information to us, please note that we process the data, including Personal Information, in the EU.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that processing.

GenePlanet will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

13. Changes to this Privacy Policy

We may modify this Privacy Policy at any time, but we will provide prominent advance notice of any material changes, 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 Privacy Policy 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 Policy.

If you object to any changes, you may delete your account by contacting us.

14. Information about children

GenePlanet is committed to protecting the privacy of children as well as adults. Neither GenePlanet nor any of its Services are designed for, intended to attract, or directed toward children under the age of 18. A parent or guardian, however, may collect a saliva sample from, create an account for, and provide information related to, his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to GenePlanet about his or her child is kept secure and that the information submitted is accurate. If you are under 18, we ask that you do not use our Service or give us your personal information without your parent or guardian consent.

15. Legal basis under EU General Data Protection Regulation 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 update / upgrade 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, GenePlanet 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 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.

16. Identity and Contact Details of the Data Controller

Contact Details of the Data Protection Officer

• Email: dpo@geneplanet.com

GenePlanet customers can reach us using phone number, or you may submit questions using email. Contact details can be found by using “help” / “?” button which can be found in bottom right corner on web page https://my.geneplanet.com.

GENERAL TERMS AND CONDITIONS FOR PERFORMING AND USE OF GENETIC ANALYSIS

1. Terms

• Analysis is performed and personal and sensitive data is controlled by the company genEplanet, personal genetics, d.o.o ("We", "us" and "our"). Please read carefully the following general terms and conditions for performing and use ("Terms") as they will shed light on the necessary founding services and allow you to discover the results and information provided by these services.
• We reserve the right to change the Terms at any time and for any reason.
• Conditions are written by following legal provisions of the Republic of Slovenia. Slovenian courts have exclusive jurisdiction over any claims or disputes arising out of or in connection with the conditions.

2. Ordering process

• You have received the kit for taking your biological sample, instructions for sample submission and instructions on where to fill your personal data which are needed for successful analysis completion.
• Please fill out in detail all the necessary information requested with your order, because otherwise we cannot accept and/or successfully process your sample.
• Collect your saliva sample and return it back to our processing centre. Be careful to follow all instructions on how to correctly collect your sample and return it to us otherwise we cannot guarantee success of your sample analysis.

3. Results of genetic analysis

• In case we will end up performing genetic testing of your DNA, we would try to send the results of the analysis to you within our SOP determined period from the date we receive your saliva sample.
• Information (with the genetic results), graphic content, text, images, trademarks, trade names and logos (the "Materials") are protected by copyright and other intellectual property laws. Once you agree to the Terms of Use, we grant you, for a period of time, a non-exclusive license for personal purposes. Personal purposes means for reading, viewing and/or printing of one available copy of the materials, as long as all copyright, trademark and other proprietary notices are left intact. Any other use of the contents of the genetic analysis, such as the reproduction, modification, distribution, transmission, re-publication, or use of content is prohibited.
• In case of a change of your personal data necessary for the delivery of our products, you must notify the company genEplanet d.o.o and/or data processor through which you ordered genetic analysis in due time. If this is not done on time, then the analysis will be sent to the address specified when ordering (if your order included printed version of analysis results) and will be considered to be received.
• After receiving the results of the genetic analysis to your premises (receipt of printed book to your premise or download of electronic results to your computer), it is you who is responsible for protecting them from being seen by anyone unauthorized.
• genEplanet d.o.o employs the latest knowledge and the highest standards to provide that all information and test results are accurate and correct, but we are not responsible for the reliability and integrity of the data. Acquired genetic material is analysed based on current scientific research and publications on Caucasian race (white European), but this data might be subject to change over time as new findings emerge.
  

4. Website access

• We will make the necessary arrangements to ensure that the Website is fully operational at all times. However, due to the nature of interactive services and the internet generally, we cannot guarantee that the Website will be free from delays, interruptions or errors and access to the Website may be suspended (whether by us or due to external causes) temporarily and/or without notice. We will not be liable for any loss or damage arising from the Website not being available (whether for internal processing reasons or otherwise).
• We may restrict, suspend or terminate your use of the Website if we believe that you have breached these Terms and Conditions at any time. The suspension or termination of the Website will be without prejudice to any rights which we may have against you in respect to your breach of these Terms and Conditions.
• You are responsible for ensuring that no unauthorized access is obtained into your account. You will be entirely liable for all activities conducted through your account whether authorized by you or not until you have notified us of such unauthorized use and we have stopped access to your user account. If we have reason to believe that there is likely to be a breach of security or misuse of your account, we may change any or all of your password or security code and notify you accordingly.
• We reserve the right to suspend or terminate forthwith your right to use you user account if we have reason to believe that your password is being misused.
• We may provide links to websites on the Internet which are operated by third parties. Such links are provided for your convenience only. We make no representations whatsoever about any other websites which you may access through our website or which may link to the Website. When you access any other Website you understand that it is independent from us and that we have no control over the content or availability or privacy practices of that website.

5. Telephone counselling and medical consultation

• About all questions regarding genetic analysis prior to its implementation and about the results of an analysis after its completion, you can consult with an expert or genEplanet d.o.o. staff via telephone number 059/25-11-11 or via e-mail support.en@geneplanet.com.

6. The rights for cancellation and refund

• You have the right to cancel the service contract according to the general cancellation terms.
• Where you have purchased a saliva collector kit, you may cancel your purchase within seven working days of receiving the saliva collector kit. You must return the saliva collector kit to us unused, complete and in a re-saleable condition on your own expense and we will return your money minus our transportation fees;
• If you have already submitted your biological sample, you can still cancel the ordered services until the sample has not been submitted for analysis in the laboratory. Upon this cancellation you will be charged with the administrative costs and the use of the kit, and the difference would be returned.
• In any case we try to guarantee that you will be satisfied with the obtained genetic analysis. In case that you are dissatisfied with the product or services that you received from us, please contact us by e-mail support.en@geneplanet.com.
• Apart from your cancellation right, where any valid claim in respect to any item or service sold by us is based on any defect in the quality or condition of the items or service or their failure to meet specification, we shall be entitled to replace the goods or service (or the part in question) free of charge or, at our sole discretion, refund the price of the items or service (or a proportionate part of the price), but we shall have no further liability to the purchaser to the fullest extent permitted by law.

7. Warranties and disclaimers

• By placing your order, you warrant that:
• You are legally capable of entering into this contract;
• You are at least 18 years of age; and
• If you are sending a saliva sample from third parties then you have the permission and authorization of that third party, and that authorization will be sent to us with saliva sample. You also need to send us copy of authorizing person’s identification card where his/her signature is visible so that we can be completely sure that authorisation is valid.
• WHILST ALL REASONABLE EFFORTS ARE MADE TO ENSURE THAT ANY INFORMATION, INCLUDING THE RESULTS, SUPPLIED BY US IS CORRECT, WE MAKE NO REPRESENTATIONS OR WARRANTIES, EXPRESS OR IMPLIED, IN RELATION TO THE TIMELINESS, ACCURACY OR COMPLETENESS OF SAID INFORMATION. YOU CAN NOT RELY SOLELY ON THE CONTENT OR INFORMATION RECEIVED FROM GENETIC ANALYSIS TO BASE YOUR DECISIONS ABOUT IMPORTANT PERSONAL AND MEDICAL DECISIONS ON IT. YOU SHOULD CONSULT AN APPROPRIATE PROFESSIONAL FOR ADVICE, WHICH WOULD BE SPECIFIC IN TERMS OF YOUR PARTICULAR SITUATION.
• In rare cases for specific analysed DNA loci (gene information) it is not possible to obtain unambiguous information due to biological or technical reasons. This means, that the detected signal is of so low quality, that it is not possible to claim with 100% certainty, what the result is. To ensure high quality, scientific accuracy and correctness of our analyses in such cases, we cannot interpret the results and consequently the final report can be missing some SNP information and specific analysis results. The final report will be treated as successfully completed if up to two specific analyses are missing and the analysis will not be repeated in this case.
• We make no representations, warranties or undertakings that the Website, or the server that makes it available, will be compatible with your equipment or free from defects, including but not limited to viruses or other harmful elements. We accept no liability for any infection by computer virus, bug, tampering, unauthorised access, intervention, alteration or use, fraud, theft, technical failure, error, omission, interruption, deletion, defect, delay, or any event or occurrence beyond our control, which corrupts or affects the administration, security, fairness and integrity or proper conduct of any aspect of the Website or your equipment.
• Except as expressly set out in these Terms and Conditions, all representations, warranties, terms and conditions whether express or implied in relation to this Website or the information contained therein are hereby excluded to the fullest extent permitted by law.

8. Insurance 

• You agree to indemnify us and keep us indemnified in respect to all loss or damage suffered by it in connection to your use of the genetic analysis and breach of these Terms and Conditions and in respect of all claims or legal proceedings brought or threatened against it by any third party which arise in connection to your use of the genetic analysis in breach of these Terms and Conditions.
• You agree to indemnify us and keep us indemnified in respect to all loss or damage suffered by it in connection to your use of the Website in breach of these Terms and Conditions and in respect of all claims or legal proceedings brought or threatened against it by any third party which arise in connection to your use of the Website in breach of these Terms and Conditions.
• You are responsible to check if your country permits you to order and perform genetic analysis by us and you agree to indemnify us and keep us indemnified in respect to all loss or damage suffered if your country does not permit genetic analysis performance but you still ordered it with us.
• When ordering the test, you are aware of the potential impacts and risks of genetic analysis and in full awareness agree that genEplanet d.o.o takes no responsibility whatsoever for consequences.
• Our products are not a substitute for medical diagnosis, treatment, doctors’ recommendations, visit or search for recommendations from other official health institutions regarding medicines, nutrition, lifestyle, treatment methods or related services. It is intended to be used for information purposes only and for drawing attention to the importance of prevention for a longer and healthier life.

9. General provisions

• We kindly ask you to carefully read the provisions of the Statement regarding genetic analysis, as you will have to confirm that you agree with them before you send us your personal information.

10. Collection and use of personal data

• Any personal information you entrust to us will be treated in accordance with the Law on the Protection of Personal Data. You have the right to have access to your personal information that we process and can request its modification, amendment, deletion or anonymization.
• Saliva sample that you send contains genetic code, which during the period of our contractual relationship is dealt as extremely sensitive and confidential personal information and in accordance with the Data Protection is regarded as health information. Analysis of sample is necessary in the process of genetic testing. We commit ourselves to the protection of the confidential nature of such data and use it only to the extent that is necessary to produce by your order required service. You acknowledge that by ordering our services you agree to the provisions of these Terms, and you give us explicit consent to process your extremely sensitive personal information. If you submit a saliva sample that belongs to another person, we need you to confirm that the other person has expressed consent to allow us to process such highly sensitive personal information. 

11. Disclosure of personal data

• In accordance with the strict rules of confidentiality we may reveal your personal data and/or sensitive personal information within a reasonable extent necessary to carry out the purposes described above to our authorized personnel and/or service providers. Authorized persons and/or service providers are contractually bound to process your data in accordance with our instructions and under safety standards of the Slovenian Law on Data Protection.
• Testing done by us and on our behalf is based on anonymous data. The test sample from each client is designated with the number in code before start of the analysis to prevent any disclosure of any personal identifying information. Your identity is connected with the test results when the test results come back from our service providers.

12. Rights of withdrawal 

• Under certain exceptions, you have the right to obtain a copy of the personal data that we obtained from you, and correct any irregularities in such data. If you want to cancel any of these rights, please inform us at support.en@geneplanet.com. Your request will be dealt as fast as possible, and will be done within 40-day period.

13. Direct marketing

• The personal information that you have submitted may be used, in order to present to you or inform you about our products and services that may be of interest to you. This type of marketing can be done by mail, e-mail, SMS, telephone or fax. Information on products and services can always be canceled over a message to support.en@geneplanet.com.

14. Final provisions

• These General terms and conditions for performing and use of genetic analysis are valid from 30.01.2017 onwards.
• We reserve right to change or update our General terms and conditions. New or updated terms are valid from the day they are published on our web page. We will not send you specific notification of terms change. Since new terms will also apply to you already you agree to follow our web page for terms change.