This Privacy Statement (the “Statement”) applies to the website located at https://genetica.asia/ and any other website, application (including the Software and/or any other mobile application), pages, features and/or contents owned and operated by Gene Friend (the “Website”) and your use of our Services. In this Statement, the terms “we” and “us” refer to Gene Friend and its Permitted Party; and the terms “you” and “your” refer to User. The Website may also contain links to other sites and/or applications owned and operated by other entities, to which this Statement shall not be applied.

This Statement is designed to provide you a better understanding on how we collect, use, store, process, share and transfer your information in association with your use of our Services. Please make sure you review this Statement and our Terms of Service (the “TOS”) carefully since you will be required to give your consent to this Statement and our TOS before proceeding further with your use of our Services.

1. Definitions

Unless being differently stated in this section or this Statement, the terms of which first letters are in upper case shall have the respective meanings as given to them in the TOS, which can be found at https://genetica.asia/en/term-of-service/.

(i) “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.

(ii) “Individual-Level Genetic Information”: information about a single individual’s genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.

(iii) “Report”: means Genetic Information and general recommendations rendered by Gene Friend basing on the test result of your gene.

 

2. Your Information We Collect

(i) Personal Information we collect from your registration and/or use our Website and/or our Serv

(ii) Other information you provide us:

a) User Content: Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission, including but not limited to any discussions, posts, or messages you send on Gene Friend’s forums.

b) Blogs and Forums: Our Website offers publicly accessible blogs. Additionally, Gene Friend clients may participate in our online forums. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. To request the removal or de-identification of any information that can be used to identify you from our blogs or forums, please contact us at contact@genetica.asia. Please note that whenever you post something publicly, in some cases, it may be impossible to remove all instances of the posted information, for example, if someone has taken a screenshot of your posting. Please exercise caution before choosing to share any information publicly on our blogs, forums or in any other posting. You may be required to register with a third-party application to post a comment. To learn how the third-party application uses your information, please review the third-party’s privacy statement.

c) Gifts: If you provide us with information about others, or if others give us your information, for the purpose of ordering the Services as a gift, we will only use that information for the specific reason for which it was provided to us. Once a gift recipient registers for his or her Services and agrees to this Statement, our TOS, and if applicable, certain consent documents (e.g. the Letter of Consent), such information will be used in manners consistent with this Statement, and will not be shared with the purchaser, unless they independently choose to share their own information through the Services with the purchaser.

d) Customer service: When you contact our Customer Care or correspond with us about our Services, we collect information to: track and respond to your inquiry; investigate any breach of our TOS, this Statement or applicable laws or regulations; and analyze and improve our Services.

(iii) Information we collect from your use of Services:

a) Saliva sample: To use our genetic testing services, you must purchase, or receive as a Service gift given to you by other person, the Sample Collection Kit; create an online Genetica Account and register your Sample Collection Kit, and ship your saliva sample to Gene Friend. Gene Friend and/or its Permitted Party will extract the DNA from your saliva sample for analysis. During the Sample Collection Kit registration, you are asked to review our relevant Letter of Consent and Request Form, and submit us your fulfilled and signed ones.

(iv) Other sources of information: We also collect information that is publicly available. For example, we may collect information you submit to a blog, a forum, a chat room, or a social network like Facebook, Twitter or Google+. We may also collect information about you from other companies and organizations. The information we receive depends on your privacy settings with such information resources, of which features are either hosted by a third-party or hosted directly on our Website. Your interactions with these features are governed by the privacy policies of the third-party companies providing them. We do not control the third-party site’s information practices. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Website or Services.

By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions and give you product recommendations and special offers that are more likely to interest you.

 

3. How We Use Information

Gene Friend will use and share your information described above in Section 2 with third parties only in the ways that are described in this Statement, including:

(i) For the Service operation, provision, analyzation and improvement, include, among other things:

a) Open your Genetica Account, enable purchase function and process payments, communicate with you, and implement your requests (e.g., referrals);

b) Enable and enhance your use of the Web, including authenticating your visits, providing personalized content and information, and tracking your usage of our Services;

c) Contact you about your Genetica Account, and any relevant information about our Services (e.g. Statement changes, security updates or issues, etc.);

d) Enforce our TOS and other agreements with you;

e) Monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks;

f) Perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities;

g) Provision of customer support; and

h) Obtaining surveys, polls and obtaining testimonials. We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us. If you do not wish to receive these requests, you can manage them in your Genetica Account settings.

(ii) For the process of genetic test:

As described above in Section 2.(iii), to use our genetic testing service and receive the results, you must create a Genetica Account, register your Sample Collection Kit, and submit your saliva sample to us to process and analyze in order to provide you with the Genetic Information, depending on the Services purchased. Gene Friend continuously works to improve our Services based on our research and product development, and genetic associations identified in scientific literature. If you are eligible to receive additional reports or updates in the future, you may be notified of or may directly access these updates.

 

(iii) For sharing your information with others:

Gene Friend gives you the ability to share information, including Personal Information, through the Services. You have the option to share directly with individuals, using Genetica Account, through (a) our forums, (b) relative finding features (e.g., “DNA Relatives”), (c) other sharing features and tools.

For sharing your information for the Gene Friend Research and/or Product Development which may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or pharmaceutical companies. Gene Friend Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. Gene Friend Research uses Aggregate and/or Individual-Level Genetic Information and Self-Reported Information as specified in the appropriate Letter of Consent.

If you choose not to complete a corresponding Letter of Consent or any additional agreement with Gene Friend, your information as described in this section will not be used for the Gene Friend Research and Product Development. However, your Genetic Information and Self-Reported Information may still be used by us and shared with our third-party service providers as outlined in this Statement.

(iv) For recruiting you for external research:

Research is an important aspect of the Services and we want to ensure interested participants are aware of additional opportunities to contribute to interesting, novel scientific research conducted by academic institutions, healthcare organizations, pharmaceutical companies, and other groups. If you have chosen to participate in the Gene Friend Research and Product Development, from time to time we may inform you of third party research opportunities for which you may be eligible. However we will not share Individual-Level Genetic Information or Self-Reported Information with any third party without your consent. If you do not wish to receive these notifications, you can manage them by editing your preferences in your Genetica Account settings.

(v) For the provision of marketing communications:

By creating a Genetica Account, you agree that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link or go to the “Preferences” section of your Genetica Account settings to edit your email notification preferences. You may not opt-out of receiving non-promotional messages regarding your Genetica Account, such as technical notices, purchase confirmations, or Service-related emails.

 

4. Information we share with third parties

(i) General service providers:

We share the information described above in Section 2 with our third-party service providers, as necessary for them to provide their services to us and help us perform our contract with you. Service providers are third parties (other companies or individuals) that help us to provide, analyze and improve our Services. While Gene Friend directly conducts the majority of data processing activities required to provide our Services to you, we engage some third-party service providers to assist in supporting our Services, including, but not limited to in the following areas:

a) Order fulfillment and shipping.

b) Our CLIA-certified genotyping lab.

c) Customer Care support.

d) Cloud storage, IT, and Security.

(ii) Aggregate Information:

We may share Aggregate Information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. This kind of information is different from Individual-Level Genetic Information and is not Personal Information because it does not identify any particular individual or disclose any particular individual’s data. Gene Friend will ask for your consent to share Individual-Level Genetic Information or Self-Reported Information with any third party, other than our service providers, as necessary for us to provide the Services to you.

(iii) Information we share with commonly owned entities:

We may share some or all of your information with other companies under common ownership or control of Gene Friend, which may include our subsidiaries, our corporate parent, or any other subsidiaries owned by our corporate parent in order to provide you better service and improve user experience. Generally, sharing such information is necessary for us to perform our contract with you. We may provide additional notice and ask for your prior consent if we wish to share your information described above in the Section 2 with our commonly owned entities in a materially different way than discussed in this Statement.

(iv) For helping us protect lawful interests and/or as requested by applicable laws:

You acknowledge and agree that Gene Friend is free to preserve and disclose any and all Personal Information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process (such as a judicial proceeding, court order, or government inquiry) or obligations that Gene Friend may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the TOS and/or other agreements with you, and/or our policies and; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Gene Friend, its employees, its Users, its clients, and the public.

(v) Business transactions:

In the event that Gene Friend goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, you acknowledge and agree that all your information as described above in the Section 2 will be among the assets to be transferred, and would remain subject to the privacy statement of the transferee in question.

 

5. Your right to control

(i) Access to your Genetica Account:

We provide you with access to your Gene Friend data within your Genetica Account. You can access and download data processed by Gene Friend within your Genetica Account settings and within applicable reports, tools, and features. If you lose access to your Genetica Account or email address of Genetica Account, please contact Customer Care for assistance. If you lose access to your Genetica Account, in certain circumstances, we may require that you submit additional information sufficient to verify your identity before providing access or otherwise releasing information to you. If you choose not to submit the required documentation, or the information provided is not sufficient for the purposes sought, Gene Friend will not be able to sufficiently verify your identity in order to complete your request.

You may access, correct or update most of your Registration Information on your own within your Genetica Account settings.

(ii) Marketing communications:

As noted in Section 3.(v), you may be asked to opt-in to receive product and promotional emails or notifications when creating your Genetica Account depending on where you are located. Otherwise, you may view or update your email notification preferences by visiting your Genetica Account settings or by contacting our Privacy Administrator at contact@genetica.asia. You can also click the “unsubscribe” button at the bottom of promotional email communications.

(iii) Sharing outside of the Services:

You may decide to share your information with friends and/or family members, doctors or other health care professionals, and/or other individuals outside of our Services, including through third-party services such as social networks and third-party apps that connect to our Website through our application programming interface (“API”). These third parties may use your information differently than we do under this Statement. Please make such choices carefully and review the policies of all other third parties involved in the transaction. Gene Friend does not endorse or sponsor any API applications, and does not affirm the accuracy or validity of any interpretations made by third party API applications. Gene Friend will have no responsibility or liability for any consequences that may result from your release or share of your information with others.

(iv) Legal Retention Requirements:

Gene Friend and our third-party genotyping laboratory may retain your Genetic Information, date of birth, and sex as required for compliance with applicable legal obligations.

 

6. Security Measures

(i) Gene Friend takes seriously the trust you place in us. Gene Friend implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information from any unauthorized access and/or use in accordance with this Statement and applicable laws.

(ii) You acknowledge and agree that protecting your information is also your responsibility. You are required to be responsible for safeguarding your password, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify Gene Friend of any unauthorized use of your password. Gene Friend cannot secure your information that you release on your own or that you request us to release.

(iii) Your information collected through the Services may be stored and processed in Vietnam or any other country in which Gene Friend or its Permitted Party maintains facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

 

7. Children’s privacy

Gene Friend is committed to protect the privacy of children as well as adults. Neither Gene Friend Website nor any of its Services are designed for, intended to attract, or directed toward children under the age of 18. A parent or legal guardian, however, may collect a saliva sample from, create an account for, and provide information related to, his or her child who is under the age of 18 or the kid under age of 18 who is under his/her guardian. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to Gene Friend about his or her child or the kid is under his/her guardian is kept secure and that the information submitted is accurate.

 

8. Linked websites

Gene Friend provides links to third-party websites operated by organizations not affiliated with Gene Friend. Gene Friend does not disclose your information to organizations operating such linked third-party websites. Gene Friend does not review or endorse, and is not responsible for the privacy practices of these organizations. We encourage you to read the statement of each and every website that you visit. This Statement applies solely to information collected by Gene Friend and our service providers on our behalf.

 

9. Changes to this Statement

Whenever this Statement is changed in a material way, a notice will be posted as part of this Statement and on our Website for 30 days prior to the effective of the change(s). Gene Friend may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify Gene Friend’s privacy practices or may provide you with additional choices about how Gene Friend collects, processes, stores, uses, shares and transfers your Personal Information. You should review this Statement frequently for your update of our changes.

 

10. Contact information

If you have questions about this Statement, or wish to submit a complaint, please email Gene Friend’s Privacy Administrator at: contact@genetica.asia

Last update on: September 03, 2019

If there will be any update, amendment, or changes to our Privacy Statement then these will be posted on this page.