This policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By registering for the vDNA program you are accepting and consenting to the practices described in this policy.
For the purpose of data protection legislation, the data controller is UAB Amziaus genomika, a wholly-owned subsidiary of Century Genomics Limited, registered in Lithuania under number 304226633, whose registered office is at Pilies St. 16, LT-01123 Vilnius, Lithuania, referred to as ‘we’ in this policy and the Privacy Headlines you accepted when registering for the service.
Information we collect from you
We will collect and process the following data about you:
Information you give us.
“Personal Information” is information you give us that can be used to identify you either alone or in combination with other information. We collect the following types of Personal Information:
• “Registration Information” is information you provide when registering for and/or purchasing the Program. The information you give us is, your full name, address, payment method details and e-mail address and phone number, and a password to be used for your account.
• “Samples” are the actual saliva, microbiome and blood samples you provide to our partner labs to process on our behalf and the associated reference number. They would not be considered Personal Information unless they were accessed by a person also having access to the link between the reference number and your Registration Information, which is kept under secure conditions by us alone. But we have included reference to them in this Policy to inform you as to our use of them.
• “Sample Information” is data generated through the analysis of your saliva, microbiome and blood samples, including DNA data relating to your genotype.
• “Phenotypic Information” is your Personal Information, including your health history, dietary habits, exercise, sleep and wellness goals that you enter during the online assessment part of the Program; any recommendations we provide to you as part of the Program; and any information you submit from the fitness tracker we provide you with as part of your Welcome Pack.
Information we collect about you. With regard to each of your visits to vDNA we will automatically collect the following information:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions.
Uses made of the information
We use information held about you in the following ways:
Registration Information. We will use this information:
• to provide you with the information that you request from us;
• to provide you with information about other services we offer that are similar to vDNA;
• to provide you with information about goods or services we feel may interest you, if we have obtained your consent to doing so;
• to notify you about changes to our Program.
• We use Samples to derive Sample Information (see below).
• We also store DNA from your saliva sample after the sample testing process. We will do this until you notify us that you do not wish us to continue to do so. This is to enable you to authorise us (or someone else specified by you) to carry out further tests on your saliva sample as DNA testing improves and the data we can glean from it increases. Be assured that we will never carry out tests on your Samples, nor provide them to anyone else to test, without your express specific prior approval. If you’d like us to stop storing your DNA at any time, please email us at firstname.lastname@example.org
Sample Information. We will use this information:
• to provide you with information and recommendations as part of the Program;
• with or without combination with your Phenotypic Information, and personal data from others users of the Program, for the purposes of research and product development. This might be conducted by us, or by someone else to whom we provide the data. In no circumstances will we provide to any person for research or product development purposes any Sample Information/Phenotypic Information which is linked to your Registration Information (or indeed any other personal data we hold about you).
Phenotypic Information. We will use this information:
• to provide you with the information that you request from us, and that you request that we share with your healthcare or well-being professionals;
• with or without combination with your Sample Information, and personal data from others users of the Program, for the purposes of research and product development. This might be conducted by us, or by someone else to whom we provide the data. In no circumstances will we provide to any person for research or product development purposes any Sample Information/Phenotypic Information which is linked to your Registration Information (or indeed any other personal data we hold about you).
Information we collect about you. We will use this information:
• to administer vDNA and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve vDNA to ensure that content comprised in the Program is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep vDNA and your Personal Information safe and secure; and
• to make suggestions and recommendations to you and other users of vDNA about goods or services that may interest you or them.
You may withdraw your consent to our processing your Personal Information at any time by emailing us at email@example.com. We will cease providing you with any aspects of the Program that require use of that information immediately, but to be clear you will not be entitled to a refund and will be committed to continue your subscription payments for the current subscription term. If you remove your consent to use of your Sample Information or Phenotypic Information, we will stop using it for the purposes of the Program, and for new research or development projects commencing after 30 days from the receipt of your request. Any research or analysis involving your data that has already been performed or is in the course of being performed (either for the provision of the Program or for research or product development purposes) prior to the expiry of that 30 day period will not be reversed, undone, or withdrawn.
This website uses Google Double Click Ad Exchange and Google Tag Manager software provided by Google. These services allow website providers to address their visitors in a targeted fashion by displaying personalised, interest-based advertisements when they visit other websites that are part of the Google Display Network. Google places what are known as cookies to analyse how users use a website. The information collected with these cookies form the basis for interest-based advertising. To do so, Google stores a small sequence of numbers in your browser. This number is used to record the visits to the website and collect anonymised data on how the website is being used. No personal data of the people visiting the website are collected in the process. If you subsequently visit another website that is part of the Google Display Network, you will be served advertisements that are very likely to be related to the products or information that you have previously viewed. You can permanently deactivate the cookies used by Google if you click on the following link and download and install the plug-in contained therein: https://www.google.com/settings/ads/plugin.
Our site also uses Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site. You can do so by visiting this page – https://tools.google.com/dlpage/gaoptout
Disclosure of your information
You agree that we have the right to share your Personal Information with:
• any healthcare or well-being professional you request us to share your Phenotypic Information with;
• Any member of our group of companies, which means our subsidiaries, our ultimate holding company and its subsidiaries;
• Our hosting company who provides server space for us to run vDNA;
• Facebook, for the purposes of conducting chat interactions with you over Messenger as part of the Program;
• Our third-party email hosting partner, Amazon Web Services, Microsoft, and GoDaddy (used for our own corporate email);
• Our email distribution partner, Mailchimp (for use in email campaigns)
• Our third party hosting partner Google, for the for the purposes of storing your Personal Information;
• A third party artificial intelligence service provider (IBM) for the purposes of your being provided (at your express prior request) with further analysis and information respect of your Sample Information and Phenotypic Information;
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• If UAB Amziaus genomika (or substantially all of its assets) is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• To protect our rights, property, or safety or those of our customers, or others.
How long we will keep your data
We will archive and stop using any Registration Information, other personally identifying information about you within 1 year of your subscription to the Program terminating or expiring. We will delete this from our archives after 5 years of your last use of vDNA. Your saliva sample will be retained permanently as long as you continue to indicate your consent to this on an annual basis, unless you notify us by emailing privacy@vitalityDNA.com that you wish for us to dispose of it. Other samples will be disposed of promptly on completion of the relevant Sample Information being derived from them and recorded.
De-identified copies of your Sample Data and Phenotypic Information do not contain any personally identifying information about you and will not be subject to those deletion requirements.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.
You have the right to access information we hold about you, together with an explanation of the categories of data being processed, the purposes of such processing, and the categories of third parties to whom the data may be disclosed. You can also require us to provide you details of the period for which the data will be stored (or the criteria used to determine that period) and information about your other rights regarding our use of your data. We will provide you with the information within one month of your request. If you ask us more than once, we have the right to apply a £30 charge to help cover the costs of processing your request.
You also have the following rights:
• The right to require us to rectify any inaccurate personal data we hold concerning you.
• The right to be ‘forgotten’ by us and have us erase any personal data we hold about you, if it is no longer necessary for us to hold the data for purposes of your use of vDNA.
• The right to object to us using your data for the purposes of profiling you or making automated decisions about you. You acknowledge that profiling is essential to the Program and we will be unable to continue providing you with the Program if you exercise this right. You will not be entitled to a refund of any sums paid to us for the Program, and will be obliged to continue making payments for the remainder of your subscription period.
• The right to ask us to port your data to another service (if technically feasible) or to provide you with a copy of data we hold about you in a structured, commonly used machine-readable format so that you can provide it to them. (Will not do so to the extent that this involves disclosing data about any other individual).
You can also exercise these rights at any time by contacting us at firstname.lastname@example.org.
To the extent that it does not involve disproportionate effort on our part, if you exercise any of the above rights we will tell any third parties to whom we have passed your data.
Additionally, you have the right to lodge a complaint regarding our use of your data. You should address any complaint to the Information Commissioner’s Office, either by calling their helpline on 0303 123 1113 or as directed on their website at www.ico.org.uk.
vDNA is committed to keep the trust you place in us. To prevent prohibited access or disclosure, to maintain information accuracy, and to ensure using the information appropriately, vDNA uses various physical, technical, and administrative measures to keep your Personal Information. Particularly, all connections to our website and our mobile application are encrypted using Secure Socket Layer (SSL) technology.
Please understand that protecting your Personal Information is also your responsibility. We ask for you to be responsible for keeping your password secure, as well as other authentication information that you use to access the Program. You should not share your authentication information to any third parties and you should inform vDNA immediately of any prohibited use of your password. vDNA cannot keep the Personal Information that you release or that you request us to release safe.
As with all web-based services, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to vDNA via the internet including over mobile devices; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Other data users
vDNA may provide signposts to resources to help users navigate health and wellness resources available to them. If you follow a link to any of these resources, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Regarding any healthcare or well-being professional you ask us to give access to your information, you should make sure you are confident that they will take the utmost care of your information. We do not take any responsibility for any actions or behaviour of any such person regarding their use of your information.
The Program is not designed for, intended to attract, or directed toward children under the age of 18. Our terms and conditions prohibit any person under 18 from accessing the Program. We do not intentionally process any personal information in relation to any child.