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Privacy Policy

GENDIUS LTD PRIVACY POLICY (this “Policy)

We are Gendius Ltd, a business that provides to our subscribers access to our mobile application “Intellin” (the “App”). This Policy is our privacy policy for the App. In this Policy we refer to Gendius Ltd as “we”, “us” and “our”.

We respect your privacy and are committed to protecting your personal data. This Policy sets out how we look after your personal data when you use the App and tells you about your privacy rights and how the law protects you.

 

  1. Important information and who we are
Purpose of this Policy

This Policy aims to give you information on how we collect and processes your personal data through your use of the App, including any data you may provide through the App when you register for an account, agree to purchase a particular level of access to the App’s functionality or when you access our services through the App.

We are a data controller

A data controller, according to the applicable data protection laws, means a person who determines the purposes for which and the manner in which any personal data is to be processed.

We are a data controller in respect of any personal data that you share with us, or that we collect, through the App (including personal data you provide to us, or that we collect, during your registration for, and subscription to, the App) and each time you utilise the services available through the App.

Important information

The App is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements the other notices and is not intended to override them.

We have appointed a Rory Cameron who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise listed at paragraph below then please contact the Rory Cameron using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Gendius Ltd, The BioHub, Alderley Park, Alderley Rd, Alderley Edge, Macclesfield, Cheshire, SK10 4TG.

Name or title of data protection officer: Rory Cameron

Email address: roryc@gendius.co.uk

Postal address: Gendius Ltd, The BioHub, Alderley Park, Alderley Rd, Alderley Edge, Macclesfield, Cheshire, SK10 4TG.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Policy and your duty to inform us of changes

This version was last updated in June 2018.

We will inform you of any changes to this Policy by email. In addition, any change to this Policy will be on this page and a notice that the Policy has been updated will be clearly shown on the App. Continued use of the App after such modifications will constitute agreement to the updated terms of the modified Policy.

It is important that the personal data we hold is accurate and current. We ask that we are kept informed if personal data changes during your relationship with us.

 

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes this includes your first name, last name, username or similar identifier, your gender and date of birth, that you provide when you register for an account with us.
  • Contact Data this includes your billing address your email address and your telephone numbers that we require you to provide for you to register for an account with us.
  • Financial Data this includes your bank account bank account and payment card details which we collect if you pay for an increased level of access to the App.
  • Technical Data this includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the App.
  • Profile Data this includes your username and password, as well as your preferences, feedback and responses to any surveys.
  • Usage Data this includes information about how you use certain features of the App.
  • Marketing and Communications Data this includes your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. We share non-identifiable data with the following parties:

  • Fiecon Pharmaceuticals for providing analytics from anonymised data.
  • ADAC to Create algorithms from anonymised data.
  • Academic partners, such as the University of Oxford, for the purpose of publishing anonymised data.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

Depending on the level of access you purchase when subscribing for us of the App we may collect Special Categories of Personal Data about you. This includes specific details about your health and as well as other genetic data. When you subscribe for a level of access to the App which may result in the collection of Special Categories of Personal Data we ensure that you are aware of this prior to your subscription to that level of access and we will ensure that we do not collect this data without your explicit and informed consent. If you do not wish for us to collect this personal data you may simply chose to not provide it to us when requested however you acknowledge that you will have subscribed to a level of access to the App that you will not be fully utilising.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, if when subscribing to access the App you specify that you wish to receive specific reports in relation to your health and yet you fail to provide that information, we will be unable to provide the report). In this case, we will be unable to provides you with the service that you subscribed for, but we will let you know if this is the case.

 

  1. How we collect your personal data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact, Financial, Profile, Marketing and Communications and Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or through the functionality available within the App. This includes personal data you provide when you:
    • create an account to use the App;
    • subscribe to the services available through the App;
    • request information about the App;
    • request marketing to be sent to you;
    • supply information to allow full use of the App; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with the App, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies. Please see paragraph 6 below for more information on our use of cookies.

 

  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to Special Categories of Personal Data. You have the right to withdraw consent to our collecting of Special Categories of Personal Data at any time by contacting us and/or using the functionality available through the App.

Purposes for which we will use your personal data

It is the responsibility of the data controller to ensure that it has a lawful basis for processing your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To enable us to respond to enquiries. (a) Identity

(b) Contact

Necessary for our legitimate interests (for the running of our business, the provision of our services and to grow our business)
To allow you to register for an account. (a)  Identity

(b)  Contact

(c)  Profile

(a)  Performance of our contract with you

(b)  Necessary for our legitimate interests (for the running of our business, the provision of our services, to grow our business to keep our records updated and to study how customers use our products/services)

(c)  Necessary to comply with a legal obligation

 

To enable you to access and allow you to use the App. (a)  Identity

(b)   Contact

(c)    Profile

(d)   Usage

(e)    Financial

Performance of our contract with you
To provide you with a new password upon request. (a)    Identity

(b)   Contact

(c)    Profile

Performance of our contract with you
To manage our relationship with you which will include but is not limited to: notifying you about changes to our terms or privacy policy or the services we offer through the App. (a)    Identity

(b)   Contact

(c)    Profile

(d)    Marketing and Communications

(a)    Performance of our contract with you

(b)   Necessary to comply with a legal obligation

(c)    Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To provide services, including feedback and reports, to you through your use of the App. (a)    Identity

(b)   Contact

(c)    Profile

(d)   Usage

(e)    Financial

Performance of our contract with you
To process and deliver the App including collecting and recovering money owed to us. (a)    Identity

(b)   Contact

(c)    Financial

(d)   Marketing and Communications

(a)    Performance of our contract with you

(b)   Necessary for our legitimate interests (to recover money owed to us)

 

To keep the App safe and secure, detect fraud and monitor any abuse of the App. (a)    Identity

(b)   Contact

(c)    Technical

(a)    Necessary for our legitimate interests (for running our business, provision of services, network security, to prevent fraud)

(b)   Necessary to comply with a legal obligation

To allow you to use the full functionality available within the App. Special Categories of Personal Data Explicit Consent
To allow us to us to prepare reports based on your use of the App. (a)    Identity

(b)   Contact

(c)    Profile

(d)   Usage

(e)    Special Categories of Personal Data

(a)    Performance of our contract with you

(b)   Necessary for our legitimate interests (for the running of our business, the provision of our services, to grow our business to keep our records updated and to study how customers use our products/services)

(c)    Explicit Consent (in relation to Special Categories of Personal Data only)

 

Change of purpose

We will only use personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, and we will only send marketing communications to you if we have you consent to do so or a legitimate interest in contacting you for such purposes. You will receive marketing communications from us if you have requested information from us and, in each case, you have not opted-out from receiving that marketing.

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Third-party marketing

We will ask for consent before we share your personal data with any outside company for marketing purposes. We are not responsible for the marketing you receive from any third-party provider.

Third-party links

The App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data. We do not control these third-party websites or applications and are not responsible for their privacy statements. We encourage you to read the privacy policy of every website or application you visit.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the App and checking or unchecking the relevant boxes within your profile to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

 

  1. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We will not sell, trade, rent or disclose your personal data to others except in the following circumstances:

  • if it is required by law enforcement or judicial authorities, or to cooperate with a law enforcement investigation;
  • if we have a good faith belief that we are required or permitted to do so by law or legal process;
  • to protect our rights, reputation, property or the safety of us or others;
  • to defend or enforce our rights or our obligations;
  • if the disclosure is required by mandatory professional standards; or
  • to a third party with your prior consent to do so.

 

  1. International transfers

We do not transfer your personal data outside the European Economic Area (“EEA”).

 

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which it is collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We have different retention periods for different aspects of personal data that we collect. These retention periods are outlined in our data retention policy, which you can request by contacting us.

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process the personal data and whether we can achieve those purposes through other means.

By law we have to keep basic information about you for six years after you cease accessing the App for tax purposes. Details of retention periods for different aspects of your personal data are available if you contact us.

In some circumstances you can ask us to delete your data. Please see the rights listed in paragraph 9 below. In some circumstances we may anonymise your personal data (so it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

  1. Your legal rights

You have the following rights in relation to your personal data:

To request access to personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data held about you and to check that we are lawfully processing it.

To request correction of the personal data that we hold. This enables the correction of any incomplete or inaccurate data we hold, though we may need to verify the accuracy of the new data provided to us.

To request erasure of personal data. This enables the deletion or removal personal data where there is no good reason for us continuing to process it. A request can also be made for deletion or removal of personal data where the right to object to processing has been successfully exercised (see below), where we may have processed information unlawfully or where we are required to erase personal data to comply with local law. Note, however, that we may not always be able to comply with requests of erasure for specific legal reasons with notification of this given, if applicable, at the time of any request.

To object to processing of personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process information which override your rights and freedoms.

To request restriction of processing of personal data. This enables a request to be made to us to suspend the processing of personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it because it is needed to establish, exercise or defend legal claims; or (d) you objected to use of data but we need to verify whether we have overriding legitimate grounds to use it.

To request the transfer of personal data back to whom it belongs or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which we were given consent to use or where we used the information to perform a contract with you.

To withdraw consent at any time where we are relying on consent to process personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of consent. If consent is withdrawn, we may not be able to provide certain products or services. We advise if this is the case at the time of the withdrawal of consent.

If you wish to exercise any of these rights then please contact us.

No fee usually required

There is no fee to access personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if a request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with a request in these circumstances.

What we may need

We may need to request specific information to help us confirm your identity when making the request and ensure your right to access the personal data (or to exercise any of the other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to the request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if the request is particularly complex or a number of requests have been made.

 

  1. Glossary
LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means processing your personal data when you have freely given your specific, informed and unambiguous indication of your wishes by a statement or by a clear affirmative action which signifies your agreement to the processing of personal data relating to you.

THIRD PARTIES
External Third Parties
  • Amazon Web Services, based in the EU who provide hosting and data storage services providers.
  • Aptus, based in the United Kingdom reviewing clinical data in line with Salford royal hospital
  • Salford royal hospital to collate clinical data for clinical research