Code You Genetics Limited (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms and conditions and any other documents referred to in it) 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 visiting www.codeyougenetics.co.uk and supplying any personal data to us including sensitive personal data (such as medical and racial information) you are accepting and consenting to the practices described in this policy.
Sensitive personal data includes data relating to health, sexual life and race.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Code You Genetics Limited c/o Chase Lodge Hospital, Page Street, Mill Hill, London, NW7 2ED.
IMPORTANT INFORMATION REGARDING THE USE OF INFORMATION BY LABORATORIES WHO CONDUCT THE GENOMIC TESTING.
Information we collect from you
We will collect and process the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our site, www.codeyougenetics.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This may include any information you supply to us on a medical consent form.
- It includes information you provide when you register to use our site, purchase services from us, search for a product, place an order on our site, participate in telephone or online conversations or discussions concerning the services we provide or their results, entering a competition, promotion or survey, or other information that you provide to us such as on online forums or blog comments and when you report a problem with our site.
- The information you give us may include your name, address, e-mail address and phone number, medical history and other personal information, financial and credit card information, personal description and photographs.
Information we collect about you
With regard to each of your visits to our site 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, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for’ page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
- Information obtained from the results of the genomic tests. This information may include the results of any genomics tests you order from us, any analysis of those results, and information our sub-contractors (such as healthcare professionals) who may provide consultations or other input in relation to those results.
Telephone calls and online communications
We may record any conversations we have for you and retain copies of those conversations. This is to monitor the quality of our service, for training purposes and as a record of our conversation with you.
Uses made of the information
We use information held about you in the following ways:
Information you give to us.
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us including the results of any genomic tests you order from us and for any consultation that we may provide. This includes passing your information to the providers of the genomic testing services (such as laboratories) that you order from us.
- to provide you with information about other services we offer that are similar to those that you have already purchased or enquired about;
- to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you and for other goods and services if you have consented to it. If you do not want us to use your data in this way please tick the relevant box situated on the form on which we collect your data;
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you.
We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
ANONYMISED USE OF YOUR DNA TEST RESULTS: WE AND THE LABORATORIES WHO ANALYSE THE DNA EXTRACTED FROM YOUR ORIGINAL SPECIMEN MAY USE YOUR PERSONAL DATA FOR MEDICAL RESEARCH PURPOSES BUT YOUR NAME AND PERSONAL IDENTIFYING DETAILS WILL NOT BE RELEASED OR DISCLOSED.
Disclosure of your information
You agree that we have the right to share your personal information with:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
- Selected third parties including:
- The providers of the genomic tests that your order from us
- Third parties such as your medical practitioners, but only if you give us consent to do this
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
- advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; analytics and search engine providers that assist us in the improvement and optimisation of our site;
- credit card companies in connection with obtaining payment from you.
We will disclose your personal information to third parties:
- 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 we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of us or any of our suppliers, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
Personal data security
We protect information both online and off-line. The transmission of information, including any payment information, is encrypted and protected using Transport Layer Security (TLS). Stored customer information is kept in a secure environment where access is restricted to employees who need the information to perform a specific job. We use PayPal Pro as a payment gateway. We do not store any financial data, but financial information submitted through our site is sent directly to PayPal for authorisation. All communication between our customers, our web server and PayPal is encrypted using TLS.
- Medical data security. Your medical data is stored within our practice management software partner, Practice Pal. Aee below for Practice Pal’s data security policy
- Practice Pal data security policy. We take security seriously and any information we hold about our clients is stored using a purpose built practice management system called Practice Pal. Practice Pal can only be accessed by staff that have been trained and that require access, i.e. our own client service managers and genetic consultants and Practice Pal’s support, technical development and administrative staff. Each staff member has their own login credentials. We do not share this information with any third party and we do not keep information on past customers or about people who ask us to delete the data we hold about them.
Access to PracticePal is via a 256 bit Secure Socket Layer (SSL) certificate, and fully password protected at all times. Through normal use, no data is downloaded to a client machine or leaves the firewalled server (unless the client chooses to download their own copy of the database backup). All our software is password protected and is hosted on RackSpace servers within the EU. These cloud servers reside in RackSpaces’ world-class data centres, with hardware RAID 10 storage, ECC memory, and fully redundant networking and power all the way to the host. The hardware is fully redundant, hot swappable and behind dedicated hardware and software firewalls. All data are automatically backed up, and then that backup is also backed up to a different physical location (within the EU) hosted by a separate data hosting company. RackSpace guarantee that our Cloud Instance(s) will be available 99.9% of the time in any given monthly billing period, excluding Scheduled Maintenance.
Risks of Internet Transmisson: Unfortunately, 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 our site; 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.
Deletion/Destruction of Data: If you return DNA samples to us but do not provide us with the signed documentation and other information necessary for us to continue with processing your test, we will destroy any samples 3 months after we receive them. However please be aware that the laboratory that provides the genomic testing services may require to keep your data to comply with their own legal requirements. We may keep information for our legal records such as copies of correspondence and telephone conversations.
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 can also exercise the right at any time by contacting us at Code You Genetics LTD C/O Chase Lodge Hospital, Page Street, Mill Hill, London, NW7 2ED or firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
Access to information
Please check these policies before you submit any personal data to these websites.
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.