Introduction

This is the privacy and cookie statement (hereinafter: statement) of the private limited company iGene Products B.V. (hereinafter: iGene), established in Nijmegen (Chamber of Commerce number 63823764) and having its office at Oude Haven 102 in (6511 XH) Nijmegen.

This statement applies to all processing of personal data of iGene users. 'Personal data' means any information relating to an identified or identifiable natural person (hereinafter also: data). 'Users' of iGene include all purchasers of its products and services, such as intermediary purchasers and end users, and small and large purchasers, as well as visitors to its websites. The user hereby declares to have read this statement.

All processing of personal data is subject to privacy legislation and regulations, including the General Data Protection Regulation (hereinafter: GDPR) and the GDPR Implementation Act. We are responsible for ensuring that all data processing complies with this legislation.

We consider it important that our services are reliable and transparent. We therefore handle our users' data discreetly and carefully.

This statement provides information about how we handle the data we process from our users. We also provide information about our security policy and user rights.

Position of iGene

iGene is the data controller for processing users' data if and insofar as iGene itself determines the purpose and means of data processing. Examples include data processing in the context of offering its products and services, such as performing DNA tests, analyzing DNA, and delivering DNA reports to users.

iGene is a processor if and insofar as iGene processes data on behalf of third parties. Those third parties are then the controllers. iGene enters into a data processing agreement with the controllers, which regulates, among other things, security, confidentiality and user rights. This statement does not apply to situations where iGene is a processor.

What does iGene primarily do?

iGene primarily focuses on performing DNA tests, analyzing DNA, and delivering DNA reports to users.

Deoxyribonucleic acid (hereinafter: DNA) is a molecule that functions as the main carrier of hereditary information in organisms, including humans. A DNA strand is a kind of collection package of almost all your hereditary information. The package is made up of smaller pieces of DNA. These pieces are called genes. Each gene contains the information for the specific formation of a protein. They pass on all your hereditary characteristics, such as your hair and eye color.

DNA is present in every cell of every human, animal, plant, and fungus. DNA is essentially the blueprint for the existence of organisms. Although a large part of human DNA is identical, some pieces of DNA differ per person. These are the variants in the DNA.

Some variants can be used to analyze where your ancestors came from and whether you are related to each other. Other variants in DNA increase the chance that you have a certain characteristic or get a disease. But often a variant has a small influence or there are more variants that influence health or characteristics. Sometimes there is little evidence that a variant is the cause of a disease or characteristic. In those cases, follow-up research is needed.

You can buy iGene's DNA tests online. When you buy such a test, you will receive a package with instructions on what to do (hereinafter: kit). With iGene, you must collect some biological material in the form of saliva. You send this to iGene.

Subsequently, iGene sends the biological material to a certified laboratory. There, the DNA is extracted from your saliva using high-quality equipment. Over 700,000 different variations of your DNA are mapped. These variations are called single-nucleotide polymorphisms (SNPs). This is pronounced as 'snips'. These are the raw DNA data.

The laboratory sends the raw DNA data back to iGene. iGene performs an analysis of this. This analysis culminates in an individual report with results on various health themes, such as personal characteristics, drug sensitivity, and genetic predisposition to various conditions. See section 5.3 for more information.

Purposes and Legal Bases for Data Processing

iGene only processes data for well-defined, explicitly described, and legitimate purposes and on the basis of legal grounds, as described below. A legal basis is the foundation provided by law to process certain user data for specific purposes.

Creating, Using, and Managing an Account

Creating, using, and managing an account in connection with ordering iGene's products and services. For example, users can create an account in the app and fill in order details in the account. The legal basis for processing data for this purpose is necessity for the performance of the contract.

Ordering Products and Services

Ordering iGene's products and services, such as ordering the kit. A closely related purpose concerns payments for products and services. The legal basis for processing data for these purposes is necessity for the performance of the contract.

Performing DNA Tests, Analyzing DNA, and Delivering DNA Reports

Performing DNA tests and closely related purposes, namely analyzing DNA and delivering DNA reports. For these purposes, genetic data of users is processed. See section 3 for more explanation.

Firstly, iGene has a legal basis for processing data for these purposes. iGene only processes genetic data for these purposes based on user consent.

Secondly, genetic data falls under the category of 'special data'. Special data is additionally protected by law due to its sensitivity.

The processing of special data is prohibited unless a legal exception is met. iGene meets the legal exception to this prohibition: iGene only processes the special data with explicit user consent for these purposes.

Although two 'forms' of consent are distinguished above, iGene asks for consent once for these specific purposes. Therefore, the term 'consent' is used in the singular below.

Website and App Visits and Usage

Visits to and use of iGene's websites and/or apps. The legal basis for data processing depends on the purpose. See section 7 on cookies for more information.

Direct Marketing

Sending commercial communications to our users (direct marketing) regarding, for example, new or modified products or services. This can include newsletters, email marketing, addressed mail, flyers, or (online) advertisements. It may also concern activities that could be interesting for our users. If we have received a user's electronic contact details in the context of selling our products and services, we may use these contact details without further consent for sending commercial communications for 'similar own products and services'. The user can always object to the use of their electronic contact details for marketing. The legal basis for processing the (underlying) data for this purpose is legitimate interest.

Administrative or Fiscal Purposes

Administrative or fiscal purposes towards, among others, the Tax Administration, for example in the context of the turnover we achieve with our products and services. The legal basis for processing data for these purposes is necessity to comply with legal obligations or legitimate interest.

Information Requests, Questions, and/or Complaints

Requests to iGene for information, questions, and/or complaints. The legal basis for data processing depends on the purpose. The basis may be necessity for performance of the contract, legitimate interest, or compliance with legal obligations.

Data Processed by iGene

iGene ensures that the data it processes is adequate, relevant, and limited to what is necessary for the purposes described in section 4. iGene processes the following categories of data:

Creating, Using, and Managing an Account

To create an account for the websites or apps, a user must provide their data. Without providing the data, no account can be created. Specifically, iGene processes the following user data during registration and use of the app:

• Tube code. This is a unique, anonymous code that is randomly generated. The user fills in the tube code on the return sticker. See section 5.3 for more details
• Year of birth (no month or day of birth)
• Ethnicity
• Country of origin
• Language setting of the app
• Meta-information, such as operating system of user's device, version of operating system, app version, and push tokens
• Optional: email address. The user can optionally enter an email address in the app for the following purposes:
  • The user can then receive push notifications by email, while these are normally only sent via the app
  • Should the user lose their tube code, their account can be recovered based on the provided email address
  • The user can request a report and/or raw DNA data via the app. The data is sent to the email address that the user enters once in the app. For this purpose, the email address is not stored by iGene

The user has the option to give consent in the app to share data with a certified professional, such as a doctor in a hospital. The user enters the professional's code in the app with whom the user wishes to share data as well as the client code (internal reference number of the professional). After the connection is made, the professional can view the user's data.

Ordering Products and Services

In the context of ordering products and services, such as ordering the kit, iGene processes the following user data:

• Name, address, and place of residence
• Email address to send the track-and-trace code
• Payment details

The user orders a kit online that is delivered to the provided address. The kit is paid for online.

Performing DNA Tests, Analyzing DNA, and Delivering DNA Reports

Step 1: the user collects biological material and puts it in a tube. The user then sends the biological material in an envelope to iGene accompanied by the tube code.

Step 2: upon return receipt of the envelope, iGene processes the following user data:

• Biological material
• Tube code. Since the tube code is not linked – and cannot be linked – to other user data, iGene does not know which natural person the biological material comes from. iGene therefore cannot trace which name belongs to the biological material

Step 3: iGene sends the following user data to a certified laboratory:

• Biological material, which is provided with
• A label with the tube code and a barcode variant of the tube code

Step 4: iGene receives the following results back from the laboratory:

• A genome studio file. This is a file in which the biological material per tube code is mapped in SNPs, as explained in section 3

Step 5: iGene sends the laboratory results to iGene GmbH. iGene GmbH analyzes the laboratory results, performs quality controls, and prepares individual DNA reports. For this purpose, iGene GmbH processes the following user data:

• SNPs
• Tube code
• Year of birth
• Ethnicity
• Country of origin
• Language setting of the app

The final DNA report prepared by iGene GmbH contains results about:

Personal characteristics, such as food intolerances. Examples include predisposition to alcohol sensitivity, gluten intolerance (celiac disease), lactose intolerance, norovirus resistance, hereditary fructose intolerance, and hemochromatosis (iron overload).

Drug sensitivity based on the genetically determined function of enzymes. For example, iGene can determine for a number of enzymes whether the enzymes work faster or slower than normal, such as the BChE enzyme, CYP1A2 enzyme, and MTHFR enzyme. Based on enzyme function, iGene can map or evaluate the required dosage for a number of medications, such as Lornoxicam, Abacavir, and Amitriptyline.

Genetic predisposition to various conditions, such as stroke, Parkinson's disease, and cardiovascular diseases.

For a complete overview, please refer to iGene's website. Click here.

The results are displayed in iGene's app or in a PDF report. Finally, the user can discuss the report with a doctor and adjust their lifestyle based on their advice if necessary.

Website and App Visits and Usage

When visiting the websites or apps, iGene's servers or third parties may store data. This concerns visit data. 'Visit data' includes URL, IP address, browser type, browser language, date, time of visit, and data relating to click and usage behavior. See section 7 on cookies for more information.

Direct Marketing

For commercial communications to our customers (direct marketing), iGene processes data such as email address, first name, last name, address, and/or telephone number.

Administrative or Fiscal Purposes

For administrative or fiscal purposes towards, among others, the Tax Administration, only the necessary data is provided, such as an account number or user name.

Information Requests, Questions, and/or Complaints

For information requests, questions, and/or complaints, iGene processes the data provided by the user for that purpose, such as name, address, telephone number, and/or email address.

Third Parties Processing Your Data

The principle is that iGene does not share your data with third parties. However, in the following situations, iGene may share your data:

• With affiliated companies, operational groups, subsidiaries, branches, and/or (other) third parties if and insofar as necessary for the purposes described above. Specifically, iGene Products B.V. handles logistics between user and laboratory on the one hand, and between laboratory and iGene GmbH on the other hand. iGene GmbH performs the analysis. iGene B.V. provides knowledge-based support and quality control in the analysis for iGene GmbH. Additionally, iGene B.V. provides knowledge-based support to iGene Products B.V. at the explicit request of users, for example to answer questions about DNA reports.
• With processors, i.e., parties that process your data on behalf of iGene, such as IT providers. In such cases, these third parties may only use your data for the purposes described above and only on iGene's instructions. iGene only engages processors who guarantee that appropriate technical and organizational measures are in place and protect data subjects' rights.
• With laboratories, with which cooperation is based on an agreement, who map the SNPs and subsequently feed back to iGene.
• The user has the option to give consent in the app to share data with a certified professional.
• With its employees if and insofar as necessary for the performance of their duties. In such a case, access will be granted to the extent necessary for the purposes described above and only if the employee is bound by confidentiality.
• If and insofar as required by law, a court order or (other) legal proceedings, such as with supervisory authorities, judicial authorities, or other competent government authorities to establish and/or exercise iGene's rights. Examples include the Tax Administration, pension providers, UWV, and Occupational Health Service.
• In connection with a business transaction, such as a split-off, merger, consolidation, or sale of assets or in case of bankruptcy.

If applicable, iGene will require third parties to perform processing activities in accordance with iGene's policies and guidelines regarding data protection.

If and insofar as consent is required for sharing data with third parties, iGene will ask for your consent.

Cookies

To the extent that we use cookies to collect, combine, or analyze data about your use of our websites and apps so that you can be treated better or differently, we process your data. For example, by tracking which pages you visit on our websites and apps, we engage in profiling. For each data processing, we have a legal basis and the privacy statement you are reading, the Cookiecode privacy statement, and Google's privacy statement apply. Click here to read our cookie statement.

Links to Other Parties

iGene's websites and apps may contain links to third-party websites and/or apps. When users visit third-party websites and/or apps, those parties' statements apply. iGene is not responsible for how third parties handle users' data.

In cases where third parties, including media agencies and advertising networks, process data for their own purposes and with their own means, they do so as controllers. For example, these controllers may build their own profiles based on user behavior on the websites where media agencies and advertising networks purchase advertising space. These profiles are then sold to advertisers for (re)targeting purposes.

iGene is neither directly nor indirectly liable for the actions or omissions of third parties, including other controllers.

User Rights

General

Below, the user's rights regarding the processing of their data by iGene are explained. For any request, the user can send an email to iGene (info@igene.eu) or a letter by post.

If and to the extent legally permitted, iGene may request a copy of valid identification for identification purposes. The portrait photo and citizen service number can be redacted. The copy of the identification will be deleted immediately after identification.

If the user is under 16 years of age, the user needs permission from their parent(s) or guardian(s) to provide data to iGene. iGene will in that case ask for consent from parent(s) or guardian(s). They can always have the data provided to iGene adjusted, protected, or deleted.

Right to Information

We are obliged to inform the user about our identity, what data we process from the user, how long, for what purposes, on what basis, and to whom we provide data. All this information can be found in this statement. If the user wants more information, we will provide it in principle free of charge.

Right of Access

The user does not need to give a reason for an access request. The right of access only relates to access to the user's own data.

Right to Rectification

The user can ask iGene to rectify their data directly. The user also has the right to complete incomplete data.

'Right to be Forgotten'

In certain cases, we are obliged to delete data at the user's request without undue delay. This includes cases where data is no longer necessary for the purposes for which it was processed or if the user has withdrawn their consent and there is no other legal basis for processing. If and insofar as iGene has shared data with other parties, and is obliged to delete data, it will take all reasonable measures to inform those other parties that links and copies of data should also be deleted.

The 'right to be forgotten' is in quotation marks because we cannot always delete all user data. Sometimes, for example, processing is still necessary for compliance with legal obligations or for establishing, exercising, or defending legal claims. We therefore always make an assessment when such a request is made.

Right to Restriction of Processing

The user has, in principle, the right to have the processing of their data restricted, for example if the user disputes the accuracy of their data.

Notification of Rectification, Erasure, or Restriction

Unless impossible or involving disproportionate effort, we will inform recipients of the user's data of any rectification, erasure, or restriction of processing. iGene will provide information about these recipients if the user requests this.

Right to Data Portability

Under certain conditions, the user has the right to data portability: the user has this right only with respect to data they themselves have provided to iGene AND if the processing is based on consent or a contract to which the user is a party. 'Data portability' means that the user can request iGene to receive their data. The user can then store this data for personal reuse. The user can also transfer this data to another company or ask iGene to do this for them.

Withdrawal of Consent

If and insofar as data processing is based on consent, the user has the right to withdraw that consent at any time. After consent is withdrawn, iGene will ensure that it ceases processing the data for that purpose. However, the processing of data from the period before withdrawal remains lawful.

Right to Object

The user has, in principle, the right to object to the processing of their data. After the objection, iGene will in principle stop processing the data.

Separately from this, the user can easily and free of charge object to the use of their electronic contact details for, for example, our newsletters. For instance, the user can click 'unsubscribe' at the bottom of all our emails or email us at info@igene.eu with such a request. After that, we will no longer use the relevant email address.

For objection to the placing or reading of cookies or the deletion of cookies, the user must consult the browser settings or help function. Some functions on the websites and apps may no longer work if cookies can no longer be placed or read. If a user would like more information about this, they can contact info@igene.eu. Note that cookie settings must be adjusted separately for each browser and computer. If the user wants to disable cookies from specific parties, this can be done via www.youronlinechoices.com.

Complaint to Data Protection Authority or Court

If the user believes that the processing of their data infringes the law, they can contact us. However, the user also has the right to lodge a complaint with the competent authority, such as the Data Protection Authority, or to go to court.

Limitations of Rights

Sometimes we may limit the user's rights, for example in the context of preventing, investigating, detecting, and prosecuting criminal offenses, such as fraud.

Retention Periods

iGene does not keep data longer than necessary for the purposes for which iGene processes the data. After that, iGene will delete or anonymize the data, unless iGene needs certain data longer for another purpose. If that is the case, iGene has a legal basis for this and will ensure that this data is only accessible for that other purpose. Here are some important retention periods for iGene:

• Order data, as referred to in section 5.2, will be deleted no later than 6 months after we have requested the data.
• Biological material will be destroyed by the laboratory no later than 6 months after the SNPs have been mapped. This happens in line with the agreements iGene has made with the laboratory.
• Raw DNA data, DNA analyses, and DNA reports remain available only until the user terminates or deletes their account. The raw DNA data is necessary for implementing updates and expansions of the DNA reports. When the user terminates or deletes their account, the raw DNA data and associated DNA analyses and DNA reports will be immediately deleted.

Entirely separate from the processing of genetic data, iGene must retain certain documents for a minimum period for tax or administrative purposes. Usually, the retention period is 5 or 7 years after a certain event. In those cases, we will only retain the data necessary to meet our legal obligations. After the legal retention periods, iGene will delete or anonymize the data.

Security

iGene takes the security of your data very seriously. Therefore, iGene has taken appropriate technical and organizational measures to ensure that the data is well secured and processed exclusively for specific purposes. iGene has taken into account the processing risks of the data in its security, especially as a result of loss or unlawful use of your data. iGene also ensures that only employees who need it for the performance of their function can access data for specific purposes.

The storage of genetic data on the one hand, and the analyses and reports on the other hand, are strictly separated:

• Storage takes place on internal, secured servers in a database designed by iGene. These servers are located in iGene's buildings. Only specific iGene software can work with the genetic data.
• The analyses and reports are processed on external, secured servers. These are not in iGene's network. The servers are managed and hosted by a third party, namely OVH in Germany. The analyses are stored on a server that is not connected to the public internet. The reports are on servers that store minimal data to be able to offer the reports to the user. The tube code is only stored on these servers as a hash. A hash is a form of pseudonymization, thus of encryption.
• The internal and external servers communicate with each other via an application programming interface (API). An API is an interface that enables software on separate servers to communicate with each other. You could say that iGene is the messenger submitting a request to a third party. Subsequently, that third party feeds back the answer to iGene. The API is only deployed for the specific purpose of analyses.
• The genetic data is only linked to a tube code and/or year of birth, not to any other data. See further under section 5.3.
• Secure backups of all genetic data are made daily. These backups are encrypted based on the AES 256 standard and stored in the cloud at Google Cloud Storage in Eemshaven without any other identifiers.
• The user has access to their own data in the app through the unique tube code and year of birth. Payment(s) to iGene take place via Payment Service Provider Pay.nl via an encrypted connection based on SSL/TLS.

Although there are always risks associated with data processing, iGene will continuously review and update its security measures.

Data Breaches

If a personal data breach has occurred (hereinafter: data breach), we must report this to the Data Protection Authority within 72 hours after we have become aware of it, unless it is unlikely that the data breach poses a risk to the rights and freedoms of users.

If it is likely that the data breach poses a high risk to the rights and freedoms of users, we are obliged to also notify the data breach to the users.

A data breach exists, among other things, if data has been lost in a security incident, such as a hack in our systems, or if we cannot rule out unlawful processing of data.

If you encounter a security incident or data breach on our websites or apps, you must report this immediately by sending an email to info@igene.eu or calling +31 (0)10 310 4200.

International Transfers

All biological material, raw DNA data, DNA analyses, and DNA reports are stored and (further) processed in the European Economic Area (hereinafter: EEA).

However, some data may be transferred and (further) processed in a country outside the EEA, such as statistical analytical data relating to orders on iGene's website. This data is processed based on cookies and/or similar techniques. iGene uses software from Google Inc. for this, such as Google Analytics and Google Tag Manager. Google Inc. has its servers located in the United States, among other places. If a user signs up for iGene's newsletter, their email address may end up on a server of the company MailChimp in the United States.

If and insofar as data is transferred to recipients in a country outside the EEA, the principle is that such transfer is only allowed if that country offers an adequate level of protection. If there is no adequate level of protection in a country outside the EEA, we will ensure appropriate safeguards to protect the data as well as possible. An example of this is the use of model contracts that have been approved by the European Commission.

If there are also no appropriate safeguards in a country outside the EEA, we will only transfer your data if there is a legal exception. An example of this is explicit consent from the user.

If the user wants to know what safeguards iGene implements to protect data and where these can be consulted, the user can contact us.

Contact Details

For questions, requests, suggestions, or complaints about this statement or data processing, you can contact iGene via info@igene.eu or by mail at Oude Haven 102, (6511 XH) Nijmegen.

You can also contact our data protection officer: Mr. R. Haan with phone number +31 (0)10 310 4200 and email address r.haan@igene.nl.

Changes

We may change this statement if developments give rise to this. The most current statement can be found on our website. We recommend that the user regularly consult this statement to stay informed of the changes. Continued use of our products and services or visit to our websites means that the user has read the modified statement.

Glossary

Below follows an explanation of some terms used in this statement without initial capital letter (unless otherwise indicated). The singular form, plural form, and conjugations of each term can be used interchangeably in the statement. Where a word with 'masculine' gender is used, all other genders, including feminine, should be read equally.

Anonymization

This is an irreversible process to ensure that data can no longer be traced back to data subjects. Data subjects are natural persons (individuals) whose data is processed. In this statement, this may include the 'user'.

Apps

All applications and platforms of iGene.

Data Protection Authority

The Data Protection Authority is our national supervisor in the field of data protection. They assess whether organizations process data in accordance with applicable legislation and regulations.

Special Data

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a person's sex life or sexual orientation. It is prohibited to process special data unless an exception is met. iGene meets an exception to the prohibition because it asks for explicit consent from its users to process genetic data. In addition to the fact that iGene meets the exception, iGene also always has a legal basis to process this data. See below under 'Legal Bases'.

Cookies

Cookies are small text files that a server sends to a browser when the products and services are used. Cookies remember the data that a user enters for a subsequent visit, so that the content of the products and services can be tailored to the user and it is not necessary to re-enter data. In addition to cookies, iGene may use 'similar techniques', such as JavaScripts, tracking pixels, and web beacons. These are techniques that ensure that a system can collect information, store it, and then transmit it. In this statement, cookies and similar techniques are collectively referred to as 'cookies'.

Users

All (potential) clients of iGene's products and services whose data is processed. Users also include visitors to iGene's websites and apps and recipients of the newsletter. Some examples of users:

• Natural persons who place an order online with iGene
• Large purchasers or resellers without their own logistics. A large purchaser can use iGene's logistics to serve their own customers with kits. The app that a large purchaser or reseller uses may have its own listing in the app stores and its own house style, but technically the app is identical to iGene's
• Large purchasers with their own logistics. Some large purchasers of kits do not use iGene's logistics. They use their own platform and infrastructure to share DNA reports with their customers

Data

'Personal data' means any information relating directly or indirectly to an individual without the need for that individual's name to be known. Examples include name, address, place of residence, email address, telephone number, genetic data, cookie IDs, tracking data, commercial, advertising cookies, and financial data. In this statement, personal data is also referred to as 'data.'

Legal Bases

To lawfully process user data, iGene needs a legal basis. This is the basis provided by law to be allowed to process user data. The legal bases that are most important to us are discussed below:

Consent

One of the legal bases for processing data is prior consent of the user for one or more specific purposes. 'Consent' means any freely given, specific, informed, and unambiguous indication of the user's wishes by which the user, by a statement or by a clear affirmative action, signifies agreement to data processing. For processing genetic data, iGene relies on consent.

But consent is not the only basis for being allowed to process data. Other, equally important bases for being allowed to process certain user data WITHOUT consent are the following:

Necessity for Performance of the Contract

The data processing is necessary to take measures at the user's request before concluding a contract or for the performance of any contract between the user and iGene. For example, we must process data if a user orders products or services from iGene, such as name, address, and place of residence.

Necessity to Comply with Legal Obligations

The data processing is necessary to comply with legal obligations that rest on iGene. This includes obligations towards the Tax Administration and UWV.

Necessity for Legitimate Interests

The data processing is necessary for the purposes of the legitimate interests pursued by iGene or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the user that require protection of data. In this statement, we briefly refer to this as 'legitimate interest'. To be able to rely on this basis, we will first determine whether there are legitimate interests. Think of processing that falls under our normal business operations or daily management of iGene. Then we ask ourselves whether we can achieve the same result with less data or through a less intrusive way. iGene will also perform a balancing test. This means that we weigh the interests and rights of the user against our own. If we come to the conclusion that our interests outweigh those of the user, we will rely on this basis.

Recipient

Natural or legal person, public authority, agency, or other body, whether or not a third party, to whom data is disclosed.

Products and Services

All products and services that iGene supplies or provides to a user. iGene's general terms and conditions apply to the products and services. Click here for the general terms and conditions. iGene reserves the right to modify the products and services at any time. Products and services also include all iGene websites and apps.

Pseudonymization

The processing of data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the data are not attributed to an identified or identifiable person. Encryption is a form of pseudonymization.

Controller

Organization that determines purpose and means for the processing of data. For example, iGene is controller for processing data for performing DNA tests, analyzing DNA, and delivering DNA reports to users.

Processing

(A set of) operations performed on (a set of) data, whether or not by automated means. Examples include collecting, recording, organizing, storing, modifying, retrieving, consulting, using, disclosing, transmitting, consulting, using, making available, and deleting data.

Processor

Organization that processes data on behalf of the controller.

Deletion

Erasure of data so that it can neither directly nor indirectly be retrieved.

Websites

All websites of which iGene is owner or domain name holder, which iGene controls or operates in any way, including but not limited to igene.nl.

© 2022 iGene