- We are committed to safeguarding the privacy of 54gene website visitors and service users including visitors to our Diagnoseme web platform.
- This notice applies where we are acting as a data controller with respect to the personal data of our website visitors and service user; in other words, where we determine the purposes and means of the processing of that personal data.
- In this notice, “we”, “us” and “our” refer to 54gene Inc. registered in Nigeria as Stack Diagnostics Nigeria Ltd carrying out business under the trade name 54Gene. [ For more information about us, see Section 12.1]
How we use your personal data
- We collect and process genetic data and biological samples as well as information relating to your health (all together referred to as “special category data”) provided by you for the purpose of carrying out diagnostic tests to provide you with a result. The legal basis for this processing is your explicit consent by signing up to our DiagnoseMe platform.
- We may collect your information and data from corporate clients to whom we provide Diagnostic services. Where a corporate client provides personal information of their employees, they act as Data Controllers and are responsible to their employees; and we act as Data Processors. Our legal basis for carrying out processing activity in this instance shall be in the performance of the contract with the corporate client.
- We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interest of monitoring and improving our website and services.
- We may process your DiagnoseMe account data (“account data”) as provided by you which includes your name and email address. We may process account data for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests for the proper administration of our website and business.
- We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, location of residence, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is in the performance of the contract to provide you this service.
- We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”) for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent.
- We may process any of your personal data identified in this notice where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
- In addition to the specific purposes for which we may process your personal data set out above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of other natural persons.
Providing your personal data to others
- We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this notice. [ Information about our group of companies can be found at 54gene.com.]
- We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- We may disclose your personal information and special category of information to our suppliers or subcontractors insofar as reasonably necessary for providing any of our services as stated in our terms.
- Financial transactions relating to our website and services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
- In addition to the specific disclosures of personal data set out above, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
- We and our other group companies have offices and facilities in Nigeria, the United States and the United Kingdom. The National Information Technology Development Agency and the Attorney General of Nigeria have recognized these countries as adequate with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards.
Retaining and deleting personal data
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- We will retain your personal data as follows:
- personally identifiable information relating to your DiagnoseMe account information will be retained for a minimum period of one year following your sign up, and for a maximum period of 2 years following sign up to have it retained by us.
- genetic data and biological samples provided by you for diagnostic tests will be retained by our labs for a minimum period of one year and a maximum period of 3 years.
- In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the research purposes and activities of the Company.
- Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- We may update this notice from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this notice.
- We will notify you of changes to this notice by email or through the private messaging system on our website.
- Some of the rights you have for providing us your information are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
- Your principal rights under data protection laws for providing your data to 54Gene are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
- You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data when logged into our website by opening the settings on your account information.
- You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
- In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include where: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of this right to erasure where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
- In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
- You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
- You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
- To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine- readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
- If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. In Nigeria, you may do so to do the National Information Technology Development Agency.
- To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section.
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
- status – to help us determine if you are logged into our website;
Cookies used by our service providers
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- Blocking all cookies will have a negative impact upon the usability of many websites.
- If you block cookies, you will not be able to use all the features on our website.
- This website is owned and operated by 54gene Inc registered in Nigeria as Stack Diagnostics Nigeria Limited carrying on business under the trade name 54Gene.
- You can contact us:
- by using our website contact form;
- by telephone, on [the contact number published on our website from time to time; or
- by email, using [the email address published on our website from time to time.