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Privacy Policy iGene Products B.V.

This privacy policy is a translation of the orignal Dutch privacystatement: https://www.igene.nl/privacyverklaring

last modified on October 26, 2022


  1. Introduction

  2. Position of iGene

  3. What does iGene primarily do?

  4. Purposes and bases of data processing

  5. Data that iGene processes

  6. Third parties that process your data

  7. Cookies

  8. Links to other parties

  9. Rights of the user

  10. retention period

  11. Security

  12. Data leaks

  13. Transfer

  14. Contact details

  15. Amendments

  16. Glossary

  1. Introduction

    This is the privacy and cookie statement (hereinafter: statement ) of the private company with limited liability iGene Products BV (hereinafter: iGene ), established in Nijmegen (Chamber of Commerce number 63823764) and with offices at Oude Haven 102 in (6511 XH) Nijmegen.

    This statement applies to any processing of personal data of the users of iGene. 'Personal data' is all information about an identified or identifiable natural person (hereinafter also: data ). 'Users' of iGene include all buyers of its products and services, such as intermediary buyers and end buyers and small and large buyers, 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 laws and regulations, including the General Data Protection Regulation (hereinafter: AVG ) and the AVG Implementation Act. We are responsible for ensuring that any data processing complies with these laws and regulations.

    We believe it is important that our services are reliable and transparent. We therefore handle the data of our users discreetly and carefully.

    This statement provides information about how we handle the data we process from our users. In addition, we provide information about, among other things, our security policy and the rights of the user.

  2. Position of iGene

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

    iGene is a processor if and insofar as iGene processes data for third parties. Those third parties are then responsible. iGene concludes a processing agreement with those responsible, which, among other things, regulates security, confidentiality and the rights of the users. This statement does not apply to the situation that iGene is a processor.

  3. What does iGene primarily do?

    iGene is primarily concerned with conducting DNA tests, analyzing DNA and providing 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 collective package of almost all your hereditary information. The package is made up of smaller pieces of DNA. Those 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 found in every cell of every human being, animal, plant and fungus. DNA is, on balance, the design for the existence of organisms. Although much of the DNA of people is the same, some pieces of DNA differ from person to person. Those are the variants in the DNA.

    Some variants can be used to analyze where your ancestors come from and whether you are related. Other variants in the DNA increase the chance that you have a certain characteristic or develop a disease. But often a variant has a small influence or there are more variants of influence on health or characteristics. Sometimes there is little evidence that a variant is the cause of a disease or trait. In those cases, further investigation is required.

    You can buy the iGene DNA tests online. If you buy such a test, you will receive a package with an explanation of what to do (hereinafter: kit ). With iGene you have to take some biological material in the form of saliva. You send that to iGene.

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

    The lab sends the raw DNA data back to iGene. iGene makes 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 disorders. For more information, see section 5.3.

  4. Purposes and bases of data processing

    iGene only processes data for specific, explicit and legitimate purposes and on the basis of the legal bases, as described below. A legal basis is the basis that the law provides for the processing of certain data of a user for specific purposes.

    1. Create, use and manage an account

      Creating, using and managing an account in connection with ordering products and services from iGene. For example, the user can create an account in the app and enter order details in the account. The basis for processing data for this purpose is necessity for the performance of the agreement.

    2. Ordering products and services

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

    3. Performing DNA tests, analyzing DNA and delivering DNA reports

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

      In the first place, iGene has a legal basis for processing data for these purposes. iGene processes genetic data for these purposes only on the basis of the user's consent.

      Secondly, genetic data falls under the category of 'special data'. Due to their sensitivity, special data are given extra protection by the legislator.

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

      Although two 'forms' of permission are distinguished above, iGene will ask you for permission once for these specific purposes. The term 'consent' is therefore also used in the singular hereafter.

    4. Visit to and use of websites and/or apps

      Visiting and using the iGene websites and/or apps. The basis for processing data depends on the purpose. See also section 7 on cookies.

    5. Direct marketing

      Sending commercial communications to our users (direct marketing) in the context of, for example, new or changed products or services. You can think of newsletters, e-mail marketing, addressed mail, flyers or (online) advertisements. It may also include activities that may be of interest to our users. If we have received a user's electronic contact details in the context of the sale of our products and services, we may use these contact details without further permission to send commercial communications for 'own similar products and services'. The user can always object to the use of his electronic contact details for marketing.

    6. Administrative or tax purposes

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

    7. Requests for information, questions and/or complaints

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

  5. Data that iGene processes

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

    1. Create, use and manage an account

      In order to create an account for the websites or apps, a user must provide his data. No account can be created without providing the data. Specifically, iGene processes the following user data when registering and using the app:

      • Tube code. This is a unique, anonymous code that is randomly generated. The tube code is filled in by the user on the return sticker. See further under section 5.3

      • Year of birth (no birth month or day of birth)

      • Ethnicity

      • Country of origin

      • Language setting of the app

      • Meta information, such as user's device operating system, operating system version, 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 also receive push messages by e-mail, while they are normally only sent via the app;

        • Should the user lose his tube code, his account can be recovered based on the specified e-mail address; and

        • The user can request a report and/or raw DNA data through the app. The data is sent to the e-mail address that the user enters once in the app. For this purpose, the e-mail address is not stored with iGene.

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

    2. Ordering products and services

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

      • Name, address and place of residence

      • Email address to send the track and trace code

      • Payment details

        The user orders a kit online, which is delivered to the specified address. The kit is paid for online.

    3. Performing DNA tests, analyzing DNA and delivering DNA reports

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

      Step 2: iGene processes the following information from the user upon receipt of the envelope:

      • Biological material

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

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

      • Biological material, which is provided

      • A label with the tube code and a barcode variant of the tube code Step 4: iGene receives the following results from the laboratory:

      • A genomestudio file. This is a file in which the biological material has been mapped into SNPs per tube code, as explained in section 3

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

      • SNPs

      • Buiscode

      • Year of birth

      • Ethnicity

      • Country of origin

      • Language setting of the app

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

      • Personal characteristics, such as food intolerances. You can think of a 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 action 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 the action of enzymes, iGene can identify or evaluate the required dosage for a number of medicines, such as Lornoxicam, Abacavir and Amitriptyline.

      • Genetic predisposition to various disorders, such as stroke, Parkinson's disease and cardiovascular disease.

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

        The results are displayed in the iGene app or in a PDF report. Finally, the user can discuss the report with a doctor and possibly adjust his/her lifestyle on his/her advice.

    4. Visit to and use of websites and/or apps

      When you visit the websites or apps, the servers of iGene or third parties can store data. This concerns visitor data. 'Visit data' includes, among other things, URL, IP address, browser type, language of the browser, date and time of the visit and data relating to click and usage behaviour. See also section 7 on cookies.

    5. Direct marketing

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

    6. Administrative or tax purposes

      Only the necessary information, such as an account number or name of the user, is provided for administrative or tax purposes towards, among others, the Tax and Customs Administration.

    7. Requests for information, questions and/or complaints

      For a request for information, questions and/or complaints, iGene processes the data provided by the user for that purpose, such as name, address, telephone number and/or e-mail address.

  6. Third parties that process your data

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

    • With affiliated companies, operating groups, subsidiaries, branches and/or (other) third parties if and insofar as this is necessary for the purposes described above. Specifically, iGene Products BV takes care of the logistics between the user and the laboratory on the one hand, and between the laboratory and iGene GmbH on the other hand. iGene GmbH performs the analysis. iGene BV is engaged in knowledge content support and quality control in the analysis for iGene GmbH. In addition, iGene BV offers knowledge-related support to iGene Products BV at the explicit request of the users, for example to answer questions about the DNA reports.

    • With processors, i.e. parties that process your data for iGene, such as IT suppliers. In such cases, these third parties may only use your data for the purposes described above and only on instructions from iGene. iGene only engages processors who guarantee that appropriate technical and organizational measures have been taken and protect the rights of those involved.

    • With laboratories, with whom we collaborate on the basis of an agreement, that map the SNPs and then provide feedback to iGene.

    • The user has the option to give permission 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 a duty of confidentiality.

    • If and to the extent required by law, a court order or (other) legal process, such as with regulators, courts or other competent government authorities to establish and/or exercise iGene's rights. You can think of the Tax Authorities, pension providers, UWV and Arbodienst.

    • In connection with a business transaction, such as a divestiture, merger, consolidation or sale of assets or in the event of bankruptcy.

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

    If and insofar as permission is required for sharing data with third parties, iGene will ask you for this.

  7. Cookies

    Insofar as we use cookies with the aim of collecting, combining or analyzing 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 keeping track of which pages of our websites and apps you visit, we perform profiling. We have a basis for every processing of data and the privacy statement that you read, the cookie code privacy statement and the Google privacy statement apply. Click here to read our cookie statement .

  8. Links to other parties

    The iGene websites and apps may contain links to third party websites and/or apps. When users visit the websites and/or apps of third parties, the statements of those parties apply. iGene is not responsible for the way in which third parties handle user data.

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

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

  9. Rights of the user

    1. General

      The following explains what the user's rights are with regard to the processing of his data by iGene. For any request, the user can send an e-mail to iGene (info@igene.eu) or a letter by post.

      If and insofar as permitted by law, iGene may request to provide a copy of a valid proof of identity for identification purposes. In addition, portrait photo and citizen service number can be shielded. The copy of the ID will be deleted immediately after identification.

      If the user is younger than 16 years, the user needs permission from his or her parent(s) or guardian(s) to provide data to iGene. In that case, iGene will ask for permission from parent(s) or guardian(s). They can always adjust, protect or delete the data provided to iGene.

    2. Right to information

      We are obliged to inform the user about our identity, which data we process from the user, for how long, for what purposes, on what basis and to whom we provide data. All this information can be found by the user in this

      clearance. If the user wants more information, we will in principle provide it free of charge.

    3. Right of access

      The user has the right to inspect his data. For example, the user has the right to obtain information from iGene about whether we process the user's data, and if so, which data, what the purposes of the processing are, to which parties data is provided, what the retention periods are and the available information. about the origin of the data (if the data does not originate from the user). The user does not have to give a reason for a request for access. The right of access only relates to access to the user's own data.

    4. Right to rectification

      The user can ask iGene to have his data rectified immediately. The user also has the right to have incomplete data completed.

    5. 'Right to be forgotten'

      In certain cases, we are required to delete data without unreasonable delay at the request of the user. You can think of cases in which data are no longer necessary for the purposes for which they are processed or if the user has withdrawn his consent and there is no longer any other basis for the 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 will also be deleted.

      The 'right to be forgotten' is in quotes. We are not always allowed to delete all data of the user. Sometimes, for example, the processing is still necessary to comply with legal obligations or to establish, exercise or substantiate claims. We therefore always weigh up when such a request is made.

    6. Right to restriction of processing

      In principle, the user has the right to have the processing of his data restricted, for example if the user does not agree with the correctness of his data.

    7. Notice of Rectification, Deletion or Restriction

      Unless it is impossible or involves a disproportionate effort, we will inform the recipients of the user's data of any rectification, deletion or restriction of processing. iGene will provide information about these recipients if requested by the user.

    8. Right to data portability

      Under certain conditions, the user has the right to the portability of his data: the user only has this right with regard to data that he himself has provided to iGene and if the processing is based on permission or an agreement to which the user himself is a party. The 'portability of data' means that the user can make a request to iGene to receive his data. Subsequently, the user can store this data for personal reuse. The user can also

      then pass on his data to another company or ask iGene to do this for the user.

    9. Withdraw consent

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

    10. Right of objection

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

      Apart from this, the user can easily and free of charge object to the use of his electronic contact details for, for example, our newsletters. For example, the user can click on 'unsubscribe' at the bottom of all our emails or email us at info@igene.eu with a request to do so. After that, we will no longer use the e-mail address in question.

      To object to the placement or reading of cookies or the removal of cookies, the user must consult the settings or help function of the browser. Some functions on the websites and apps may no longer work if cookies can no longer be placed or read. If a user wants more information about this, he can contact info@igene.eu . Please note that the cookie settings must be adjusted separately for each browser and computer. If the user wishes to disable the cookies of specific parties, this can be done via www.youronlinechoices.com .

    11. Complaint to the Dutch Data Protection Authority or to the court

      If the user believes that the processing of his data violates the law, he can contact us. However, the user also has the right to submit a complaint to the competent authority, such as the Dutch Data Protection Authority, or to go to court.

    12. Limitations of rights

      Sometimes we can limit the rights of the user, for example in the context of the prevention, investigation, detection and prosecution of criminal offenses such as fraud.

  10. Retention periods

    iGene does not store 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 basis for this and will ensure that this data is only accessible for that other purpose. The following are some important retention periods for iGene:

    • Order data, as referred to in paragraph 5.2 , will be deleted no later than 6 months after we have requested the data.

    • Biological material is destroyed by the laboratory no later than 6 months after the SNPs have been mapped. This is done in line with the agreements that iGene has made with the laboratory.

    • Raw DNA data, DNA analyzes and DNA reports will only be available until the user terminates or deletes their account. The raw DNA data is necessary for making updates and expansions of the DNA reports. When the user terminates or deletes their account, the raw DNA data and associated DNA analyzes and DNA reports will be immediately deleted.

    • Quite apart from the processing of genetic data, iGene must keep certain documents for a minimum period of time 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 data that is necessary to comply with our legal obligations. After the legal retention periods, iGene will delete or anonymize the data.

  11. Security

    iGene takes the security of your data very seriously. That is why iGene has taken appropriate technical and organizational measures to ensure that the data is properly secured and is only processed 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 job can view data for specific purposes.

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

    • The storage takes place on internal, secure servers in a database designed by iGene. These servers are located in the iGene buildings. Only specific iGene software can work with the genetic data.

    • The analyzes and reports are processed on external, secure servers. These are not in the network of iGene. The servers are managed and hosted by a third party, namely OVH in Germany. The analyzes 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, i.e. encryption.

    • The internal and external servers communicate with each other through an application programming interface ( API ). An API is an interface that allows software on separate servers to communicate with each other. You could say that iGene is the messenger who makes a request to a third party. The third party then feeds back the answer to iGene. The API is only used for the specific purpose of analytics.

    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 his own data in the app by means of the unique tube code and the year of birth. Payments (instructions) to iGene take place via the Payment Service Provider Pay.nl via an encrypted connection based on SSL/TLS.

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

  12. Data leaks

    If a data breach has occurred (hereinafter: data breach ), we must report this to the Dutch Data Protection Authority within 72 hours of becoming 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 report the data breach to the users as well.

    A data breach occurs, for example, if data is lost during a security incident, such as a hack into our systems, or if we cannot reasonably rule out the possibility of 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 e-mail to info@igene.eu or by calling +31 (0)10 310 4200.

  13. Transfer

    All biological material, raw DNA data, DNA analyzes 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 related to orders placed on the iGene website. This data is processed on the basis of 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 in the United States, among others. If a user registers for the iGene newsletter, his/her e-mail 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 starting point is that such transfer is only permitted 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 provide appropriate safeguards to protect the data as well as possible. An example of this is the use of model contracts approved by the European Commission.

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

    If the user wants to know which guarantees iGene uses to protect data and where they can be consulted, the user can contact us.

  14. Contact details

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

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

  15. Amendments

    We may change this statement if developments give cause to do so. The most current statement can be found on our website. We advise the user to consult this statement regularly, so that he is kept informed of the changes. Continued use of our products and services or visits to our websites means that the user has read the amended statement.

  16. Glossary

    The following is an explanation of some of the terms used in this statement without initial capitals (unless otherwise stated). 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 the feminine, should be read equally.

    1. Anonymize

      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'.

    2. Apps

      All iGene applications and platforms.

    3. Authority for Personal Data

      The Dutch Data Protection Authority is our national data protection supervisor. It assesses whether organizations process data in accordance with the applicable legal regulations.

    4. Special data

      Personal data revealing race or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a person, health data or data relating to a person's sexual behavior or sexual orientation. It is prohibited to process special data, unless an exception is met. iGene complies with an exception to the prohibition because it requests explicit permission from its users to process genetic data. In addition to the fact that iGene complies with the exception, iGene always has a basis for processing this data. See below under 'Basic principles'.

    5. 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 for data to be entered again. In addition to cookies, iGene may use 'similar technologies' such as JavaScripts, tracking pixels and web beacons. These are techniques that allow a system to collect information, store it and then send it. In this statement, cookies and similar technologies are collectively referred to as 'cookies'.

    6. 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

      • Wholesale buyers or resellers without their own logistics. A wholesale customer can use iGene's logistics to serve its own customers with kits. The app used by a wholesale customer or reseller can have its own listing in the app stores and its own house style, but technically the app is the same as that of iGene.

      • Wholesale customers with their own logistics. Some bulk buyers of kits do not use iGene's logistics. They use their own platform and infrastructure to share DNA reports with their customers.

    7. Facts

      A 'personal data' is all information that can be traced directly or indirectly to an individual without the name of that individual having to be known. Examples are name, address, place of residence, e-mail address, telephone number, genetic data, cookie IDs, data related to tracking, commercial, advertising cookies, and financial data. In this statement, personal data is also referred to as 'data.'

    8. Fundamentals

      In order to lawfully process user data, iGene needs a legal basis. This is the basis that the law provides for the processing of user data. The principles that are most important to us are discussed below:


      One of the bases for processing data is the prior consent of the user for one or more specific purposes. "Consent" is any free, specific, informed and unambiguous expression of will by which the user accepts data processing by statement or unambiguous active action. iGene relies on consent for the processing of genetic data.

      But consent is not the only basis for processing data. Other equally important grounds for processing certain user data without consent are the following:

      Necessity for the execution of the agreement

      The data processing is necessary in order to take measures at the request of the user before entering into an agreement or for the implementation of any agreement 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.

      Necessary 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 and Customs Administration and UWV.

      Necessary for the representation of legitimate interests

      The data processing is necessary for the protection of the legitimate interests of iGene or a third party, unless the interests, fundamental rights and fundamental freedoms that require data protection of the user outweigh our interests. In short, in this statement we refer to 'legitimate interest'. In order to rely on this basis, we will first determine whether there are legitimate interests. Think of processing operations that fall under our normal business operations or the daily management of iGene. We then ask ourselves whether we can achieve the same result with less data or via a less drastic way. iGene will also perform a balance test. This means that we balance the user's interests and rights against our own.

    9. Receiver

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

    10. Products and services

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

    11. of Pseudonymise

      Processing data in such a way that the data can no longer be linked to a specific data subject without the use of additional data. The condition is that the additional data is kept separately and that technical and organizational measures are taken to ensure that the data is not linked to an identified or identifiable person. Encryption is a form of pseudonymization.

    12. Responsible

      Organization that determines the purpose and means for the processing of data. For example, iGene is responsible for processing data for conducting DNA tests, analyzing DNA and providing DNA reports to users.

    13. Process

      (A set of) operations relating to (a set of) data, whether or not automated. Examples are collecting, recording, organizing, storing, changing, retrieving, viewing, sharing, passing on, consulting, using, providing and deleting data.

    14. processor

      Organization that processes data on behalf of the controller.

    15. remove

      Erase data so that it cannot be retrieved either directly or indirectly.

    16. Websites

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