Privacy Policy

GeneLinx

Introduction

In the following, we provide information about the collection of personal data when using

our website https://gene-linx.com/
our profiles in social media.

Personal data is any data that can be related to a specific natural person, such as their name or IP address.

1.1. Contact details

The controller within the meaning of Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is GeneLinx GmbH, Keibelstraße 4, 10178 Berlin, Germany, email: www.gene-linx.com. We are legally represented by Alekhya Narravula.
Our data protection officer can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, E-Mail: datenschutz@heydata.eu.

1.2. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

Art. 6 para. 1 s. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
Art. 6 para. 1 s. 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
Art. 6 para. 1 s. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain, Canada and Israel) (Art. 45 para. 3 GDPR).
If no adequacy decision exists (e.g. for the USA), the legal basis for the data transfer are usually, i.e. unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and are part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses to protect the data. These include, for example, guarantees regarding the encryption of data or regarding an obligation on the part of the third party to notify data subjects if law enforcement agencies wish to access the respective data.

1.4. Storage duration

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and no legal obligations to retain data conflict with the deletion. If the data are not deleted because they are required for other and legally permissible purposes, their processing is restricted, i.e. the data are blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

1.5. Rights of data subjects
Data subjects have the following rights against us with regard to their personal data:

Right of access,
Right to correction or deletion,
Right to limit processing,
Right to object to the processing,
Right to data transferability,
Right to revoke a given consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available at https://www.bfdi.bund.de/EN/Service/Anschriften/Laender/Laender-node.html.

1.6. Obligation to provide data

Within the scope of the business or other relationship, customers, prospective customers or third parties need to provide us with personal data that is necessary for the establishment, execution and termination of a business or other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude the contract or to provide a service or will no longer be able to perform an existing contract or other relationship.
Mandatory data are marked as such.

1.7. No automatic decision making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

1.8. Contacting us

When contacting us, e.g. by e-mail or telephone, the data provided to us (e.g. names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 s. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

1.9. Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit f GDPR. We delete the data when the results of the surveys have been evaluated.

2. Newsletter and Marketing

We reserve the right to inform customers who have already used services from us or purchased goods from time to time by e-mail or other means electronically about our offers including promotions, clinical trials, patient advocacy groups, research projects, etc., if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to the use of their e-mail address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each e-mail or by sending an e-mail to our above-mentioned e-mail address.

Interested parties have the option to subscribe to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Subscription takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our e-mail address given above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 s. 1 lit. a GDPR), we also measure the opening and click-through rate of our newsletters to understand what is relevant for our audience.

3. Data processing on our website

3.1. Notice for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). What information this is in detail can be found in the following sections.

This storage and access is based on the following provisions:

Insofar as this storage or access is absolutely necessary for us to provide the service of our website expressly requested by website visitors (e.g., to carry out a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 para. 2 no. 2 of the German Telecommunications Telemedia Data Protection (Telekommunikation-Telemedien-Datenschutz-Gesetz, “TTDSG”).
Otherwise, this storage or access takes place on the basis of the website visitor’s consent (Section 25 para. 1 TTDSG).

The subsequent data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

These data are:

IP address
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer necessary, at the latest after 14 days.

3.3. Web hosting and provision of the website

Our website is hosted by Ionos. The provider is 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur. In doing so, the provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider’s privacy policy at https://www.ionos.co.uk/terms-gtc/privacy-policy/#c4183.

It is our legitimate interest to provide a website, so the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

We use the content delivery network Cloudflare for our website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. The provider thereby processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data in the USA. Further information can be found in the provider’s privacy policy at https://www.cloudflare.com/privacypolicy/.

We have a legitimate interest in using sufficient storage and delivery capacity to ensure optimal data throughput even during large peak loads. Therefore, the legal basis of the described data processing is Art. 6 para. 1 s. 1 lit. f GDPR.

Legal basis of the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

3.4. Contact form

When contacting us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in answering inquiries directed to us. The legal basis for the processing is therefore Art. 6 para. 1 s. 1 lit. f GDPR.
We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

3.5. Waiting list

Site visitors can register on our waiting list on the website. For this purpose, we process metadata or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly way to learn about our launch and arrange appointments for teleconsultation. Therefore, the legal basis for data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Insofar as we use a third-party tool for the agreement, the information on this can be found under “Third parties”.

3.6. Offer of services

We offer services via our website. In doing so, we process the following data as part of the ordering process:

name,
email,
phone,
country,
type of service,
payment details.

The processing of the data is carried out for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 s. 1 lit. b GDPR).

3.7. Payment processors

For the processing of payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 s. 1 lit. b GDPR).

These payment processors are:

Zoho Corporation B.V., Netherlands
Stripe Payments Europe, Ltd., Ireland

4. Our Services

4.1. Teleconsultation

You can request a teleconsultation through our Website. For the purposes of the teleconsultation, we process the following personal data:

First and last name
Contact data (E-mail address, telephone number, country of residence)
Health data
Family history and
Genetic data

For this purpose you will receive from us a form, where you should fill in the above mentioned information.

Your personal data is shared with a specific genetic expert, at the choice of GeneLinx, from

this list of experts,

who will conduct the teleconsultation session.

With the genetic expert we have entered a Joint Controllership Agreement according Art. 26 GDPR.

GeneLinx shall make on demand the essential content of the data protection joint responsibility agreement available to the data subjects. Moreover GeneLinx provides the data subject free of charge with the information required under Articles 13 and 14 GDPR in a precise, transparent, comprehensible and easily accessible form in clear and simple language.Data subjects can exercise their rights both against GeneLinx and against genetic counselors.

The legal basis for the processing is consent (Art. 6 para. 1 s. 1 lit. a GDPR, Art. 9 para. 2 lit a GDPR). Data subjects may revoke their consent at any time by contacting us at privacy@gene-linx.com. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it.

4.2. Genetic testing

As a part of teleconsultation service, you may request a genetic test. If you choose to undergo genetic testing, we will process and share with the laboratory the following data with our partner laboratories for the purpose of conducting the test. The relevant personal data is:

First and last name
Date of birth
E-Mail address
Telephone number
Medical and family history

We use the the following laboratory services for this purpose:

Blueprint Genetics Oy Blueprint Genetics Inc., Keilaranta 16 A 2505 3rd Ave, 02150 Espoo Suite 204, Finland
CENTOGENE GmbH, Am Strande 7, 18055 Rostock, Germany

Depending on the patient’s individual needs, we might work with different partners in a concrete case. The patient will be informed accordingly in such cases.
The processing is based on consent (Art. 6 para. 1 s. 1 lit. a GDPR, Art. 9 para. 2 lit a GDPR). Data subjects may revoke their consent at any time by contacting us at privacy@gene-linx.com. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it.

4.3. Sharing information with your clinic or your physician

If requested by you, we transfer your data to the health service provider that is treating you, meaning the following data

First and last name
Contact data (E-mail address, telephone number)
Health data and
Genetic data

The legal basis is your explicit consent (Art. 6 para. 1 s. 1 lit. a GDPR, Art. 9 para. 2 lit a GDPR). Data subjects may revoke their consent at any time by contacting us at privacy@gene-linx.com. The revocation does not affect the lawfulness of the processing until the revocation.
The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it.

4.4. Scientific Research

For research purposes, we might ask for your explicit consent to use your personal data in the context of our studies. For this purpose we processing the following data:

First and last name
Health data and
Genetic data

4.5. Improvement of our product

In order to improve, we might ask for your explicit consent to use your personal data in the context of our studies. For this purpose we processing the following data:

First and last name
Health data and
Genetic data

5. Third parties

5.1. Elementor

We use Elementor to create websites. The provider is Elementor LTD., Tuval St 40, Ramat Gan, Israel. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider’s privacy policy at https://elementor.com/terms/.

5.2. CookieYes

We use CookieYes to manage consents. The provider is CookieYes Limited, 3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom. The provider processes meta/communication data (e.g. device information, IP addresses) in Great Britain.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. c DSGVO. The processing is necessary for the fulfillment of a legal obligation to which we are subject.

The legal basis for the transfer to a country outside the EEA are adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided as part of an adequacy decision in accordance with Art. 45 para. 3 GDPR that the third country ensures an adequate level of protection.

5.3. Google Analytics

We use Google Analytics for analytics. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses (Art. 46 para. 2 lit. c GDPR) adopted by the EU Commission in accordance with the examination procedure under Art. 93 para. 2 of the GDPR, which we have agreed to with the provider.

5.4. Zoho Meetings

We use Zoho Meetings for video calls. The provider is Zoho Corporation Pvt. Ltd, 4141 Hacienda Dr, Pleasanton, Ca 94588 USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), contact data (e.g. emails) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in making our communications particularly lively through the use of video conferencing.

5.5. Zoho Forms

We use Zoho Forms for questionnaires and forms. The provider is Zoho Corporation Pvt. Ltd, 4141 Hacienda Dr, Pleasanton, Ca 94588 USA. The provider processes content data (e.g. data in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in creating forms in a simple way.

5.6. Zoho Bookings

We use Zoho Bookings to schedule appointments. The provider is Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, Netherlands. The provider processes usage data (e.g. websites visited, interest in content, access times), contact data (e.g. email addresses, telephone numbers) and master data (e.g. names, addresses) in the EU.

The legal basis of the processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest to arrange appointments in a simple way.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider’s privacy policy at https://www.zoho.com/de/privacy.html.

5.7. Zoho Workdrive

We use Zoho WorkDrive as cloud storage. The provider is Corporation Pvt. Ltd, 4141 Hacienda Dr, Pleasanton, Ca 94588 USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest to collaborate, create and store documents in a cost-efficient and effective manner.

5.8. ZohoCRM

We use ZohoCRM for customer relationship management. The provider is Corporation Pvt. Ltd, 4141 Hacienda Dr, Pleasanton, Ca 94588 USA. The provider processes usage data (e.g. web pages visited, interest in content, access times), content data (e.g. entries in online forms), and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and inexpensive way.

6. Data processing on social media platforms

We are represented in social media networks in order to present our organization and our services there. The operators of these networks regularly process their users’ data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to show advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. To this end, the operators of the networks store information on user behavior in cookies on the users’ computers. Furthermore, it cannot be ruled out that the operators merge this information with other data. Users can obtain further information and instructions on how to object to processing by the site operators in the data protection declarations of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may result in risks for users, e.g. because it is more difficult to enforce their rights or because government agencies access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so that the legal basis is Art. 6 para. 1 s. 1 lit. f GDPR.

6.1. Facebook

We maintain a profile on Facebook. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://www.facebook.com/policy.php. A possibility to object to data processing arises via settings for advertisements: https://www.facebook.com/settings?tab=ads.
We are joint controllers for processing the data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR with Facebook. Facebook explains exactly what data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive a faster response if they contact Facebook directly.

6.2. Instagram

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

6.3. LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

7. Changes to this privacy policy

We reserve the right to change this privacy policy with effect for the future. A current version is always available here.

8. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.

GeneLinx

PRIVACY POLICY