Privacy Policy
Eligens SIA
1. GENERAL CONDITIONS
1.1. The purpose of this Privacy Policy (hereinafter - Privacy Policy) is to provide to customers of Eligens SIA, unified registration number: 50203470741, registered address Stabu iela, 10, Riga, LV-1010, Latvia, (hereinafter - "We", "Our", "Us") and persons visiting Our website https://eligens.io/ (hereinafter referred to as the "Website") (hereinafter - Data Subject, "You", "Your", "Yours") information on what personal data We collect about You and for what purpose, on the terms of data processing, on data protection, as well as to inform You about Your rights and obligations.
1.2. When processing personal data We comply with the laws and regulations in force in the Republic of Latvia, Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter - the Regulation), as well as other laws and regulations in the area of privacy and personal data processing.
1.3. This Privacy Policy applies to any natural person whose personal data is processed by Us and applies to the processing of personal data regardless of the form in which You or any other natural person has provided personal data to Us: on the Website, in paper format or by telephone.
1.4. Our Cookie Policy is available on Our Website under Cookie policy.
2. DATA CONTROLLER AND ITS IDENTIFYING INFORMATION
2.1. As We process Your personal data and determine the purposes and means of the processing, We shall be deemed to be the controller of Your personal data.
2.2. Identity and contact details of the Data Controller: Eligens SIA, unified registration number: 50203470741, registered address Stabu iela, 10, Riga, LV-1010, Latvia, electronic mail address: privacy@eligens.io; Website address: https://eligens.io/.
2.3. To contact Our Data Protection Officer, please write to: privacy@eligens.io. Please note that Our Data Protection Officer does not provide general advice to other persons on the compliance of the processing of personal data with the Regulation and the Law on the Processing of Personal Data, but performs the tasks referred to in Article 39 of the Regulation and provides general information on the processing of personal data carried out by Us.
2.4. You can use this contact information to get answers to questions about Our Privacy Policy and/or the processing of Your personal data.
3. TYPES OF PERSONAL DATA AND THE PURPOSE AND LEGAL BASIS FOR PROCESSING THEREOF
3.1. Personal Data means any information relating to an identified or identifiable natural person, i.e. the Data Subject. Processing means any operation relating to personal data, such as obtaining, recording, transforming, using, consulting, erasing or destroying.
3.2. We comply with the principles of data processing provided for by law and confirm that personal data are processed in accordance with applicable laws and regulations.
3.3. We may obtain Your personal data:
- From You – if You use Our Website, register on Our Website, order any of Our services, contact Us (email, phone) or otherwise provide Us with Your personal data;
- From Our cooperation partners – certified laboratories – if You order one of Our services where a certified laboratory performs a DNA test on You, we receive Your relevant personal data (DNA test results) from the certified laboratory;
- From other persons (e.g. accountant, law firm, state and local authorities, credit institutions) – where the processing of Your personal data is in accordance with one of the purposes set out in Clause 3.4 of the Privacy Policy and has a legal basis.
3.4. We process the following personal data for the following purposes and on the following legal basis:
| Type of personal data | Purpose of the processing of personal data | Legal basis for processing personal data |
|---|---|---|
| Your name, date of birth, delivery address, email address, telephone number | This is necessary to fulfil Our contractual obligations to You to provide the service You have ordered, including:
DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our website. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. |
This is necessary for marketing purposes, including:
DATA STORAGE: Your personal data will be kept for this purpose for a maximum of 2 years from the date of receipt of Your consent or until You withdraw Your consent. | Your personal data is processed only with Your consent to the processing of personal data for marketing purposes – Article 6(1)(a) of the Regulation. You may opt-out of commercial communications that We send to You at any time by using the unsubscribe link in the communication sent to You by email, or by withdrawing consent in Your Personal Cabinet on Our website. | |
| This is necessary for Our accounting purposes. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 10 years from the date of Your last Order. | Your personal data is processed for the performance of a legal obligation to which We are subject - Article 6(1)(c) of the Regulation. | |
| This is necessary to carry out a survey to assess the quality of the service. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 1 year from the date of Your last Order. | Your personal data is processed for the purposes of Our legitimate interests - to evaluate and improve the quality of Our services - Article 6(1)(f) of the Regulation. | |
| This is necessary to prevent and detect fraud, to protect You and Us. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website. | Your personal data is processed for Our legitimate interests, to ensure Your security and Our security - Article 6(1)(f) of the Regulation. | |
| Your financial information (bank name, bank account, payment card details (card number, expiry date, CVC code)) | This is necessary to fulfil Our contractual obligations to You, for the administration of mutual payments for the service(s) You have ordered, and/or if You exercise Your right of withdrawal from the service(s) so that We can refund the price paid for the service to You. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 1 year from the date of Your last Order. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. |
| This is necessary to prevent and detect fraud, to protect You and Us. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 1 year from the date of Your last Order. | Your personal data is processed for Our legitimate interests, to ensure Your security and Our security - Article 6(1)(f) of the Regulation. | |
| Your date of birth, place of birth, Your name, Your surname, Your names, surnames if they have been changed | This is necessary to fulfil Our contractual obligations to You by providing the service You have requested in relation to determining Your ethnic origin, establishing a family tree, tracing the migration of ancestors, determination of kinship. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. Your personal data is processed only with Your explicit consent to the processing of the personal data in question for the purpose of receiving a service related to determining Your ethnic origin, establishing a family tree, tracing the migration of ancestors, determination of kinship - Article 9(2)(a) of the Regulation. You may withdraw Your consent to the processing of Your data at any time by withdrawing consent in Your Personal Cabinet on Our website. Please note that if You do not provide or withdraw Your consent to the processing of Your personal data for the above processing purpose, We will not be able to provide You with the service for which Your personal data is processed. |
| Name, surname, date of birth, place of birth, date and place of marriage, date and place of birth of children, employment (time period, place), information about military service, information about received awards, other types of biographical information of Your relatives (father, mother, grandfather, grandmother, great-grandfather, great-grandmother) | This is necessary to fulfil Our contractual obligations to You by providing the service You have requested in relation to determining Your ethnic origin, establishing a family tree, tracing the migration of ancestors, determination of kinship. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website. | The processing of Your personal data is necessary for the performance of the Contract– Article 6(1)(b) of the Regulation. Your personal data is processed only with Your explicit consent to the processing of the personal data in question for the purpose of receiving a service related to determining Your ethnic origin, establishing a family tree, tracing the migration of ancestors, determination of kinship - Article 9(2)(a) of the Regulation. You may withdraw Your consent to the processing of Your data at any time by withdrawing consent in Your Personal Cabinet on Our website. Please note that if You do not provide or withdraw Your consent to the processing of Your personal data for the above processing purpose, we will not be able to provide You with the service for which Your personal data is processed. |
| Your ethnic data | This is necessary to fulfil Our contractual obligations to You by providing the service You have requested in relation to determining Your ethnic origin, establishing a family tree, tracing the migration of ancestors, determination of kinship. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website or until You withdraw Your consent. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. Your personal data is processed only with Your explicit consent to the processing of the personal data in question for the purpose of receiving a service related to determining Your ethnic origin, establishing a family tree, tracing the migration of ancestors, determination of kinship - Article 9(2)(a) of the Regulation. You may withdraw Your consent to the processing of Your data at any time by withdrawing consent in Your Personal Cabinet on Our website. Please note that if You do not provide or withdraw Your consent to the processing of Your personal data for the above processing purpose, we will not be able to provide You with the service for which Your personal data is processed. |
| Your genetic data | This is necessary to fulfil Our contractual obligations to You in providing the service You have requested, related to the analysis of genetic data (analysis of DNA test results). DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website or until You withdraw Your consent. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. Your personal data is processed only with Your explicit consent to the processing of the personal data in question for the purpose of receiving Our service(s) related to the analysis of genetic data (analysis of DNA test results) - Article 9(2)(a) of the Regulation. You may withdraw Your consent to the processing of Your data at any time by withdrawing consent in Your Personal Cabinet on Our website. Please note that if You do not provide or withdraw Your consent to the processing of Your personal data for the above processing purpose, we will not be able to provide You with the service for which Your personal data is processed. |
| Your health data (Your current and/or historical medical conditions, Your lifestyle, the results of Your previous medical tests, the reports of Your previous medical examinations, the reports of Your doctors, specialists) | This is necessary to fulfil Our contractual obligations to You by providing the service You have requested, in relation to taking a DNA test and/or analysing the results of a DNA test. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website or until You withdraw Your consent. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. Your personal data is processed only with Your explicit consent to the processing of specific personal data for the purpose of receiving our service related to taking a DNA test and/or analysing the results of a DNA test - Article 9(2)(a) of the Regulation. You may withdraw Your consent to the processing of Your data at any time by withdrawing consent in Your Personal Cabinet on Our website. Please note that if You do not provide or withdraw Your consent to the processing of Your personal data for the above processing purpose, we will not be able to provide You with the service for which Your personal data is processed. |
| Your gender | This is necessary to fulfill Our contractual obligations to You by providing the service You have requested. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. |
| History of Your orders and activities on our Website (orders You have placed, services You have viewed) | This is necessary to fulfil Our contractual obligations to You by providing the service You have requested. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 2 years from the last time You logged in to Your Private office on Our Website. | The processing of Your personal data is necessary for the performance of the Contract – Article 6(1)(b) of the Regulation. |
| This is necessary to carry out surveys to assess the quality of our services, to improve the performance of Our website. DATA STORAGE: Your personal data will be stored for this purpose for a maximum period of 1 year from the date of Your last Order. | Your personal data is processed for the purposes of our legitimate interests - to evaluate and improve the quality of Our services - Article 6(1)(f) of the Regulation. |
4. RECIPIENTS OF PERSONAL DATA
4.1. In order for Us to provide You with the best possible service, in certain circumstances set out below, We may need to transfer Your personal data to the following parties:
4.1.1. If the performance of Our Service requires taking a DNA test we may transfer Your personal data to our business partners - appropriately certified laboratories - to take Your DNA test;
4.1.2. In order for Us to provide You with the services We offer, in relation to taking a DNA test, You need to take a DNA test, and in order to take Your DNA test, We need to collect Your biomaterial (saliva), so We may transfer Your personal data to a courier service in order to supply You with a Biomaterial collection kit and arrange for Your collected Biomaterial to be delivered to Our business partner, a certified laboratory, for performance of Your DNA test;
4.1.3. In order to fulfil Our legal obligation, We may transfer Your personal data to Our business partners, such as law firms, accountants, who are involved in the organization and provision of Our activities;
4.1.4. For the accurate interpretation of your DNA tests, we may transfer your personal data to our cooperation partners who provide appropriate IT technologies for the interpretation of DNA tests;
4.1.5. For the safe storage of your personal data, We may transfer your personal data to our cooperation partners who provide and maintain data storage servers.
4.1.6. In the manner and in the cases provided for by external laws and regulations, We may transfer Your personal data to state and local government institutions.
4.2. Subject to clause 4.1, We will only transfer Your personal data to persons who can ensure the security and processing of Your personal data in accordance with the requirements of the Regulation.
5. INFORMATION ON WHETHER WE INTEND TO TRANSFER PERSONAL DATA TO THIRD COUNTRIES
5.1. We mostly process and store Your personal data in the member states of the European Union and the European Economic Area. However, in certain cases, in order to fulfill a contract concluded with You and provide You with a service, We may send Your personal data to third countries.
5.2. When sending Your personal data to any of the third countries, We take special care regarding the protection of Your personal data.
5.3. Before sending Your personal data to a third country, We make sure that:
- According to the decision of the European Commission on the adequacy of the level of protection, the data recipient is able to ensure a level of protection of personal data that corresponds to the level of data protection in the EU, or
- appropriate guarantees have been implemented and exist for data protection, or
- sending data is necessary when there is a special situation defined in the regulatory acts.
6. STORAGE OF PERSONAL DATA
6.1. We keep Your personal data for no longer than is necessary for the purposes for which We process the personal data (please see Chapter 3 "Types of Personal Data and the Purpose and Legal Basis for Processing Thereof" of this Privacy Policy) or as long as at least one of the following criteria applies:
6.1.1. Your Personal Data is necessary for the purposes for which it was received;
6.1.2. For as long as the contract with You is in force or the service is being provided;
6.1.3. While We and/or You may, in accordance with the procedures set out in external laws and regulations, pursue our legitimate interests, for example, by lodging objections or bringing or pursuing legal action;
6.1.4. As long as there is a legal obligation to retain the data, for example under the Accountancy Law;
6.1.5. As long as Your consent to the processing of Personal Data is valid.
6.2. Upon termination of the circumstances referred to in Clause 6.1, the retention period of Your Personal Data shall also terminate and all relevant Personal Data shall be permanently deleted from the computer systems and electronic and/or paper documents that contained the relevant Personal Data or they are pseudonymized (anonymized).
7. YOUR RIGHTS AS THE DATA SUBJECT
7.1. As a Data Subject, You have the following rights in relation to the processing of Your personal data:
7.1.1. You have the right to be informed before personal data are collected. All information about the processing of Your personal data is reflected in this Privacy Policy and Our Cookie policy, which You can consult at any time on Our Website, or if You have any questions, You can contact us at our email address: privacy@eligens.io.
7.1.2. You have the right to request access to Your personal data. You have the right to obtain confirmation from Us as to whether or not personal data is being processed in relation to You and, if so, the right to access that data by requesting a copy of Your personal data from Us. We may refuse to provide You with a copy of Your personal data on a case-by-case basis where this may adversely affect the rights and freedoms of others.
7.1.3. You have the right to correction of information. You have the right to ask Us to correct and update personal data about You that is inaccurate and that We hold.
7.1.4. You have the right to request the erasure of Your personal data. You can exercise this right in the following cases:
- Your personal data is no longer necessary for the purposes for which it was collected or otherwise processed (e.g. You are no longer Our client);
- If the lawful basis for processing Your personal data is Your consent (please see Chapter 3 “Types of Personal Data and the Purpose and Legal Basis for Processing Thereof” of this Privacy Policy) and there is no other lawful basis for processing it;
- Where the lawful basis for processing is the public interest or Our legitimate interests (please see Chapter 3 “Types of Personal Data and the Purpose and Legal Basis for Processing Thereof” of this Privacy Policy), except in exceptional cases provided for by laws and regulations;
- If Your personal data is processed for direct marketing purposes;
- If Your personal data is being processed unlawfully;
- If, in accordance with the requirements of the laws and regulations applicable to Us, We are required to delete Your personal data.
7.1.5. Your right to have Your personal data erased may be limited in the following cases:
- If the processing of Your personal data is necessary for the exercise of the right to freedom of expression and information;
- If the processing of Your personal data is necessary for compliance with a legal obligation imposed on Us by law or regulation, or for the performance of a task carried out in the public interest or in connection with the exercise of official authority lawfully conferred on Us;
- Where processing of Your personal data is necessary for reasons of public interest in the field of public health, as required by the Regulation;
- If the processing of Your personal data is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, as required by the Regulation;
- Where processing of Your personal data is necessary for the establishment, exercise or defence of legitimate claims.
7.1.6. You have the right to request that the processing of Your personal data (other than storage) be restricted. You can exercise this right in the following cases:
- If You contest the accuracy of Your personal data, You may request that We restrict the processing of Your personal data until We have verified the accuracy of Your personal data;
- If the processing of Your personal data is unlawful and You object to the erasure of Your personal data and instead request the restriction of the use of the data;
- If We no longer need Your personal data for processing, but need it for the establishment, exercise or defence of legitimate claims;
- If You object to the processing of Your data for which We have a legitimate interest, We will restrict the processing until We have verified the validity of Your request.
7.1.7. If, at Your request, We restrict the processing of Your personal data, We may process such personal data, except for storage, only with Your consent or for the establishment, exercise or defence of legitimate claims or for the protection of the rights of another natural or legal person, or for important reasons of public interest.
7.1.8. You have the right to object to the processing of Your personal data in the following cases:
- You rely on grounds relating to Your particular situation and where the lawful basis for processing is the public interest or Our legitimate interests (please see Chapter 3 “Types of Personal Data and the Purpose and Legal Basis for Processing Thereof” of this Privacy Policy), unless We have compelling reasons for processing which override Your interests, rights and freedoms or for the establishment, exercise or defence of legitimate claims;
- Your personal data is processed for direct marketing purposes;
- You rely on grounds relating to Your particular situation and where Your personal data are processed for scientific or historical research purposes or for statistical purposes, except where the processing is necessary for the performance of a task carried out in the public interest.
7.1.9. You have the right to portability of Your personal data if all of the following conditions are met:
- You have provided Us with Your personal data in a structured, commonly used and machine-readable format, and
- There is rights to transfer Your particular data to another controller, and
- the controller to whom the personal data have been provided does not impede it in any way, and
- where the lawful basis for processing Your personal data is Your consent or the performance of a Contract (please see Chapter 3 “Types of Personal Data and the Purpose and Legal Basis for Processing Thereof” of this Privacy Policy), and
- processing is carried out by automated means.
7.1.10. You have the right to withdraw Your consent to the processing of Your personal data at any time, where the lawful basis for the processing is Your consent (please see Chapter 3 “Types of Personal Data and the Purpose and Legal Basis for Processing Thereof” of this Privacy Policy), without affecting the lawfulness of processing based on consent given before revocation.
7.1.11. You have the right to lodge a complaint with the supervisory authority. If You believe that We are violating Your rights as a data subject, You have the right to lodge a complaint with the Data Inspectorate (address: Elijas street 17, Riga, LV-1050, e-mail: pasts@dvi.gov.lv). However, in case of any uncertainty, We encourage You to contact Us first.
8. AUTOMATED DECISION-MAKING, INCLUDING PROFILING
8.1. We do not use automated decision-making, including profiling.
9. FINAL PROVISIONS
9.1. We may make changes or additions to this Privacy Policy at any time and without notice. Amendments shall take effect upon posting on Our website.
If You have any questions about this Privacy Policy and the processing of Your data, please contact Us:
- By sending Your question to us by e-mail: privacy@eligens.io.
- By sending Your question to us by post to our registered office at Stabu iela, 10, Riga, LV-1010, Latvia.