Introduction
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We are committed to safeguarding the privacy of 54gene website
visitors and service users including visitors to our Diagnoseme
web platform.
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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.
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We use cookies on our website. Insofar as those cookies are not
strictly necessary for the provision of our website and
services, we will ask you to consent to our use of cookies when
you first visit our website.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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Please do not supply any other person's personal data to us,
unless we prompt you to do so. You may choose to supply personal
data of others for which you confirm that you have their
explicit consent to so do and our terms of use and privacy
notice shall apply to how we use that data. You shall be
responsible for any liability arising from the status of such
person’s consent to have their data processed.
Providing your personal data to others
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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.]
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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.
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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.
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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.
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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
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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
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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.
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We will retain your personal data as follows:
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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.
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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.
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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.
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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.
Amendments
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We may update this notice from time to time by publishing a new
version on our website.
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You should check this page occasionally to ensure you are happy
with any changes to this notice.
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We will notify you of changes to this notice by email or through
the private messaging system on our website.
Your rights
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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To the extent that the legal basis for our processing of your
personal data is:
- consent; or
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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.
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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.
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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.
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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.
About cookies
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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.
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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.
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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
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We use cookies for the following purposes:
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authentication - we use cookies to identify you when you
visit our website and as you navigate our website;
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status - to help us determine if you are logged into our
website;
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personalisation - we use cookies to store information about
your preferences and to personalise the website for you;
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security - we use cookies as an element of the security
measures used to protect user accounts, including preventing
fraudulent use of login credentials, and to protect our
website and services generally;
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advertising - we use cookies to help us to display
advertisements that will be relevant to you;
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personalisation - we use cookies to store information about
your preferences and to personalise the website for you;
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analysis - we use cookies to help us to analyse the use and
performance of our website and services; and
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cookie consent - we use cookies to store your preferences in
relation to the use of cookies more generally.
Cookies used by our service providers
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We use Google Analytics to analyse the use of our website.
Google Analytics gathers information about website use by means
of cookies. The information gathered relating to our website is
used to create reports about the use of our website. Google's
privacy policy is available at:
https://policies.google.com/privacy
Managing cookies
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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:
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Blocking all cookies will have a negative impact upon the
usability of many websites.
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If you block cookies, you will not be able to use all the
features on our website.
Our Details
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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.
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You can contact us:
- by using our website contact form;
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by telephone, on [the contact number published on our
website from time to time; or
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by email, using [the email address published on our website
from time to time.
Data protection officer
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Our data protection officer's contact details are: