UNSEEN BIO PRIVACY POLICY

Version 1.0

Effective Date: July 7, 2020

Preface

We recognize that the information you submit to us and the data we provide is sensitive information. Therefore, we are committed to protecting and respecting your privacy. With this in mind, we are providing this Privacy Policy to explain our policies regarding the collection, use and disclosure of information that we receive through our Services and directly from you.

This Unseen Bio Privacy Policy (“Privacy Policy”) applies to all products, programs, testing service, websites, pages, features, content, research, optional study participations, software (including mobile applications or services), collection, testing, and analysis of biological samples (collectively, the “Service”) provided by Unseen Biometrics ApS (“UnseenBio,” “we,” or “us”). Our Privacy Policy is designed to help you (“you”, “customer”, or “user”) better understand how we collect, use, store, process, and transfer your information when using our Services.

This Privacy Policy is incorporated by reference into the Unseen Bio terms of service (“Terms” or “Terms of Service”), which can be found on our website and mobile software applications. Please carefully review this Privacy Policy and Terms of Service. By using our Services, you agree, accept, and consent to all of the policies and procedures described in these documents. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy or the Terms of Service, you should immediately discontinue use of our Services.

Links to Other Sites

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Acceptance of Privacy Policy

By subscribing to or otherwise using the Service, or accessing any content or materials made available through the Service, you agree to be bound by our Terms of Service, that includes this Privacy Policy, and accept them. By accepting these documents, you consent to use of your information according to the terms specified in these documents, that include informed consent for use of your Samples, Sample Data, Test Data and other types of information for purposes specified in these documents that include testing, analysis, reporting, improving our data analysis methods, Research and development, Research Studies, as well as Study Participations as further described in this Privacy Policy.

Changes to This Privacy Policy

Unseen Bio reserves the right to change or modify this Privacy Policy at any time and in its sole discretion. Any changes or modifications will be effective immediately upon posting of the revised Privacy Policy (with the revision effective date posted on the top left side) on our Service. Your continued use of the Service following the posting of revised Privacy Policy will constitute your acceptance of those changes.

Information You Provide Us

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (‘Personal Data’). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Postal code, City

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Health and Lifestyle Information

This is information about your health, including your own and your close relatives’ medical history, treatments received or ongoing, known allergies, medications, known long term conditions and relevant lifestyle information such as smoking or alcohol consumption and the type and frequency of physical exercise.

Biological Samples

These are the self-collected stool samples which you provide to us using our Sample collection kits (“Kits”) and that enable us to perform the testing services and analyses. Our analyses include, but are not limited to, microbiome analysis and metabolic model reconstruction.

Information We Derive From What You Give Us

Genetic Data

This is uninterpreted microbial DNA data which we receive from our laboratories and which is stored and displayed to you in your personal account. This information is used for generating your personal report.

Results of Interpretation

These include health, nutrition, sports, and personal traits data which are derived from interpretation of your health and lifestyle information and raw data and which we display to you in your personal report.

Information We Collect About You

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access our Service by or through a mobile device (‘Usage Data’). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), your login information, language preference, browser type, browser version, browser plug-in types and versions, operating system and platform, time zone setting, clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, any phone number used to call our customer service number, the time and date of your visit, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data. Unseen Bio's purpose in collecting non-personally identifying information is to better understand how Unseen Bio's visitors use its website. From time to time, Unseen Bio may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.

Tracking Cookies Data

To enrich and perfect your online experience, Unseen Bio uses "Cookies", similar technologies and services provided by others to display personalized content, appropriate advertising and store your preferences on your computer.

A cookie is a string of information that a website stores on a visitor's computer, and that the visitor's browser provides to the website each time the visitor returns. Unseen Bio uses cookies to help Unseen Bio identify and track visitors, their usage of https://unseenbio.com, and their website access preferences. Unseen Bio visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using Unseen Bio's websites, with the drawback that certain features of Unseen Bio's websites may not function properly without the aid of cookies.

By continuing to navigate our website without changing your cookie settings, you hereby acknowledge and agree to Unseen Bio's use of cookies.

Information from Third Parties

We may be provided personal information from the companies which serve as our sales partners, distributors or are otherwise related to our sales channels. We take all the reasonable efforts to ensure that all these parties comply with all the national and the international legislation in terms of privacy. This information generally includes, but may be not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City

Use of Data

We use your information in accordance with this Privacy Policy for activities necessary for provisioning the Service that include testing and analysis of data, generate and deliver Test Results and recommendations, and improve our Services.

These activities may include but are not limited to:

  1. To open and maintain your Unseen Bio account;
  2. To enable purchase of our Service (e.g., process payments);
  3. To communicate with you (e.g., informing you of policy changes, security updates or issues, etc.);
  4. To implement your requests (e.g. requests to customer service);
  5. To facilitate use of our website and mobile applications (including authenticating your visits, providing personalized content, and tracking your use of our Services);
  6. To enforce our Terms and other agreements such as monitor, detect, investigate and prevent prohibited or illegal activities, spam and other security risks, performing quality control;
  7. To perform research & development activities;
  8. To conduct data analysis to improve existing Services or develop new Services; and
  9. To improve our data analytics and artificial intelligence engine that help us provide more precise and accurately personalized recommendations to you.
  10. To fix bugs or issues, to analyze use of our website, to improve or optimize the customer experience and Customer Service, or to assess the efficacy of our marketing campaigns.

Retention of Data

Unseen Bio will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Unseen Bio will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Location of Data Storage

The data that we collect from you will be stored at a destination within Denmark. It will also be processed by our staff. This includes staff engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Biological samples are stored at our partner laboratories, which are accredited to have DIN EN ISO 15189:2014, the College of American Pathologists (CAP) and CLIA certification, which include industry standards for the storage of samples taken from humans. We store the samples for three (3) months, although we retain the right to store the samples for an indefinite period.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside of Denmark and choose to provide information to us, please note that we transfer the data, including Personal Data, to Denmark and process it there. You have given informed consent to this Privacy Policy when you initially accessed our services, that informed consent is also consent for us to make these transfers.

Unseen Bio will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Disclosure for Law Enforcement

Under certain circumstances, Unseen Bio may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Unseen Biometrics ApS may disclose your Personal Data in the good faith belief that such action is necessary to:

  1. To comply with a legal obligation
  2. To protect and defend the rights or property of Unseen Bio
  3. To prevent or investigate possible wrongdoing in connection with the Service
  4. To protect the personal safety of users of the Service or the public
  5. To protect against legal liability

Service Providers

We may employ third party companies and individuals to facilitate our Service (‘Service Providers’), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose:

Security Of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Rights

Unseen Bio aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. This Section outlines our policies and commitment to General Data Protection Regulation (“GDPR”) applicable ONLY to information from and of the residents of the European Union (“EU”). Except where a term is specifically defined herein, the terms used in this Section will have the meaning provided under in the GDPR. You have the right at any time:

To access and rectify

To access and rectify any Personal Data held about you that is inaccurate Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact Unseen Bio by using support@unseenbio.com with the subject line: “GDPR: Right to Data Rectification” to exercise your rights to portability of your Personal Data pursuant to GDPR. We may not be able to fulfil part or all of your request if doing so could adversely affect the rights and freedoms of others.

To receive a copy

To receive a copy of the Personal Data we hold about you. You can request to obtain a copy of your Personal Data in a structured, commonly used, machine-readable format. You may also request the transfer of your Personal Data directly to another Data Controller, where it is technically feasible, unless choosing to exercise this right adversely affects the rights and freedoms of others. Please note that we may ask you to verify your identity before responding to such requests. There may be an additional fee associated with processing your request.

Please contact Unseen Bio by using support@unseenbio.com with the subject line: “GDPR: Right to Data Portability” to exercise your rights to portability of your Personal Data pursuant to GDPR. To have your account and Personal Data deleted i.e. the right to be forgotten. It is your right to delete your Account or your Personal Information following a request for Account Closure at any time.

To be forgotten

You can request erasure of Personal Data that:

  1. is no longer necessary in relation to the purpose for which it was collected or used;
  2. was collected with your consent but later you withdrew such consent; or
  3. was collected for a purpose with your consent, but there are no overriding legitimate grounds for our further processing.

Unseen Bio will take reasonable steps to fulfil your request. Our assistance with your request, however, is subject to the following limitations:

  1. When processing your Personal Data is necessary to comply with a legal obligation, establish, exercise, or defend legal claims;
  2. In relevant data protection laws that restrict this right for certain types of data;
  3. When there are limitations in the available technology; and
  4. When we are limited by the cost of implementing

Subject to the above terms and conditions, Unseen Bio will fulfill your request within the shortest time possible and within the maximum period of thirty (30) days from receipt of a request. However, there may be some latency in deleting your Personal Information from our backup systems after it has been deleted from our production, development, analytics, and research systems. Also, our partner laboratories may retain information they receive from us in order to comply with laws or regulations that may require them to do so.

Notwithstanding the above, Unseen Bio shall be permitted to retain, to the extent permitted by law, any and all Personal Data that is in de-identified, anonymized, pseudonymized, and aggregated forms in accordance with the terms of this Privacy Policy.

Please contact Unseen Bio using support@unseenbio.com to exercise your right to erase your Personal Data pursuant to GDPR using the subject line: GDPR: Right to Erasure

To restrict processing

Under GDPR, you have the right to restrict our processing of your Personal Data under the following circumstances:

  1. you dispute the accuracy of Personal Data
  2. the processing is unlawful and you do not wish the erasure and request the restriction instead
  3. we no longer need the Personal Data for the purposes;
  4. when our legitimate grounds for processing override your rights

Following a request for restriction, however, we can continue to use your restricted Personal Data, when:

  1. we have your consent;
  2. to establish, exercise or defend legal claims;
  3. to protect the rights of another natural or legal person
  4. for reasons of important public interest.

Please contact Unseen Bio by using support@unseenbio.com using the subject line: “GDPR: Right to Restrict Processing” to exercise your rights to restrict processing your Personal Data pursuant to GDPR.

To withdraw consent

To the extent Unseen Bio has requested and you provided your consent for processing of your Personal Data, or accepted a Consent Form, you can withdraw your consent at any time by contacting our Customer Service using the information specified below. Your withdrawal will not affect the lawfulness of our processing based on consent you granted before its withdrawal as well as use of your data in ways otherwise permitted by law.

Upon withdrawal of consent we will remove and destroy your sample. Unseen Bio will fulfill your request within the shortest time possible and within the maximum period of thirty (30) days from receipt of a request. Please contact Unseen Bio by using support@unseenbio.com with the subject line: “GDPR: Withdraw Consent” to exercise your rights to withdraw consent pursuant to GDPR.

If you request the removal or deletion of your sample or any data before the testing services have been completed, this may affect our ability to provide your results to you. Any Services that used your individual-level Personally Identifiable data that have already been performed prior to your withdrawal for which you have given consent to cannot and will not be reversed, undone, or withdrawn.

To the extent permitted by applicable law, we may still use the de-identified, anonymized, or pseudonymized information that do not personally identify you for Research, Research Studies, data analysis, marketing, and other purposes in accordance with the terms of this Privacy Policy.

How to exercise your rights on Personal Data

If you would like to exercise your rights under GDPR on use of your Personal Data as described above, please send us a request using the designated methods specified above. In your message, please indicate the right you would like to exercise, request you make, and the information that you would like to access, review, correct, or erase.

We may ask you for additional information to confirm your identity and resident status and other information, for security purposes, before disclosing the Personal Data you requested. We reserve the right to charge a fee, where permitted by law (e.g., if our cost of processing your request is prohibitive, or your request is manifestly unfounded or excessive). We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

We ask that you attempt to resolve any issues regarding your Data Protection or data requests first with us.

Please contact us at support@unseenbio.com and we will be happy to respond to your request promptly.

If you are not happy with how we have responded to your request or resolved your complaint, you may contact the Danish supervisory authority found at: http://www.datatilsynet.dk/

Our user data protection levels are at the highest setting by default. In the unlikely event of a breach, Unseen Bio will notify the Datatilsynet according to procedures provided in GDPR Articles 33 and 34.

Your Use of Information

You should be very careful about sharing or discussing your results on social media or with friends, family, employers or third parties such as insurers. The information could be used to your disadvantage and/or passed on to other parties to whom you did not intend to disclose your results.

Retention of Personal Information

By choosing to have Unseen Bio extract the molecular level data from your Samples as part of the Service, you consent to have Unseen Bio access, analyze, and store your Personal Information using the same or more advanced technologies, in a manner consistent with our Terms and this Privacy Policy. Unless we notify you otherwise, we will store your Samples and data from the Samples for at least three (3) months, but may, in our sole discretion, to the extent permitted by law, retain such Samples and data for a longer period of time. All of the same safeguards applicable to Personal Information will be provided, to any further use of your Samples, as in our Terms of Service and this Privacy Policy.

Unless you close your Account that results in deletion of your Personal Information in the Account as described in the Account Closure process as specified below, Unseen Bio will store your Personal Information as long as your Account is open.

Children’s Privacy

Our Service is not available to anyone under the age of 18 (‘Children’).

Our Service is not designed for, intended to attract, or directed toward children under the age of 18 or below the legal age of majority to form a binding contract in your country of residence, whichever is greater.

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us.

In the event Unseen Bio is notified or becomes aware that the Service has been used by a child under the age of 18 to store information of that child without parental consent, Unseen Bio shall be and is authorized to delete, in its entirety, with no notice to you, any of the information stored by that child or by you on that child’s behalf. Unseen Bio also reserves the right to revoke any license to use the Service, which is being used or has been used by a child under the age of 18.

Contact Us

If you have any questions about this Privacy Policy, please contact us: