Privacy policy

This privacy policy sets out how Gene Check uses and protects any information that you give us when you use this website (the “Website”)) or otherwise interact with us.

When, in this policy, we refer to GeneCheck we mean GeneCheck, a trading style of Panglossian Limited whose registered address is at Pure Pharmacy Head office, Bakers Yard, Portland St North, Dublin 1(“GeneCheck”) and subsidiary company of Pure Pharmacy a trading style of DBDC Nine Limited of PSI House, Fenian Street, Dublin 2 (“Pure Pharmacy”). GeneCheck is the data controller in respect of your personal information and is responsible for ensuring that the personal data we collect is processed in accordance with relevant data protection laws.

If you have any questions or are unsure about anything contained in this privacy policy, please let us know by contacting our Data Protection Officer at info@genecheck.ie.

This privacy policy applies to any and all personal information gathered by GeneCheck from any prospective and actual customers through our Website or other channels (such as; Email, Telephone, by post, Social Media, SMS, Newsletters/Blogs, Competitions or Web Chat.

We may change this policy from time to time by updating this page. You should check this Website from time to time to ensure that you are familiar with the current privacy policy. If we propose a material change to how we process your personal information, we will notify you by email and will otherwise post an alert that our policy has changed on our Website.

WHAT INFORMATION WE COLLECT ABOUT YOU

Depending on how and why you interact with us, we may process some or all of the following information: –

• Full name
• Contact information such as e-mail address, telephone number, address and Eircode
• Doctors full name
• Signature
• Sample information if you wish to use our GeneCheck service
• Contact preferences such as preferred contact method and whether or not you would like to receive news and updates from us
• Information you share with our teams
• Your bank and credit/debit card details
• Data collected by the QR code
• Information about how you navigate and use our Website such as the search terms you use, the pages you visit, the amount of time you spend on the Website.

We may also collect what is known as special category information, this is information that is particularly sensitive and requires additional protection under Data Protection Laws. These may include the following;

• Genetic data (for example Saliva samples)
• Health data

WHAT WE DO WITH THE INFORMATION WE GATHER

We will use the personal information we hold about you for the following purposes: –

• To provide the services you have requested and to manage our relationship with you.
• To respond to your enquiries
• To enable you to access and use our Website
• For internal record keeping purposes and to help us improve our products and services
• To set up a Patient Medication Record to record testing and results.
• To undertake testing and analysis and to provide results to your medical team (if you ask us to)
• To process payments
• To satisfy our regulatory requirements
• If you consent, to send you news and updates that we think might be interesting to you

WHAT LEGAL BASIS DO WE RELY ON TO PROCESS YOUR INFORMATION?

Data protection law sets out a number of conditions which organisations can rely on in order to lawfully handle personal information. The conditions we rely on are as follows: –

Legitimate interestsThe law permits us to handle your personal information where necessary in our legitimate interests provided that this isn’t outweighed by your interests. Many of the purposes we handle your personal information, described above, fall into this category as they are activities which enable us to run our business efficiently and effectively for example, enabling us to use third party service providers. We may, if necessary, also use your information to defend our legal rights or to obtain legal advice and to manage any complaint that you might have. We ensure that your rights and interests are protected when we do this.

Consent

We are permitted to use your personal data when you give us your consent for us to do so. For example, we rely on consent for sending you marketing communications.

Performance of a contract

Where you transact with us to buy a service, we will use your personal information so that we can fulfil our part of the contract.

Required by law

We will, if required by law, disclose your personal information for example in response to a court order. We will disclose your personal information if requested by a law enforcement agency or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, non-compliance with of our terms and conditions, or as otherwise permitted or required by law and consistent with legal requirements.

WHO WE SHARE YOUR INFORMATION WITH

Other companies in our group of companies

We will share your personal data with companies in our group of companies, including Pure Pharmacy, for the purposes of internal reporting and to enable us to run our business effectively and efficiently

Service providers

We will not pass your personal information to anyone outside our group of companies, except to carefully selected third parties who help us to run our business and provide the service you have requested. For example, we will share your sample data (once we have removed personal identifiers), with our chosen laboratory in Germany. Your personal information will also be processed by organisations who provide the IT systems we use to run our business. We will also share your personal data with your doctor or medical team if you request.

A prospective purchaser of our business

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets or where we are required to forward the information in order to comply with a regulatory or legal process.

We will also always ensure that before we share your personal information with a service provider, we have entered into a contract with the service provider which requires them to keep your information secure and only use it for the purposes we permit them to. We will never sell or share your personal information with third parties for the purposes of marketing without seeking prior consent.

HOW LONG WE WILL KEEP YOUR PERSONAL INFORMATION FOR

We will keep your personal information for as long as we need it to provide the services and products you request from us. We may also keep it to comply with our legal obligations, to resolve complaints and to enforce our rights.  As a result, the length of time that we keep your information for will vary depending on the purposes for which we have it. In any event, we will review what information we need on an ongoing basis and will only retain it for the minimum amount of time that we need it for.

WHERE IN THE WORLD WILL WE HOLD YOUR INFORMATION?

Your personal information may occasionally be processed and held by third parties outside the European Economic Area (EEA).

If we do send personal information overseas, we will make sure that appropriate safeguards are in place to ensure it is protected in accordance with European data protection law. These might include: –

• Sending personal information only to countries that European Authorities have indicated have adequate data protection laws in place e.g. Canada or Switzerland;
• Putting in place contracts with the recipient containing terms which the European Authorities have approved as providing adequate protection; organisations which are members of a scheme which has been approved by European Authorities as achieving adequate protection.

Cookies on our Website

Cookies are small text files stored on your computer (or mobile device) by web pages as you visit them. Cookies are not programs and cannot harm your computer. For further information about cookies, visit allaboutcookies.org

For more information about how we use cookies, please refer to our separate Cookie policy by clicking COOKIE POLICY.

Links to other websites

Our Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst viewing such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

YOUR RIGHTS

You have the right, at any time, to request that we don’t send marketing material to you. You can do this by:

• Clicking on the unsubscribe link at the bottom of promotional e-mails
• E-mailing us at any time at info@genecheck.ie

We will try to keep your personal information up to date but rely on you telling us promptly if your name, address, telephone number or any other details change. You can correct or amend your personal information by e-mailing us at info@genecheck.ie.

Data protection laws also mean that you have a number of additional rights including the right to access your personal information and to receive a copy of it. You can exercise this right by e-mailing us at info@genecheck.ie.

You can also object to your personal information being processed, ask for it to be corrected, restricted or deleted or to have it transferred either to you or a third party in a commonly structured format. Please be aware that some rights are not absolute. We will review and consider all requests individually however, it may be that, in some instances, we may not always be required to comply.

For further information about how these rights apply, or to exercise your rights, please e-mail us at info@genecheck.ie.

Complaints

If you have any questions about how Gene Check handles your personal information or are unhappy about how we have done so, you can e-mail us at info@genecheck.ie.

You also have the right to raise any complaint you may have with the Data Protection Commission (“DPC”) You can do this by contacting them: –

• By post: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
• By phone: (01) 765 01 00 / 1800 437 737
• By webform: forms.dataprotection.ie/contact