The Royal Health Clinic

Introduction

Welcome to Everything Genetic Limited’s privacy notice.

Everything Genetic Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you provide personal data to us and tells you about your privacy rights and how the law protects you.

In addition to this notice, you can also download:

Employer’s Liability Insurance Certificate

ICO Registration Certificate

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Everything Genetic Limited collects and processes your personal data including any data you may provide: through our website (www.everythinggeneticltd.co.uk); through our online portal, when you enquire about a product or service; when you purchase a product or service or when you sign up to our newsletter or take part in a competition.

Generally, our website and online portal is not intended for children and we do not collect data relating to children. However, in connection with Covid-19 testing, where the individual to be tested is a child then we will collect such data relating to that child as is relevant to such testing.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the
other notices and is not intended to override them.

Controller

Everything Genetic Limited is the controller and responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection officer using the details set out below.

Contact details

  1. Our full details are:
    1. Full name of legal entity: Everything Genetic Ltd
    2. Name or title of data protection officer: Mr James Price
    3. Email address: james@everythinggeneticltd.co.uk
    4. Postal address: 20-22 Wenlock Road, London, N1 7GU

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 5th January 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, self-isolation address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have obtained from us.
  • Service Data includes details which relate to the services you have enquired about or may require from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website or online portal.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, our online portal and our products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Medical Data including your NHS number and Covid-19 test results.
  • Test to Release Data including date of arrival in the UK, coach number, flight number, vessel name, date on which last departed or transited through non-exempt country, non-exempt territory or non-exempt region and country, territory or region travelling from or via before entering the UK.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We collect Special Categories of Personal Data about you (this may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances:

  1. a) In limited circumstances, with your explicit written consent.
  2. b) Where it is needed in the public interest.
  3. c) Where it is necessary to protect your vital interests.
  4. d) Where it is necessary to comply with a legal obligation on us.
  5. e) Where it is necessary for preventative or occupational medicine.

Less commonly, we may process this type of information where it is needed in relation to legal claims.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we (may) have with you (or you have with a third party) and you fail to provide that data when requested, we may not be able to perform the contract we have (or the relevant third party has) or are trying to enter into with you (for
example, to provide you with goods or services). In this case, we may have to cancel a product or service you (might) have with us (or the relevant third party) but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website/online portal;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website or online portal, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    • Technical Data from analytics providers such as Google based outside the UK.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Inc. based outside the UK.
    • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the UK.
  • Where we need to perform the contract we are about to enter into or have entered into with you (or you have entered into with a third party).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences;
  • following the opt-out links on any marketing message sent to you; or
  • contacting us at any time.
  • External Third Parties including:
    • Service providers acting as processors and/or joint controllers based in France, Germany, Belgium and the USA who provide IT and system administration services and sub-contracting services.
    • Professional advisers acting as processors and/or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities acting as processors and/or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
    • Public Health England and similar authorities/organisations who have a legal right to such information.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK which give personal data the same protection it has in the UK.
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