Welcome to the Privacy Policy of SeekGene.
Beijing SeekGene BioSciences Co., Ltd. (also referred to as; SeekGene/ we / us / our) respects your privacy and we are committed to protecting your personal data.
This privacy policy will inform you as to how we look after and protect your personal information when you visit our website, and tell you about your privacy rights and legal protections.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED? 
4. HOW WE USE YOUR PERSONAL DATA 
5. DISCLOSURES OF YOUR PERSONAL DATA 
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION 
9. YOUR LEGAL RIGHTS 
10. GLOSSARY 

1.IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Policy
This privacy policy(“Privacy Policy”) is designed to make you aware of our privacy practices when you use our website or request to receive information from us.

The Website is not directed to inpiduals under the age of sixteen (16), and we do not knowingly collect personal information from inpiduals under 16.
If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website. Please take a moment to review our policies and practices described below.
 

Data controller
The Controllers of your personal data in the meaning of the General Data Protection Regulation ("GDPR") is Beijing SeekGene BioSciences Co., Ltd. with which you have a business relationship or whose products/services you are using.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
 

Contact details
If you wish to contact SeekGene regarding your personal information or this Privacy Policy, please contact the data privacy manager by one of the methods listed below:
 

Full name of legal entity: Beijing SeekGene BioSciences Co., Ltd. 
Email address: info@seekgene.com
Telephone number: +86 10 5691 8048
Mail address: Beijing SeekGene BioSciences Co., Ltd. 
Room 201, Floor 2, Tower A, Building 9, Zone1, 8 Life Science Park way, Life Science Park, Changping District, Beijing, China.
You have the right to make a complaint at any time to the relevant data protection supervisory authority (for example, in the UK, the supervisory authority for data protection is called the Information Commissioner's Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach your relevant supervisory authority so please contact us in the first instance.
 

Changes to the Privacy Policy and Your Duty to Inform Us of Changes
We keep our privacy policy under regular review. This version was last updated on 28 April 2023.
This privacy policy is effective as of the date stated at the start of this Privacy Statement. We reserve the right to modify this Privacy Policy at any time by posting the revised policy on our Website and updating the date the policy was last revised at the start of this Privacy Policy, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you by email or by means of a prominent notice on our home page.
 

Third-party links

This website may include links to third-party websites, plug-ins and applications. Links to third-party websites are provided solely as a convenience to you. If you use these links, you will leave the SeekGene Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. This Privacy Policy does NOT apply to the practices of third parties that we do not own or control. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, refers to any information that can identify an individual. Anonymous data, on the other hand, does not contain any identifying information. We may gather, utilize, keep, and transfer various types of personal data about you, which we have classified as follows:
● Genetic Data, which includes genetic analysis from DNA and RNA samples that have been anonymized.
● Identity Data, which includes your first name, last name, username, job title, or any similar identifier.
● Contact Data, which includes your billing address, delivery address, email address, and phone numbers.
● Financial Data, which includes your bank account and payment card details.
● Transaction Data, which includes information about payments you have made, as well as other details about the products and services you have purchased from us.
● Technical Data, which includes your internet protocol (IP) address, login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technologies used by the devices you use to access our websites.
● Profile Data, which includes your username and password, purchases or orders made by you or your business, your interests, preferences, feedback, and survey responses.
● Usage Data, which includes information about how you use our websites, products, and services.
● Marketing and Communications Data, which includes your preferences for receiving marketing communications from us and our third parties, as well as your communication preferences.
We also gather, utilize, and distribute Aggregated Data, such as statistical or demographic data, for any purpose. This data may be derived from your personal data, but it is not considered personal data under the law, as it does not disclose your identity, either directly or indirectly. For instance, we may aggregate your Usage Data to determine the percentage of users who access a specific website feature. However, if we combine or connect Aggregated Data with your personal data, such that it can directly or indirectly identify you, we will handle the combined data as personal data, and it will be utilized in accordance with this privacy policy.
 

Genetic data 
Due to the nature of our services, we gather Special Categories of Personal Data, specifically genetic data. However, we only handle data that has been anonymized to the point that the data subject is not identifiable by us. Despite this, our analysis may contain enough genetic markers to be distinctive to an individual, even if we have eliminated other names and identifiers.
 

We mandate that all of our clients obtain explicit and specific consent from you in order to allow us to carry out our services and process your genetic data. 
 

If You Fail to Provide Personal Data
 

If we are legally required or have a contract with you that necessitates the collection of personal data, and you refuse to provide that data upon request, we may not be able to fulfill the contract we have or are attempting to establish with you. For example, we may be unable to provide you with goods or services. In this instance, we may have to terminate a product or service you have with us, but we will notify you if this is the case.
 

3.HOW IS YOUR PERSONAL DATA COLLECTED?
 

We use various methods to collect data from and about you, including:
 

Direct interactions. You may provide us with your Identity, Contact, and Financial Data by filling out forms or corresponding with us via post, phone, email, or other means. This includes personal data you provide when you:
● Registering or signing up for accounts, newsletters, events, webinars or contests;
● Participating in webinars and other online events;
● Communicating with us at conferences, events, and trade fairs;
● Submitting information in Customer Service requests, contacts forms, or otherwise seek help from us;
● Submitting information in response to surveys, e-mails, promotions and other feedback forms regarding our Services;
● During personal or virtual business meetings, e-mail and telephone calls with SeekGene’s employees.
Automated technologies or interactions. By browsing our websites, you provide us with automatic information. The term "Automatic Information" is information automatically collected by our web server that your web browser makes available whenever you visit one of our websites. This information is stored temporarily in a so-called log file. The following information is processed and stored until automatically deleted:
● the website you are accessing;
● the time and duration of your visit;
● the pages you have visited;
● your searches and temporarily;
● your IP address;
● the referrer website;
● your browser type (e .g. Chrome, Safari), browser software language and version;
● your operating system (e.g. Microsoft Windows 11) and its interface;
● the domain name and the address of your internet access provider.
Your IP address is used to identify the city of from which you are accessing the site as well as the company to which the IP address has been registered. We use browsing data of our users for creating aggregated statistics, to learn what is of interest to users in order to improve various aspects of our  websites and to provide services like troubleshooting, and to recognize users who have already visited our websites in order to customize their website experiences for their future visits. We also use the browsing data to study traffic patterns and maintaining or restoring the security of our websites or to detect and correct technical defects and errors.
 

Third parties or publicly available sources. We may receive personal data about you from various third parties, as outlined below:
● Anonymized Data (including genetic data and DNA samples) from our clients. 
● Technical Data from the following parties:
(a)analytics providers;
(b)advertising networks; 
(c)search information providers.
● Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
● Identity and Contact Data from data brokers or aggregators.
 

4.HOW WE USE YOUR PERSONAL DATA 
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. Most commonly, we will use your personal data in the following circumstances:
● Where you have given us explicit consent to use your personal data for a specific purpose.
● Where it is necessary to protect your vital interests or the vital interests of another person.
● Where it is necessary for the establishment, exercise, or defense of legal claims.
Click here  to find out more about the types of lawful basis that we will rely on to process your personal data.
In general, we do not use consent as the legal basis for processing your personal data, although we will seek your consent before sending you third-party direct marketing communications via email or text message. You have the right to withdraw your consent to marketing at any time by contacting us.
 

Purposes for Which We Will Use Your Personal Data
We have provided a table below outlining the ways in which we intend to use your personal data, along with the legal basis we rely on to do so. Where applicable, we have also identified our legitimate interests.
Please note that we may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. If you require further information on the specific legal basis we are relying on to process your personal data where more than one ground has been outlined in the table below, please do not hesitate to contact us.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 
 

Promotional Offers from Us
We may utilize your Identity, Contact, Technical, Usage, and Profile Data to create an understanding of what we believe you may want or need, or what may be of interest to you. This is how we determine which products, services, and offers may be applicable to you (referred to as marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, and you have not chosen to opt-out of receiving such marketing.
 

Third-party Marketing
We will obtain your explicit consent before sharing your personal data with any third party for marketing purposes.
 

Opting Out

You can request us or third parties to stop sending you marketing messages at any time by contacting us. If you choose to opt-out of receiving marketing messages, please note that this will not affect personal data that has been provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.
 

Cookies
You have the option to configure your browser to reject all or some browser cookies or notify you when websites set or access cookies. However, if you choose to disable or reject cookies, please be aware that some parts of our websites may become inaccessible or may not function properly. 
Change of Purpose
We will solely utilize your personal information for the purposes we initially obtained it for, unless we reasonably believe that we need to use it for another purpose that is compatible with the original intent. In the event that we require utilizing your personal data for an unrelated purpose, we will inform you and explain the legal basis that permits us to do so.
Please be advised that we may process your personal data in compliance with the aforementioned regulations, without your knowledge or consent, when it is required or allowed by law.
 

5.DISCLOSURES OF YOUR PERSONAL DATA
We may disclose your personal information to the parties listed below, for the purposes outlined in the Purposes for which we will use your personal data above.
● Internal Third Parties, as defined in the Glossary.
● External Third Parties, as defined in the Glossary.
● Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If our business undergoes a change, the new owners may use your personal information in the same way as described in this privacy policy.
We require all third parties to respect the security of your personal information and to handle it in accordance with the law. We do not permit our third-party service providers to use your personal information for their own purposes and only allow them to process it for specified purposes and in accordance with our instructions.

6.INTERNATIONAL TRANSFERS
We are based in the China company, however, whenever we transfer your personal information outside of the European Economic Area (EEA), we ensure that a similar level of protection is provided by implementing at least one of the following safeguards:
● Transferring your personal information to countries that have been determined to provide an adequate level of protection for personal information by the European Commission.
● Using specific model contracts approved by the European Commission, which provide personal information with the same level of protection it has in Europe when transferring personal information outside of the EEA.

In particular, when transferring data to our group companies in China, we use model contracts that have been approved by the European Commission.
Please contact us if you require further information about the specific mechanism we use when transferring your personal information outside of the EEA. 
 
7.DATA SECURITY
We have implemented suitable security measures to prevent your personal information from being lost, misused, accessed without authorization, altered, or disclosed. Furthermore, we restrict access to your personal information to employees, agents, contractors, and other third parties who require access for business purposes. They will only process your personal information according to our instructions and are bound by a duty of confidentiality.
We have established procedures to handle any suspected personal information breaches and will notify you and any relevant regulatory authorities of a breach if required by law.

8.DATA RETENTION
How Long Will You Use My Personal Data For?
We will keep your personal information only for as long as necessary to fulfill the purposes for which we obtained it, including meeting any legal, regulatory, tax, accounting, or reporting requirements. If there is a complaint or a reasonable prospect of litigation related to our relationship with you, we may retain your personal information for a longer period.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
In some instances, you can request that we delete your information: please refer to your legal rights below for more information.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes.  In such cases, we may use this information indefinitely without further notice to you.
 

9.YOUR LEGAL RIGHTS
As per applicable laws, including GDPR or LGPD, you have certain rights which are outlined below:
 

9.1 Your rights under the GDPR

● Access and Portability: You have the right to request access to your personal data held by us and certain information about the purpose, categories, and recipients of your personal data. You can also request a copy of your data in a structured, machine-readable format and ask us to share it with another data controller.
 

● Correction: You have the right to ask us to correct any inaccurate or incomplete personal data.
 

● Right to Deletion: Under certain circumstances, you have the right to ask us to delete your personal data, provided there is no overriding legitimate basis for processing or retaining it.
 

● Restriction: Under certain circumstances, you have the right to ask us to restrict the processing of your personal data, provided there is no legitimate basis for processing it.
 

● Objection: You can object to our processing of your personal data based on our legitimate interests and we will stop processing your data unless we can demonstrate an overriding legitimate ground.
 

9.2 Your rights under LGPD
 

● Confirmation, Access and Portability: You have the right to request confirmation of the processing of your personal data, access to your personal data held by us, and certain information about the entities with which we have shared your data. You can also request a copy of your data in a structured, interoperable format and ask us to share it with another data controller.
 

● Refusal or Withdrawal of Consent: You have the right to refuse or withdraw your consent, which may impact our ability to provide certain products and services to you.
 

● Correction: You have the right to ask us to correct any inaccurate or incomplete personal data.
 

● Right to Deletion, Blockage or Anonymization: Under certain circumstances, you have the right to ask us to delete, block or anonymize your personal data, provided there is no overriding legitimate basis for processing or retaining it.
 

● Restriction: Under certain circumstances, you have the right to ask us to restrict the processing of your personal data, provided there is no overriding legitimate basis for processing or retaining it.
 

● Objection: You can object to specific processing purposes, but we may demonstrate legitimate reasons to process your personal data if it is essential for the functionality of our products or services.
 

If you wish to exercise any of the rights set out above, please contact us.
 

No Fee Usually Required
 

There is usually no fee required to access your personal data or to exercise your rights. However, if your request is unfounded, repetitive or excessive, we may charge a reasonable fee. In such cases, we may also refuse to comply with your request.
 

What We May Need From You
 

In order to confirm your identity and ensure that you have the right to access your personal data (or to exercise any of your other rights), we may need to request specific information from you. This is a security measure to prevent the disclosure of personal data to unauthorized individuals. We may also contact you to request further information to expedite our response to your request.
 

Time Limit to Respond

We aim to respond to all legitimate requests within one month. However, some requests may be more complex or involve multiple requests, which may require us to take longer than a month to respond. If this is the case, we will notify you and keep you informed of the status of your request.
 

10.GLOSSARY 
 

Lawful Basis
● Legitimate Interest means the interest of our company in conducting and managing our business to provide you with the best service/product and the most secure experience. We ensure that we take into account and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are outweighed by the impact on you (unless we have your consent or are required or permitted to do so by law). For more information on how we evaluate our legitimate interests against any potential impact on you in relation to specific activities, please contact us.
● Performance of Contract means processing your data when it is necessary for the performance of a contract in which you are a party or to take steps at your request prior to entering into such a contract.
● Comply with a legal obligation means processing your personal data when it is necessary to comply with a legal obligation that we are bound by.

Third Parties
Internal Third Parties
Other companies in the SeekGene Group acting as joint controllers or processors and who are based in China or other countries.
 

External Third Parties
● Service providers acting as processors who provide IT and system administration services.
● Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
● Revenue & Customs, regulators, and other authorities acting as processors or joint controllers, who require reporting of processing activities in certain circumstances.