PRIVACY POLICY

Introduction

Welcome to Geno Health’s privacy policy.

Geno Health respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our services and tell you about your privacy rights and how the law protects you.

 

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Geno Health collects and processes your personal data through your use of this website and/or our services.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Geno Health Limited is the controller and responsible for your personal data (collectively referred to as Geno Health, “we”, “us” or “our” in this privacy policy).

We have appointed a data protection officer (DPO) 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 (see Section 9 below), please contact the DPO using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO, Leon Tang, in the following ways:

Email address: [email protected]

Postal address: 3rd Floor, 150 Fleet St, London EC4A 2DQ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 policy and your duty to inform us of changes

We keep our privacy policy under regular review.

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 policy of every website you visit.

2. 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 as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, sex and gender, details of your parent or guardian (if you are a child).
• Contact Data includes address, email address, telephone numbers and details of your next of kin (please ensure you provide a copy of this privacy policy to your next of kin).
• 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 this website.
• Financial Data includes bank account and payment card details and preferred payment methods.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• Insurance Data includes details about your medical insurance, such as the insurer name and policy/identification details.
• Health Data includes your medical records, medical history, details of previous health professionals, genetic data, record of services and treatments you receive from us.
• Profile Data includes your preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. We will notify you if this is the case at the time.

3. 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, Financial, Transaction, Insurance, Health, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, WeChat, WhatsApp or otherwise. This includes personal data you provide when you:
  • contact us;
  • book or our services;
  • come to our clinic;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback.
• Automated technologies or interactions. As you interact with our website, we will 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 collect Profile and Usage Data. Please refer to section 10 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:
  • your insurance provider;
  • your previous health provider(s);
  • your next of kin or family member(s);
  • translators or interpreters;
  • health professionals;
  • organisations which provide information about your care;
  • technical and payment services;
  • publicly available sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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 obligation.
• Where processing is necessary for the provision of medical diagnosis, health care or treatment, and/or the management of health care services, pursuant to contract with a health professional.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We explain more about what a “lawful basis” is in the section below the table. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of data & Lawful basis for processing including basis of legitimate interest
To inform potential customers of what our business offers and understand how customers and potential customers are using and interacting with our website	(a) Identity – Necessary for our legitimate interests (to study how customers and potential customers use our services) (b) Technical (c) Usage
To register you as a new customer and book and manage appointments and queries	(a) Identity – Performance of a contract with you (b) Contact – Necessary for the provision of medical diagnosis, health care or treatment, and/or the management of health care services, pursuant to contract with a health professional (c) Health (d) Insurance
To process payment for services to you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity – Performance of a contract with you (b) Contact – Necessary for our legitimate interests (to recover debts due to us)   (c) Financial (d) Transaction (e) Marketing and Communications (f) Insurance
To provide our services to you	(a) Identity – Performance of a contract with you (b) Contact – Necessary for the provision of medical diagnosis, health care or treatment, and/or the management of health care services, pursuant to contract with a health professional (c) Health (d) Insurance
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review, give feedback or take a survey	(a) Identity – Performance of a contract with you (b) Contact – Necessary to comply with a legal obligation (c) Profile – Necessary for our legitimate interests (to keep our records updated and to study how customers use our services) (d) Marketing and Communications
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity – Performance of a contract with you (b) Contact – Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business) (c) Profile (d) Usage (e) Marketing and Communications
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity – Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Contact – Necessary to comply with a legal obligation (c) Technical
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising and content we serve to you	Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
To use data analytics to improve our website, services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) (a) Technical (b) Usage
To make suggestions and recommendations to you about services that may be of interest to you	Necessary for our legitimate interests (to develop our services and grow our business) (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications

 

‘Lawful Basis’ explained

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Marketing

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

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Change of purpose

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 and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table under the heading ‘Purposes for which we will use your personal data’ above.

• External third parties, namely:
  • Service providers who provide IT and system administration services.
  • Professional advisers acting including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting who require reporting of processing activities in certain circumstances.
  • Healthcare professionals or organisations.
  • Emergency services or the police.
  • Marketing research companies.
  • ‘Semble’ online booking software.
  • ‘Halaxy’ online booking software.
  • ‘UnionPay’ payment provider.
  • Intermediary care providers such as translators, interpreters or care assistance companies.
• 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 policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may need to transfer your personal data outside the United Kingdom. The country we will most commonly need to transfer your personal data to will be China.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office or other authority responsible for assessing adequacy under applicable data protection law;
• We may use specific contracts approved by the Information Commissioner’s Office or other authority responsible for approving such terms under data protection law, which give personal data the same protection it has in the UK, having assessed whether further safeguards are needed.
• We may request your specific consent to transfer your personal data, in accordance with Article 49 of the UK GDPR. In this case, we will inform you of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards;
• We may rely on the fact that the transfer is necessary for the performance of our contract with you or our contract with a third party, in accordance with Article 49 of the UK GDPR.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Section 9 ‘Your Legal Rights’ below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out in Section 1 above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use the following cookies:

• Traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
• Essential cookies to enable essential services and functionality, including identity verification, service continuity and site security.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our website, for example some parts of this website may become inaccessible or not function properly.