Privacy Notice

Please read the below carefully

Welcome to the privacy notice of Smart DNA, a company registered inFederal Republic of Nigeria and with our registered office at 42 Ajose street, Maryland, Lagos.

.

Smart DNA 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 visit our website (regardless of where you visit it from) and/or when you use our products and services, namely the DNA, Drug or Alcohol Testing Kits. This privacy notice will tell you about your privacy rights and how the law protects you.  Furthermore, this notice implements the requirements of the General Data Protection Regulation (the law which protects and controls the use of personal data) and the ‘Caldicott Principles’ which are guidelines designed to ensure that all patient data remains confidential unless consented to otherwise. Smart DNA has developed systems and processes to ensure that the standards set out in both documents are met or exceeded.

The website operated by us is www.smartdna.com.ng 

This privacy notice is provided in a layered format, so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

GLOSSARY

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Smart DNA collects and processes your personal data:

through your use of our website, including any data you may provide through our website when you contact us via our contact page or when you use our live chat feature;

when you purchase and use our products and services, including use of our DNA, Drug or Alcohol Testing Kits; or

through referral forms and phone calls from lawyers, sample donors or members of the public.

Where you are submitting personal data on behalf of a child, please be aware that this privacy notice shall also apply to the child’s personal data. We have done our best to write this privacy notice in simple clear terms, but if you have any questions concerning this privacy notice or your child’s personal data, please contact us at quality@alphabiolabs.com

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.

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:

Non-Special Category of Personal Data

Identity Data includes first name, last name, username or similar identifier, title, date of birth, job title & company name.

Contact Data includes home address, email address and telephone number.

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 purchased from us.

Technical Data includes internet protocol (IP) address, 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.

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, products 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 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.

Special Categories of Personal Data

This category of data was previously referred to as ‘Sensitive Personal Data’. This type of data is required for the provision of DNA, Drug and Alcohol Testing. We may collect details about your race or ethnicity, information about your health (including your medical history and GP details), genetic and biometric data (including DNA sample/profile) and test results via the website and/or following your use of our products and services, namely the DNA, Drug and Alcohol Testing kits.

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 (for example, to provide you with our goods or services, namely DNA, Drug and Alcohol testing). In this case, we may have to cancel a product or service you have with us 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:

Complete the forms on our website contact pages;

Use the live chat feature on our website;

Apply for, purchase and use our products and services, namely the DNA, Drug and Alcohol Testing kits;

Make an appointment;

Create an account on our website;

Subscribe to our service or publications;

Request marketing to be sent to you;

Give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

analytics providers such as Google based outside the EU and from our third party providers for emails and communications.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Through referral forms and phone calls from lawyers, sample donors or members of the public

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 or regulatory obligation.

Where processing is necessary to carry out DNA, Drug and Alcohol Testing, and to provide you with the results of such tests.

Where we use a ‘Special Category’ of data, including Medical Data, we are required to confirm an additional lawful basis (to that set out above) for the processing of such data which will most commonly include the following circumstances:

Where processing is necessary for, medical diagnosis, the provision of health or social care or treatment, including carrying out DNA, Drug and Alcohol testing, and providing the results of such tests.

Express consent that is freely, affirmatively, and transparently, given with regards to the processing described.

In addition to the data protection laws which we adhere to, we also respect the common law right of confidentiality relation to your Medical Data.  We will never share your records to any third party not involved in the provision of services (other than your registered GP or a sample collector) between us unless you expressly consent to us doing so.

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 at info@alphabiolabs.com

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. For example, we may be required to disclose your data in the interests of public health, national security, or serious threats to health and/or safety (including child abuse or neglect).

Data security

We work hard to prevent your personal data from being accidentally lost, destroyed, used or accessed in an unauthorised way, altered or disclosed. In particular:

We use a secure server to protect any financial transactions on our website. We also take appropriate physical, electronic and managerial measures to ensure that the data disclosed to us is kept secure, accurate and up to date, and kept for only as long as is necessary for the purposes for which it is used. For finance reasons some information may be retained for longer.

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.

All of our reports are sent as a pdf file that require a password to open them.  This password is picked by the person who instructs the test. This password protects the report from being opened by anyone who does not know the password.

If you would like us to send a copy of the report without a password protecting it, you will need to send us a written request confirming:

You want us to remove the password protection

You understand the report will be able to be opened by anyone who receives it

You are happy to accept responsibility for any consequences as a result of the removal of the password

You will not hold us accountable for any data breach due to the removal of the password

You have read and are happy with this privacy notice.

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 sites; any transmission is at your own risk. Once we have received your information, we will use those strict procedures and security features set out above, to try to prevent unauthorised access.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data.

In some circumstances we may 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.