Privacy Policy

Objectives

Protecting your privacy and data security is our top priority, DNALL (“DNALL” or we) has created a notice of this Privacy Policy ("Policy") in order to comply with the Personal Data Protection Act B.E. 2562 and related secondary laws. However, please read and understand this Privacy Policy in conjunction with the terms and conditions for using the service as it relates to you.



Scope

This Privacy Policy ("Policy") applies to the services and products of DNALL that are offered or distributed to customers through healthcare facilities, sales representatives, websites, mobile applications, customer service center (Call Center) Social media channels, online contact, and other channels through which DNALL collects your personal information.

Under this policy "Personal Information" means information about an individual by which an individual can be identified directly or indirectly, and "Sensitive Personal Data" means personal data that is classified by law as sensitive personal data.

DNALL reserves the right to amend this policy from time to time. DNALL, therefore, urges you to regularly check for any amendments to this Policy. Any revision will be effective immediately upon the posting of the revised Privacy Policy on DNALL's website or application.



Privacy Policy

1) Your personal data collected by DNALL

DNALL will collect, use and/or disclose your genetic information for the purpose of the test. Your personal information that is collected and processed under this policy, whether it is personal information that you directly provide to DNALL or personal information that DNALL automatically collects from you, or personal information that DNALL receives from third parties, including:



1.1) Personal contact information

(1) Personal information such as name, surname, date of birth, age, gender, identification card number, photograph, and signature, etc.

(2) Contact information such as an address, telephone number, fax, e-mail address, user ID for the application (line ID), contact information, etc.

(3) Transaction information such as service history, trading history, payment details, and bank accounts, etc.

(4) Marketing information such as your satisfaction with the services received, and opinions on the service of personnel

(5) Technical information, computer data/ any mobile device on a computer system, or any other technological device that you use to access one of DNALL's websites or applications, such as log, IP address, operating system type, web browser type and version, and the information DNALL collects through cookies (Cookies) or other similar technologies, etc.

(6) Information from using the website/ communication when you use the website of DNALL. DNALL will use automatic storage technology to collect certain information about your operations, such as information about the website address, user opinion on any information you voluntarily disclose to DNALL regarding your experience of using DNALL's services and/or products, page or content and how long you read it and any other similar information and statistics, such as the number of responses to content, errors in downloading and length of visits to pages, etc.



1.2) Sensitive Personal Data

DNALL will only collect, use and/or disclose your sensitive personal information as necessary for the purpose of sending information such as customer satisfaction forms, press releases, advertisements, promotional content, marketing of products, services, and other special offers.



1.3) Personal information of minors who are under the age of majority

DNALL will not request or store personal information from minors who are under the age of majority. If DNALL finds out or be inform that it has inadvertently stored personal information from a minor, DNALL will immediately delete the personal information of the minors from the data collection system. However, DNALL may collect personal information about underage minors directly from their parents or guardians and with the express consent of such persons.



2) Purposes and legal bases for which DNALL collects, uses or discloses your personal information

2.1) We deal with many international organizations and use global information systems. As a result, we may transfer your personal data to countries outside Thailand for the purposes set out in this Privacy Policy. Purposes for which DNALL collects, uses or discloses your general personal information on the basis of express consent and/or contractual basis for the purpose of use of sensitive personal data which requires your express consent for various purposes in collecting, using, disclosing and/or transferring sensitive personal data overseas are as follows;

-Registration Information

Information you provide during account registration or when purchasing the Services, such as a name, user ID, password, date of birth, billing address, shipping address, payment information (e.g., credit card), account authentication information, or contact information (e.g., email, phone number).

-Genetic Information

Information regarding your genotype (e.g., the As, Ts, Cs, and Gs at particular locations in your DNA). Genetic Information includes the DNALL genetic data and reports provided to you as part of our Services.

-Sample Information

Information regarding any sample, such as a saliva sample, that you submit for processing to be analyzed to provide you with Genetic Information, laboratory values or other data provided through our Services.

-Self-Reported Information

Information you provide to DNALL including your gender, disease conditions, health-related information, traits, ethnicity, family history, or anything else you provide to us within our Service(s).

-User Content

Information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials, other than Genetic Information and Self-Reported Information, generated by users of DNALL Services and transmitted, whether publicly or privately, to or through DNALL. For example, User Content includes comments posted on our social media channels or messages you send through our Services.

-Web-Behavior Information

Information on how you use our Services or about the way your devices use our Services is collected through log files, cookies, web beacons, and similar technologies (e.g., device information, device identifiers, IP address, browser type, location, domains, page views).

2.2) Purposes for which DNALL collects, uses or discloses your personal data through other legal bases.

DNALL may rely on or refer to (1) the contract performance base, for initiating a contract or entering into a contract or performing a contract with you; (2) the Legal Compliance Base, for the performance of DNALL's legal duties; (3) the legitimate interests of DNALL and of third parties; (4) the base for preventing or suppressing harm to life, body or health of persons; and/or (5) the base of public interest, for carrying out missions in the public interest or performing duties in the exercise of state power or other legal bases as permitted by the Personal Data Protection Act, depending on the case, to collect, use and/or disclose your personal data.



3) DNALL may disclose or transfer your personal information to any person or entity.

DNALL may disclose or transfer your personal information to the following third parties who collect, use, or disclose personal information for the purposes stated in this Privacy Policy, you may also fall under the privacy policies of those third parties. We, therefore, recommend that you read the privacy policies of such third parties for further information on how such third parties collect, also use, or disclose your personal information

3.1) Company service provider, DNALL may employ other companies, agents, or contractors to provide services on behalf of DNALL or facilitate the provision of services to you. DNALL may disclose your personal information to the following third-party service providers, including but not limited to: (1) Infrastructure Developers, Internet, Web Sites, and Information Technology Service Providers (2) Logistics and Transport Service Providers (3) Data Analytics Service Providers (4) Contact Agents or Agencies Communications, advertising media, market survey and marketing (5) Cloud storage and service providers (6) Seminar providers (7) Tour operators (8) Service providers Printing Services (9) Payment Service Providers and Payment Systems (10) Service Providers of Document Storage and/or Shredders.

In order to provide such services, service providers may have access to your personal data. However, DNALL will provide personal information to its service providers only as necessary for providing such services and will ask the service provider not to use your personal information for any other purpose.



3.2) Third parties as required by law in some cases, DNALL may be required to disclose and/or transfer your personal information to government agencies, Law enforcement agencies, courts, officials, government agencies, law enforcement, auditors, independent directors, or other persons. In case DNALL has reason to believe that it is necessary to perform duties in accordance with the law or legal regulations or to protect the rights of DNALL or other person's rights or for the safety of persons or to investigate, prevent, or deal with fraud issues or in terms of security or safety



3.3) Assignee of rights and/or duties in case of organization restructuring Mergers and Acquisitions, Sales, Acquisitions, Joint Ventures, Transfers of Rights, Changes in Ownership or the disposal of a business, property or stock, or a similar transaction. Either partially or completely Assignee of rights and/or duties of DNALL will comply with this Privacy Policy. To respect your personal information.



4) Cookies and how cookies are used



When you visit DNALL's website DNALL automatically collects certain information from you through the use of cookies.

Cookies are information specific to your computer when you visit the website. Cookies store or track information about your use of the website and use it for trend analysis, website administration, tracking the movement of the user's use of the website, or remembering the user's settings. Some types of cookies are necessary (Necessary cookies) because, without these types of necessary cookies, Website pages may not function properly, and other types of cookies will allow DNALL to improve your experience of using the website and customize the content according to your needs. and make surfing the website more convenient because cookies remember usernames. (in a safe way) and remember your language preferences

Usually, most Internet browsers will ask you to set up whether you accept cookies. If you opt-out of being tracked by cookies or delete cookies may affect your use of the website and if cookies are not stored, the use of certain functions or websites may be restricted.

Besides, third parties may also use cookies through DNALL's website to serve advertisements related to your interests. According to the activity history of your website visits, these third parties may collect your profile or other information to know how you access the website and the web pages that you visit after leaving DNALL's website. The information collected through these automated systems may be related to the personal information you previously provided on DNALL's website. You may also be subject to third-party privacy or cookie policies those as well. DNALL, therefore, recommends that you read the privacy policy or the cookie policy of such third parties to learn more about how such third parties collect, use or disclose your personal information.



5) Transfer of your personal information to foreign countries

DNALL may disclose or transfer your personal information to third parties, or service providers located in foreign countries where the destination country may have Standards for personal data protection that are higher or lower than Thailand. When it is necessary to transfer your personal data to a foreign country that has a lower standard of personal data protection, DNALL will take steps and measures to ensure that you have an adequate level of protection for the personal data that is transferred and the person receiving the personal data transfer has appropriate personal data protection standards or as required by law.



6) The length of time DNALL maintains your personal information

DNALL will keep your personal information for as long as is reasonably necessary to use it for the purposes DNALL provides to you in accordance with this Privacy Policy. And to comply with various laws and regulations, DNALL may keep your personal data longer if necessary and/or can do so in accordance with applicable law.



7) Your rights as the subject of personal data

Subject to the provisions of the law and the relevant legal exemptions, you may have the rights set forth below

Accessibility You may have the right to request access to or obtain a copy of the personal information DNALL collects, uses, or disclose about you

Correction You may have the right to request correction of personal data collected by DNALL, use, or disclose about you to be accurate, current, complete, and not misleading

Personal Data Transfer You may have the right to obtain personal information that DNALL holds about you in an organized and readable form electronically and to transmit or transfer such personal data to another personal data controller, which must be (a) the personal data you have provided to DNALL and (b) if DNALL has received your consent for the collection, use or disclose your personal information or to perform the contract DNALL has with you, or DNALL must use your personal information for the public benefit or comply with the law. DNALL has the discretion to reject your request.

Objection You may have the right to object to the collection, use or disclose your personal information as required by applicable law

Deletion or destruction You may have the right to request DNALL to delete, destroy or cause your personal data collected by DNALL, use or disclose which is personal information that cannot identify you, unless DNALL's retention of such personal data is for legal compliance, or to establish statutory claims, for the exercise or defense of statutory claims.

Complaint You have the right to lodge a complaint with a government agency relating to the protection of personal data. In case you believe that DNALL has not complied with the Personal Data Protection Laws



8) Security measures

DNALL has put in place appropriate security measures for personal data which cover management preventive measures, technical precautions, and physical protective measures. Regarding accessing or controlling access to personal data. To maintain secret completeness and the availability of personal data to prevent the loss, access, use, alteration, correction, or disclosure of personal data without authorization or misuse, as required by applicable law.

DNALL has put in place measures to control access to personal data and access to equipment for storing and processing personal data that is safe and appropriate for the collection, use, and disclosure of personal information. DNALL has also put in place measures to limit access to personal data and the use of devices for storing and processing personal data by specifying access rights to the user's data, the right to grant access to information to the designated person(s) and the responsibilities of the user, to prevent unauthorized access to personal information, disclosure, knowing or illegal copying of personal information. or theft of personal data storage or processing devices. In addition, DNALL has put in place measures for retrospective review of access, change, deletion, or transfer of personal data. To be consistent with the methods and mediums used for collecting, using, or disclosing personal information.



9) Contact DNALL

DNALL has appointed a Data Protection Officer following the provisions of the Personal Data Protection Act (PDPA) 2019.If you wish to exercise your rights in relation to your personal data or have questions about your personal data under this Privacy Policy, please contact DNALL or the company's Personal Data Protection Officer at privacy@bangkokgenomics.com





Update on 20 Jan 2023