Privacy Policy

Our Privacy Policy was last updated and posted on May 25, 2018, with additional information required by new EU data protection legislation. It governs the privacy terms of our Website, located at http://www.dnacode.com, sub-domains, and any associated web-based and mobile applications (collectively, “Website”), as owned and operated by Health & Wellness Decoding (HWD) Pte Ltd. Any capitalized terms not defined in our Privacy Policy, have the meaning as specified in our Terms of Service.

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. We use your Personal Information only for providing and improving the website. By using the website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at http://www.dnacode.com. The following outlines our privacy policy.

  • Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
  • We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
  • We will only retain personal information as long as necessary for the fulfillment of those purposes.
  • We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
  • Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
  • We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
  • We will make readily available to customers information about our policies and practices relating to the management of personal information.
  1. Your Privacy
    Health & Wellness Decoding (HWD) Pte Ltd follows the Personal Data Protection Act 2012 (PDPA) as the primary governing law for protecting individual privacy.  Our Privacy Policy is a legal statement that explains how we may collect information from you, how we may share your information, and how you can limit our sharing of your information. We utilize the Personal Data you offer in a way that is consistent with this Personal privacy Policy. If you provide Personal Data for a particular reason, we could make use of the Personal Data in connection with the reason for which it was provided. For example, registration info sent when developing your account, might be used to suggest products to you based on past acquisitions. We might use your Personal Data to offer access to services on the Website and monitor your use of such services. HWD may also utilize your Personal Data and various other personally non-identifiable info gathered through the Website to assist us with improving the material and functionality of the Website, to much better comprehend our users, and to improve our services. You will see terms in our Privacy Policy that are capitalized. These terms have meanings as described in the Definitions section below.
  2. Definitions
    “Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Website with a web browser. It may also include publicly available information that is shared between you and others.

“Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Website. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we obtain about you.

  1. What Information We Collect
    3.1 Personally Identifiable Information

Generally, you control the amount and type of information you provide to us when using our Website. We may collect information related to you, including, but not limited to your username, first and last name, e-mail, password, phone number, and mailing address, credit card information, when you make a purchase on our website, create an account to log in to our network or at other times. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us. For customers who engage us for our testing services, we may also collect basic information in order to perform the applicable service and/or test. This information may include but is not limited to date of birth, gender, height and weight. This information is used to provide accurate and complete testing results applicable to the test requested by the client. We may also collect information that is necessary for our legitimate interests, which will be disclosed to you at the time of collection.

As a Visitor, you can browse our website to find out more about our Website. You are not required to provide us with any Personally Identifiable Information as a Visitor.

3.2 Non Personal Information Collected
When you use our Website, we automatically collect certain computer information by the interaction of your mobile phone or web browser with our Website. Such information is typically considered Non Personal Information. We also collect the following:

  • Cookies
    Our Website uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to personalize the Content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all. We never place Personally Identifiable Information in Cookies.
  • Geographical Information
    When you use the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display information with relevant data or advertisements. We will not share your current location with other users or partners. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.
  • Automatic Information
    We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website to which you’re headed when you leave our website. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet Website provider name, web browser type, type of mobile device, and computer operating system. We use all of this information to analyze trends among our Users to help improve our Website.
  • Log Data
    Like many Website operators, we collect information that your browser sends whenever you visit our Website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

Under the Child’s Online Privacy Security Act, no Website operator can require, as a condition to involvement in an activity, that a child younger than 13 years of age divulge more details than is reasonably required. HWD abides by this demand. HWD just collects information willingly offered; no information is gathered passively. children under 13 can submit only their email address when sending us an email in our “Contact Us” area. HWD makes use of the email address to respond to a one-time demand from a child under 13 and afterwards deletes the email address. In case HWD collects and maintains personal information relating to a child under 13, the parent may send out an email to us to review, alter and/or erase such info as well as to decline to enable any additional collection or use of the child’s information.

  1. How We Use Your Information
  • General Use

In general, information you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your information to facilitate the creation of and secure your account on our network; identify you as a user in our system; provide improved administration of our website and services; improve the quality of experience when you interact with our website and services; send you administrative e-mail notifications; respond to your inquiries; to enhance our website for optimal user experience; to monitor the usage and performance of our website and services; to facilitate transactions and process payments; to provide maintenance, support, and customer service for our site; to conduct research and analysis; and to fulfill other legitimate purposes permitted by applicable law.

  • Use of your Testing Information

We will only use your Testing Information in order to provide you the services you have requested, process your order, and respond to any order or billing related questions.

  • Feedback

If you provide feedback on any of our services to us, we may use such feedback for any purpose, provided we will not associate such feedback with your information. We will collect any information contained in such communication and will treat the information in such communication in accordance with this Privacy Policy and our Terms of Use.

  • Data Aggregation
    We retain the right to collect and use any Non Personal Information collected from your use of our Website and aggregate such data for internal analytics that improve our Website and Service as well as for use or resale to others. At no time is your Personally Identifiable Information included in such data aggregations.
  1. Who we share your information with and why
  • Affiliates and Service Providers
    We do not sell, rent, or otherwise provide your Personally Identifiable Information to unrelated third parties for marketing purposes. We may share your information with agents to the extent necessary for them to provide their products and services to us, or to provide you with the products and services that you have requested (i.e. testing laboratories, supplement providers, etc.). We may provide your information to affiliates that provide services to us with regards to our Website (i.e. payment processors, Website hosting companies, etc.); such affiliates will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information. Other examples include, database storage, file storage and file destruction, hosting services, marketing assistance, analyzing user data, processing payment card information, and for other legitimate purposes permitted by applicable law.
  • Legally Required Releases of Information
    We may be legally required to disclose your Personally Identifiable Information, if such disclosure is (a) required by subpoena, law, or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our Legal Terms; (d) necessary to protect us from legal action or claims from third parties including you and/or other Members; and/or (e) necessary to protect the legal rights, personal/real property, or personal safety of HWD, our Users, employees, and affiliates.
  1. Your rights
  • Choices

We offer you choices regarding the collection, use, and sharing of your information. We will periodically send you free newsletters and e-mails that directly promote the use of our website or services and may contain advertisements for third party companies or our Affiliates. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. Despite your indicated e-mail preferences, we may send you emails related to your account or transactions there under, or notices of any updates to our Terms of Use or Privacy Policy.

  • Withdrawal of Consent

You have the right to withdraw your consent to processing that is currently underway with your consent. Consent can be withdrawn by sending an email. Without your consent, HWD will use information, only insofar as such processing is permitted by applicable law (e.g., for the performance of an Agreement between HWD and you) or where such processing is necessary for compliance with a legal obligation to which HWD is subject.

  • Accessing, deleting and updating your information.

At your request, we will inform you of what personal information we have on file. In accordance with applicable data protection laws, you may have the right to request: access to, rectification, and erasure of your personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability. To exercise your rights under these provisions, please contact us via email at info@dnacode.com. When we receive your requests, we may ask you to verify your identity before we can act on your request. We may withhold information where the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested. Please note that we may be required (by law, accrediting bodies, or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). Please be advised that by deleting your personal information, it will limit or eliminate our ability to provide future communication or explanation regarding any products or services, test results or other offerings in connection with HWD. Please be further advised that after your personal information is deleted that residual copies may take a period of time before they are deleted from all latent and backup systems.

  1. Data retention

The data you provide to us may be necessary to carry out tasks prior to testing, such as verifying identity or payment details when signing in to use an account. We retain required data based on testing regulatory requirements and other standards, such as meeting our financial obligations and to carry out our responsibilities and enforce our rights arising from service agreements entered into between you and us. We store your samples for a period of 6-8 weeks or according to contractual and legal requirements if longer. All accompanying data and records associated with these tests are maintained for a minimum period of one year and will be destroyed at intervals annually thereafter.

  1. Links to Other Websites
    Our Website may contain links to other websites that are not under our direct control. These websites may have their own policies regarding privacy. We have no control of or responsibility for linked websites and provide these links solely for the convenience and information of our visitors. You access such linked Websites at your own risk. These websites are not subject to this Privacy Policy. You should check the privacy policies, if any, of those individual websites to see how the operators of those third-party websites will utilize your personal information. In addition, these websites may contain a link to Websites of our affiliates. The websites of our affiliates are not subject to this Privacy Policy, and you should check their individual privacy policies to see how the operators of such websites will utilize your personal information.
  1. Security
    The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. We utilize practical protection measures to safeguard against the loss, abuse, and modification of the individual Data under our control. Personal Data is kept in a secured database and always sent out by means of an encrypted SSL method when supported by your web browser. No Web or email transmission is ever totally protected or mistake cost-free. For example, email sent out to or from the Website may not be protected. You must take unique care in deciding what info you send to us by means of email.
  1. Privacy Policy Updates
    We reserve the right to modify this Privacy Policy at any time. You should review this Privacy Policy frequently. If we make material changes to this policy, we may notify you on our Website, by a blog post, by email, or by any method we determine. The method we chose is at our sole discretion. We will also change the “Last Updated” date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies.
  1. Questions About Our Privacy Practices or This Privacy Policy
    We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained. If you have any questions about our Privacy Practices or this Policy, please contact us.