Welcome to the privacy policy of yourDNA.family. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Registration and authentication provided directly by yourDNA.family
Interaction with support and feedback platforms
Traffic optimization and distribution
Selling goods and services online
Data transfer outside of the UK
Owner and Data Controller
Numero Pte. Ltd.
68 CIRCULAR ROAD
#02-01
049422 Singapore
Singapore
Owner contact email: info@yourDNA.family
Type of Data we collect
Among the types of Personal Data that yourDNA.family collects, by itself or through third parties, there are:
Cookies
Usage Data
email address
first name
last name
username
various types of Data
User ID
country
number of Users
session statistics
IP address
device information
browser information
operating systems
city
ZIP/Postal code
state
county
latitude (of city)
longitude (of city)
metro area
geography/region
payment info
user subscriptions
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using yourDNA.family. Unless specified otherwise, all Data requested by yourDNA.family is mandatory and failure to provide this Data may make it impossible for yourDNA.family to provide its services. In cases where yourDNA.family specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by yourDNA.family or by the owners of third-party services used by yourDNA.family serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through yourDNA.family.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of yourDNA.family (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics
Contacting the User
Content commenting
Data transfer outside the EU
Displaying content from external platforms
Handling payments
Hosting and backend infrastructure
Infrastructure monitoring
Managing contacts and sending messages
Registration and authentication provided directly by yourDNA.family
Managing support and contact requests
Interaction with support and feedback platforms
Traffic optimization and distribution
Selling goods and services online
Data transfer outside of the UK
Tag management
Platform services and hosting
User database management
Detailed information on the processing of Personal Data
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Analytics collected directly
Company: yourDNA.family
Personal Data processed: Cookies +1
YourDNA.family uses an internal analytics system that does not involve third parties.
Personal Data processed:
Cookies
Usage Data
Service provided by:
yourDNA.family
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Google Analytics 4
Company: Google LLC
Place of processing: United States
Personal Data processed: number of Users +3
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of yourDNA.family, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Contacting the User
Mailing list or newsletter
Company: yourDNA.family
Personal Data processed: email address +3
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning yourDNA.family. Your email address might also be added to this list as a result of signing up to yourDNA.family or after making a purchase.
Personal Data processed:
email address
first name
last name
Usage Data
Service provided by:
yourDNA.family
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Content commenting
Content commenting services allow Users to make and publish their comments on the contents of yourDNA.family.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly
Company: yourDNA.family
Personal Data processed: Cookies +5
YourDNA.family has its own internal content comment system.
Personal Data processed:
Cookies
email address
first name
last name
Usage Data
username
Service provided by:
yourDNA.family
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of yourDNA.family and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
OpenStreetMap widget
Company: OpenStreetMap Foundation
Place of processing: United Kingdom
Personal Data processed: Cookies +1
OpenStreetMap widget is a maps visualization service provided by OpenStreetMap Foundation that allows yourDNA.family to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Font Awesome
Company: Fonticons, Inc.
Place of processing: United States
Personal Data processed: Trackers +1
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows yourDNA.family to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
YouTube video widget
Company: Google LLC +1
Place of processing: United States +1
Personal Data processed: Cookies +1
YouTube is a video content visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows yourDNA.family to incorporate content of this kind on its pages.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Handling payments
Unless otherwise specified, yourDNA.family processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. YourDNA.family isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
PayPal
Company: PayPal Inc.
Place of processing: See the PayPal privacy policy
Personal Data processed: various types of Data as specified in the privacy policy of the service
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable yourDNA.family to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of yourDNA.family.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS)
Company: Amazon Web Services, Inc.
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Oracle Cloud Infrastructure
Cloud infrastructure platform provided by Oracle Corporation, used to host the application, store data, and operate the database backend. Personal Data processed: various types of Data as specified in the privacy policy of the service. Place of processing: see the Oracle Privacy Policy.
Infrastructure monitoring
This type of service allows yourDNA.family to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of yourDNA.family.
Datadog
Company: Datadog, Inc.
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Datadog is a monitoring service provided by Datadog, Inc.
The way Datadog is integrated means that it filters all traffic of yourDNA.family, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on yourDNA.family to be collected.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of yourDNA.family.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Zendesk Widget
Company: Zendesk, Inc.
Place of processing: United States
Personal Data processed: country +6
The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp
Company: Intuit Inc.
Place of processing: United States
Personal Data processed: Cookies +5
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Category of Personal Information collected according to the CCPA
identifiers
Managing support and contact requests
This type of service allows yourDNA.family to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk
Company: Zendesk, Inc.
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Platform services and hosting
These services have the purpose of hosting and running key components of yourDNA.family, therefore allowing the provision of yourDNA.family from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
DNA data processing and matching
Company: yourDNA.family
Core service of yourDNA.family. Users may upload raw genetic data files (DNA test results) to identify genetic matches with other Users, calculate relationship predictions, map shared chromosome segments (autosomal and X-chromosome), and support the identification of most recent common ancestors.
Categories of Personal Data processed: raw genetic data files, derived genetic markers, computed match results, shared segment data, relationship predictions, and chromosome map data.
Genetic data is treated as a special category of Personal Data under Article 9 GDPR and as Sensitive Personal Information under applicable US state privacy laws (including California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Tennessee, and Montana).
Legal basis (EU/UK): Explicit consent under Article 9(2)(a) GDPR, obtained at the point of upload via a dedicated consent flow.
Legal basis (Singapore PDPA): Consent of the individual with purpose limitation to the matching and analysis service described.
Legal basis (US state laws): Explicit opt-in consent for processing of Sensitive Personal Information.
Place of processing: Initial upload is staged on cloud infrastructure (see Amazon S3 entry). Long-term storage and analytical processing take place on infrastructure operated directly by the Owner in Singapore.
Retention: Raw genetic data files are removed from temporary cloud staging within 24 hours of successful transfer. Files retained on Owner-operated infrastructure are kept for the duration of the User's active account, plus any period required by applicable law. Users may request deletion of their raw genetic data files at any time by contacting info@yourDNA.family; such requests will be actioned within one month.
Security measures: Encryption in transit and at rest, access controls, infrastructure monitoring, and least-privilege administration. Raw genetic data is never used for purposes other than those described in this clause.
Disclosure restrictions: Raw genetic data is not sold, shared for cross-context behavioral advertising, used for targeted advertising, or disclosed to any third party except as strictly necessary to provide the service (temporary infrastructure providers acting as processors under contract). The Owner does not provide genetic data to law enforcement, insurers, employers, or other parties except where compelled by valid legal process.
TG-scoped Discussion Forums
Company: yourDNA.family
The Service provides discussion forums that are scoped to specific triangulated DNA groups. Posts and replies in a discussion forum are visible only to Users who are members of the specific TG to which the forum is attached. Discussion content is not accessible to: (a) Users who are not in the relevant TG; (b) Users who share a different TG with the posting User but not this specific TG; (c) the public. Categories of Personal Data processed: post content (text, written by Users), timestamps, the identity of the posting User as displayed within the TG, and reaction or engagement metadata. Users are responsible for the content of their own posts and should exercise care not to disclose personal data about Third-Party Data Subjects (such as living relatives) beyond what is reasonably necessary for the genealogical discussion at hand. The Owner reserves the right to remove posts that breach this Section 6.5, the Terms & Conditions, or applicable law.
Registration and authentication provided directly by yourDNA.family
By registering or authenticating, Users allow yourDNA.family to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration
Company: yourDNA.family
Personal Data processed: email address +3
The User registers by filling out the registration form and providing the Personal Data directly to yourDNA.family.
Personal Data processed:
email address
first name
last name
User ID
Service provided by:
yourDNA.family
Category of Personal Information collected according to the CCPA
identifiers
Selling goods and services online
This type of service helps the Owner to sell goods, provide services or monetize online content. To this end, the services listed below may for instance allow the Owner to process payments, set up subscription models, track orders, and manage deliveries.
Chargebee
Company: Chargebee Inc.
Place of processing: United States
Personal Data processed: payment info +3
Chargebee is a subscription management tool provided by Chargebee Inc, which allows the Owner to manage subscriptions, invoicing, pricing models, and subscription and revenue analytics.
Category of Personal Information collected according to the CCPA
commercial information
internet or other electronic network activity information
Tag management
This type of service helps the Owner to manage the tags or scripts needed on yourDNA.family in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Trackers +1
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Traffic optimization and distribution
This type of service allows yourDNA.family to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between yourDNA.family and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Amazon CloudFront
Company: Amazon Web Services, Inc.
Place of processing: United States
Personal Data processed: browser information +13
Amazon CloudFront is a traffic optimization and distribution service provided by Amazon Web Services, Inc.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
geolocation data
Amazon Route 53
Company: Amazon Web Services, Inc.
Place of processing: United States
Personal Data processed: Usage Data
Amazon Route 53 is a managed domain name system (DNS) service provided by Amazon Web Services, Inc. Amazon Route 53 manages DNS infrastructure to deliver traffic quickly and securely.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to yourDNA.family, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving yourDNA.family.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on yourDNA.family.
Family tree data processing and GEDCOM imports
Company: yourDNA.family
yourDNA.family allows Users to upload and process genealogical data files (typically GEDCOM format) containing information about ancestors, living relatives, and other individuals connected to the User. This data is used to construct family trees, identify common ancestors with DNA matches, and produce genetic evidence statements.
Categories of Personal Data processed: names, birth/marriage/death dates and locations, family relationships, contact information where provided by the User, and other genealogical fields included in uploaded files.
Personal Data of third parties: Family tree data uploaded by Users routinely includes Personal Data of individuals who are not Users of yourDNA.family, including living individuals such as relatives of the User. The Owner relies on the User to have a lawful basis for processing such Personal Data under applicable law (such as the User's family relationship, the User's legitimate interest in genealogical research, or the consent of the individuals concerned) and to have informed those individuals where required by law. The Owner acts as a processor on behalf of the User in respect of family tree data.
Personal Data of minors: Family tree data may include information about living minors (children, grandchildren, nieces, nephews, and other descendants). Users are responsible for ensuring they have a lawful basis to include minors in their family tree data, including parental or guardian consent where required by applicable law. The Owner will give priority to requests from parents or guardians for the removal of a minor's data.
Right of removal for third parties: Living individuals (or, in the case of minors, their parents or legal guardians) whose data has been included in a family tree on yourDNA.family may request removal of their data, correction, or exclusion from future matching by contacting info@yourDNA.family. The Owner will action such requests within one month and will inform the User who uploaded the data of the request where appropriate.
Place of processing: Singapore.
Retention: Family tree data is retained for the duration of the User's active account. Users may delete individual entries or entire trees at any time.
DNA match data and genetic evidence statements
Company: yourDNA.family
As part of the matching service, yourDNA.family stores and processes data about matches between Users. Where Users are identified as genetic matches and a most recent common ancestor (MRCA) is identified, the resulting genetic evidence — including the path through the family tree from the MRCA down to each DNA-tested User — may be stored for use by other Users in their own genealogical research.
Categories of Personal Data processed: match identifiers, shared chromosome segment data, predicted relationship, identified common ancestors (including names and lifespan information), the User-identified path through family trees, and identifying information of matched individuals (typically usernames or display names — never raw genetic data).
Linkability and persistence: Genetic evidence statements link DNA-tested individuals to identified common ancestors. Other Users descending from the same common ancestor may reference these statements in their own research. To preserve the integrity of references made by other Users, this data may persist even if the family tree on which it was originally based is later modified.
Third-party Personal Data: Some match data necessarily relates to identifiable third parties (DNA-tested relatives, named ancestors). The disclosures in the "Family tree data processing and GEDCOM imports" clause apply equally to this data.
User rights: Users may request that their participation in any genetic evidence statement be removed by contacting info@yourDNA.family. Note that removal may affect references made by other Users to that statement; the Owner will action such requests in a manner that balances individual privacy rights with the integrity of the genealogical record.
Place of processing: Singapore.
Public CAP (Common Ancestor Points) scoreboard
Company: yourDNA.family
yourDNA.family publishes a public scoreboard of Users ranked by Common Ancestor Points (CAP), a score reflecting each User's contributions to identifying common ancestors within the platform. The scoreboard is accessible on a public web page and is not restricted to logged-in Users.
Personal Data made public: User display name (as chosen by the User), CAP score, and ranking position.
Purpose: Community recognition and incentivization of genealogical contribution.
Consent and opt-out: By accepting the Terms & Conditions at sign-up, the User consents to publication of their display name and CAP score on the public scoreboard. Users may set their display name to a pseudonym at any time. Users may opt out of public scoreboard inclusion by contacting info@yourDNA.family.
Place of processing: Singapore. The scoreboard is delivered globally via a content delivery network (see the Amazon CloudFront entry).
Public surnames index
Company: yourDNA.family
yourDNA.family publishes a public index of surnames present in Users' family tree data, accessible on a public web page. The surnames index supports the core matching purpose of the service by allowing visitors to discover Users with overlapping surnames in their family research.
Personal Data made public: surnames appearing in any User's family tree, and aggregate co-occurrence indicators. The public index does not by itself link a specific surname to a specific User, but specific surname combinations may be indirectly identifying.
Public vs. authenticated visibility: On public pages of yourDNA.family (accessible without login), names of living individuals appearing in genetic evidence statements are shown only as abbreviations (typically initials, e.g. "AW" rather than "Andreas West"). Full names are revealed only to logged-in Users who have themselves inherited the relevant ancestral DNA segment from the identified most recent common ancestor, demonstrating a genuine genealogical and biological connection. This triangulation-gated visibility is a deliberate privacy-by-design control intended to limit exposure of living individuals to those who have a genuine genetic claim to the shared ancestry.
Purpose: Genealogical discovery and matching.
Consent and opt-out: By accepting the Terms & Conditions at sign-up, Users consent to the indexing of surnames from their uploaded family tree data on the public surnames index. Users may exclude specific surnames or entire branches from the public index by contacting info@yourDNA.family.
Place of processing: Singapore. The index is delivered globally via a content delivery network.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
Personal Data collected through sources other than the User
The Owner of yourDNA.family may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by yourDNA.family depends on the payment system used.
Cookie Policy
YourDNA.family uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Other legal basis for Data transfer abroad
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
the data transferred is sourced from a public register created under the law of the country that the data originates from;
subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via yourDNA.family.
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via yourDNA.family.
Transfer of Personal Data outside of the United Kingdom
Data transfer abroad based on consent (UK)
If this is the condition for Data transfer, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via yourDNA.family.
Other legal basis for Data transfer abroad (UK)
If no other condition for Data transfer applies, Personal Data shall be transferred from the UK to third countries only if at least one of the following is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
the data transferred is sourced from a public register created under UK law;
subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the condition the transfer is based on via yourDNA.family.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in Brazil
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running yourDNA.family and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in the LGPD.
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures;
protection or physical safety of yourself or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.
To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.
Categories of personal information processed
To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision; and
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.
In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.
In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request — except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service;
when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running yourDNA.family and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Internet or other electronic network activity information
Personal Data processed: Cookies; Usage data; Email address; First name + 21
Personal Information collected or disclosed:
Cookies
Usage Data
email address
first name
last name
various types of Data
various types of Data as specified in the privacy policy of the service
Trackers
Tracker
country
number of Users
session statistics
IP address
device information
browser information
operating systems
city
ZIP/Postal code
state
county
latitude (of city)
longitude (of city)
metro area
geography/region
user subscriptions
Sensitive Personal Information collected or disclosed
username, payment info
Purposes:
Analytics
Contacting the User
Content commenting
Data transfer outside the EU
Displaying content from external platforms
Further information about Personal Data
Handling payments
Hosting and backend infrastructure
Infrastructure monitoring
Managing contacts and sending messages
Managing support and contact requests
Interaction with support and feedback platforms
Traffic optimization and distribution
Selling goods and services online
Tag management
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Third-parties:
OpenStreetMap Foundation , PayPal Inc., Fonticons, Inc. , Google LLC
Service providers or contractors:
yourDNA.family, Amazon Web Services, Inc., Datadog, Inc., Intuit Inc., Zendesk, Inc., Chargebee Inc., Google Ireland Limited
Identifiers
Personal Data processed: Email address; First name; Last name; Usage data + 18
Personal Information collected or disclosed:
email address
first name
last name
Usage Data
Cookies
User ID
Tracker
country
various types of Data as specified in the privacy policy of the service
IP address
device information
browser information
operating systems
city
ZIP/Postal code
state
county
latitude (of city)
longitude (of city)
metro area
geography/region
various types of Data
Sensitive Personal Information collected or disclosed
username
Purposes:
Contacting the User
Content commenting
Managing contacts and sending messages
Registration and authentication provided directly by yourDNA.family
Interaction with support and feedback platforms
Further information about Personal Data
Traffic optimization and distribution
Data transfer outside of the UK
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Service providers or contractors:
yourDNA.family, Intuit Inc., Zendesk, Inc., Amazon, Amazon Web Services, Inc.
Geolocation data
Personal Data processed: Usage data; Ip address; Device information; Browser information + 10
Personal Information collected or disclosed:
Usage Data
IP address
device information
browser information
operating systems
city
ZIP/Postal code
state
county
country
latitude (of city)
longitude (of city)
metro area
geography/region
Purposes:
Traffic optimization and distribution
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Service providers or contractors:
Amazon Web Services, Inc.
Commercial information
Personal Data processed: Trackers; Usage data; User subscriptions
Personal Information collected or disclosed:
Trackers
Usage Data
user subscriptions
Sensitive Personal Information collected or disclosed
To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use yourDNA.family.
For example, you directly provide your Personal Information when you submit requests via any forms on yourDNA.family. You also provide Personal Information indirectly when you navigate yourDNA.family, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of yourDNA.family and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
The right to question the results of the profiling;
The right to be informed of the reason that the profiling resulted in the decision; if feasible
The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
The right to review personal data used in the profiling;
If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on yourDNA.family.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of yourDNA.family or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, yourDNA.family may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, yourDNA.family and any third-party services may collect files that record interaction with yourDNA.family (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within yourDNA.family and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through yourDNA.family (or third-party services employed in yourDNA.family), which can include: the IP addresses or domain names of the computers utilized by the Users who use yourDNA.family, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using yourDNA.family who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of yourDNA.family. The Data Controller, unless otherwise specified, is the Owner of yourDNA.family.
yourDNA.family (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by yourDNA.family as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy has been prepared based on provisions of multiple legislations.
This policy relates solely to yourDNA.family, if not stated otherwise within this document.
