Privacy Policy

1. Privacy at a Glance

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. You can find their contact details in the section "Information on the Responsible Party" in this privacy policy.

How do we collect your data?

Your data is collected in part by you providing it to us. This can be, for example, data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior. If contracts are concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other service requests.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time regarding this and other questions on the subject of data protection.

Analysis Tools and Third-Party Tools

When you visit this website, your surfing behavior can be statistically evaluated. This is mainly done with so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting and Content Delivery Networks (CDN)

We host the contents of our website with the following provider:

Amazon Web Services (AWS) - AWS Europe (EC2, S3, Data only in Region (eu-central-1 and eu-north-1))

The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter AWS).

When you visit our website, your personal data is processed on AWS servers (DNA ME EC2 instances) and only in regions eu-central-1 and eu-north-1. Personal data may also be transmitted to AWS's parent company in the USA. The data transfer to the USA is based on the EU standard contractual clauses. Details can be found here: <a href="https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/" target="_blank" rel="noopener noreferrer">https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/</a>.

Further information can be found in AWS's privacy policy: <a href="https://aws.amazon.com/de/privacy/?nc1=f_pr" target="_blank" rel="noopener noreferrer">https://aws.amazon.com/de/privacy/?nc1=f_pr</a>.

The use of AWS is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in the most reliable presentation of our website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user's end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: <a href="https://www.dataprivacyframework.gov/participant/5776" target="_blank" rel="noopener noreferrer">https://www.dataprivacyframework.gov/participant/5776</a>. The Framework matters here only for any residual access from the United States, for example during support; the regions used are named above.

Amazon CloudFront CDN

We use the Amazon CloudFront CDN content delivery network. The provider is Amazon Web Services EMEA SARL, 38 avenue John F. Kennedy, L-1855, Luxembourg (hereinafter "Amazon").

Amazon CloudFront CDN is a globally distributed content delivery network. Technically, the information transfer between your browser and our website is routed through the content delivery network. This enables us to increase the global availability and performance of our website.

The use of Amazon CloudFront CDN is based on our legitimate interest in the most error-free and secure provision of our website (Art. 6 para. 1 lit. f GDPR).

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: <a href="https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/" target="_blank" rel="noopener noreferrer">https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/</a>.

Further information on Amazon CloudFront CDN can be found here: <a href="https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf" target="_blank" rel="noopener noreferrer">https://d1.awsstatic.com/legal/privacypolicy/AWS_Privacy_Notice__German_Translation.pdf</a>.

3. General Information and Mandatory Information

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

Information on the Responsible Party

The responsible party for data processing on this website is:

DNA ME UG (limited liability) Pestalozzistr. 25 22305 Hamburg Represented by: Evgenii Varlygin

Phone: +49-40-333 777 67 E-Mail: hello@dna-me.net

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).

Storage Duration

Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. tax or commercial retention periods); in the latter case, deletion will take place after these reasons no longer apply.

General Information on the Legal Basis for Data Processing on This Website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, if special categories of data are processed according to Art. 9 para. 1 GDPR. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or to the access to information on your end device (e.g. via device fingerprinting), data processing is also carried out on the basis of § 25 para. 1 TTDSG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if it is necessary for the fulfillment of a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest according to Art. 6 para. 1 lit. f GDPR. The relevant legal basis in each individual case is informed about in the following paragraphs of this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work together with various external parties. In some cases, this also requires the transmission of personal data to these external parties. We only pass on personal data to external parties if this is necessary for the fulfillment of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in passing on data according to Art. 6 para. 1 lit. f GDPR, or if another legal basis permits the data transfer. When using processors, we only pass on personal data of our customers on the basis of a valid contract for order processing. In the case of joint processing, a contract for joint processing is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Advertising (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION ACCORDING TO ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE of DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION ACCORDING TO ART. 21 PARA. 2 GDPR).

Right to File a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible party, this will only be done insofar as it is technically feasible.

Information, Correction, and Deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time regarding this and other questions on the subject of personal data.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time regarding this. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21 para. 1 GDPR, a balance must be struck between your and our interests. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may - apart from its storage - only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a member state.

SSL or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

4. Data Collection on This Website

Cookies and local storage

This website does not use cookies.

To remember the display language you select, we store a single entry in your browser’s local storage. That entry contains only the language code – de, en or es – and no personal data. It is transmitted neither to our servers nor to any third party.

This storage is technically necessary in order to show you the website in the language you chose. The legal basis is § 25 (2) no. 2 TDDDG; no consent is required for it.

You can clear local storage at any time through your browser settings.

Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions - in particular retention periods - remain unaffected.

Where your enquiry is stored

The submission is sent to our own interface (api.dna-me.net). From there your enquiry is stored in our Journal Service, which runs on our own infrastructure at Amazon Web Services in the eu-central-1 region (Frankfurt am Main). We also send an internal notification email to our own mailbox.

No data is transmitted to any third-party CRM or marketing platform. Your form data does not leave the European Union.

Sending e-mail

Our e-mails — the notification about your enquiry, offers, upload credentials and results notifications — are sent through a mail provider whose registered office and servers are in Germany (manitu GmbH, St. Wendel). Your name, your e-mail address and the content of the message concerned are processed in doing so.

The legal basis is Art. 6(1)(b) GDPR where the message serves the performance of the contract or pre-contractual steps, and otherwise Art. 6(1)(f) GDPR. Transmission is encrypted, and no transfer to a third country takes place.

Origin documentation for genetic resources

Where an order concerns non-human biological material that is a genetic resource within the meaning of the Nagoya Protocol, we hold the access documentation for it: the prior informed consent and mutually agreed terms or the certificate of compliance, together with the declaration of the person who submitted them, the address that declaration was confirmed from, and the time it was made.

The legal basis is Art. 6(1)(f) GDPR: we have a legitimate interest in being able to evidence where source material came from and with whom the obligations under Regulation (EU) No 511/2014 rest. Where we are ourselves a user of a genetic resource, Article 4(6) of that Regulation applies in addition and the basis is then also Art. 6(1)(c) GDPR. The retention period is twenty years from provision of the results. For this record we are the controller, not a processor. An erasure request does not shorten it: Art. 17(3)(b) and (e) GDPR exclude it where the processing is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.

This documentation is stored separately from order data and covers neither raw signal data nor result files, which follow the periods in our terms of service. Your other rights are unaffected: you may ask what we hold and have inaccurate entries corrected.

Inquiry by E-Mail, Telephone, or Telefax

If you contact us by e-mail, telephone or telefax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent.

The data you send to us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory legal provisions - in particular statutory retention periods - remain unaffected.

cituro

We use the cituro service for booking appointments online. The provider is cituro GmbH, Peter-Dörfler-Straße 30, 86199 Augsburg, Germany (hereinafter cituro).

cituro is not embedded in this website. Our site contains only a link that takes you to the booking page operated by cituro. Loading our website establishes no connection to cituro and transmits no data to cituro. Processing by cituro begins only once you click the link and open the booking page.

If you book an appointment there, we process the details you provide through cituro – such as your name, contact details and preferred appointment – in order to arrange and hold the appointment. The legal basis is Art. 6 (1) (b) GDPR where the booking serves to initiate or perform a contract, and otherwise Art. 6 (1) (f) GDPR based on our legitimate interest in efficient appointment management.

Order Processing

We have concluded a data processing agreement (Auftragsverarbeitungsvertrag) with cituro. This is a contract required by data protection law, ensuring that cituro processes our users’ personal data only on our instructions and in compliance with the GDPR.

5. Social Media

This website contains a plain hyperlink to our LinkedIn company profile. No LinkedIn plug-ins, buttons or other embedded elements are used.

Loading this website therefore establishes no connection to LinkedIn’s servers and transmits no data to LinkedIn. Data is transferred only once you click the link and thereby open LinkedIn’s own website.

LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland is the controller for data processing on the LinkedIn website. Please refer to LinkedIn’s privacy policy at <a href="https://www.linkedin.com/legal/privacy-policy" target="_blank" rel="noopener noreferrer">https://www.linkedin.com/legal/privacy-policy</a> for details.

6. Analysis Tools and Advertising

No analytics tools, no tracking

This website uses no analytics, tracking, profiling or advertising technologies. In particular, none of the following are embedded:

Web analytics services (such as Google Analytics or Matomo)
Tracking pixels, conversion tags and retargeting tags
Advertising networks and ad-serving services
Social media plug-ins, like or share buttons
Heatmap, session-recording and A/B testing tools
External font, map or video services

No cookies are set for analytics or advertising purposes. There is no device fingerprinting, no cross-device recognition and no profiling. Your behaviour on this website is neither recorded nor analysed.

No third-party connections when you open a page

Every resource on this website – fonts, images, stylesheets and scripts – is served exclusively from our own infrastructure. Opening a page of this website therefore establishes no connection to any third-party server. This also rules out indirect inferences by third parties about your visit, such as those drawn from your IP address when external fonts or scripts are fetched.

Our principle

We reject third-party tracking as a matter of principle. In particular, we reject technologies from providers that misuse their market power by using embedded services to gather competitive intelligence.

This is distinct from the hosting provider named in section 2: that provider processes data solely on our instructions under a data processing agreement, in the eu-central-1 region (Frankfurt am Main), and receives no cross-site behavioural data from which competitive intelligence could be derived.

As a company working in genome and epigenome sequencing, we handle data that deserves particular protection. We consider it incompatible with that responsibility to give third parties any view into the behaviour of our visitors through our website.

7. Newsletter

Newsletter Data

If you would like to receive the newsletter offered on the website, we need an e-mail address from you as well as information that allows us to verify that you are the owner of the specified e-mail address and agree to receive the newsletter. Further data is not collected or is only collected on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form is carried out exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). The consent given for the storage of the data, the e-mail address and their use for sending the newsletter can be revoked at any time, for example via the "Unsubscribe" link in the newsletter. The legality of the data processing operations that have already taken place remains unaffected by the revocation.

The data you have stored with us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose no longer applies. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.

Data that has been stored by us for other purposes remains unaffected by this.

After you have been removed from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

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