Privacy Policy

Scope

This Privacy Policy applies to the processing of personal information by FYNDNA of:

• Visitors and users of the various FYNDNA sites, including our websites on FYNDNA.com, computer or mobile software applications and our social media pages that link to this Privacy Policy (collectively referred to as the sites);
• Attendees of FYNDNA events, or FYNDNA-sponsored events;
• Customers and prospective customers and their representatives;
• Subscribers to FYNDNA publications and newsletters;
• Visitors to FYNDNA facilities; and
• Suppliers and business partners and their representatives.

The legal basis for processing this personal information is (i) our legitimate interests, namely performing our services, or monitoring and improving our Sites and services, or (ii) necessity for performance of a contract between you, your company or our customer, and us.

The Privacy Policy does not apply to the following activities:

• Personal information collected about you by FYNDNA customers. FYNDNA customers are responsible for their own personal information collection and processing practices, including when customers use FYNDNA products or services to process your personal information. To find out more about our customers’ use of personal information about you, you are encouraged to review the relevant privacy policy of the company who collected your information from you. Please consult that company directly if you have any further questions about its use of information about you.
• Personal information you provide on third party sites not controlled by FYNDNA. When interacting with our websites, you also have the ability to link or connect with non-FYNDNA websites, services, social networks, applications or other features. Enabling these features will lead to other parties than FYNDNA processing information about you. FYNDNA does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.

Categories and specific pieces of personal information processed

• FYNDNA can process information about you collected directly from you both offline and online, including when you create an FYNDNA account to access FYNDNA products and services or attend an FYNDNA-sponsored event. Information about you may also be provided to FYNDNA by selected third party sources, such as data aggregators who may not have a direct relationship with you or by third parties who collect information about you on behalf of FYNDNA such as when you download an FYNDNA whitepaper.
• Specific pieces of information about you that FYNDNA may collect and process depending on your interaction with FYNDNA, includes name and physical address, email addresses, and telephone numbers.
• Certain online information about you or device information may originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties. For more information on cookies and similar technologies, please see the section on what cookies and similar technologies we use.

Please note that FYNDNA does not control the content that you may post to Communities forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

Purposes for which we process personal data

We collect and process Personal Data for a variety of purposes, including:

• to provide and promote our websites and services;
• to provide you with information about our products;
• to manage your registration for and attendance at events as well as office visits;
• to manage your registration for contests or promotions;
• to communicate with you;
• to maintain the security of the services;
• to improve performance of the services;
• to review compliance with applicable usage terms (including capacity requirements);
• to identify future opportunities for development of the services;
• to complete transactions with you when you purchase our products or services;
• to administer surveys and conduct research;
• to display personalized advertisements to you and to send to you marketing communications about us, our products and our services; and
• to comply with our legal obligations under applicable laws and to cooperate with public and government authorities as required.

We only collect and process your Personal Data to the extent it is necessary for fulfilling these purposes and where we can rely on a legal basis as defined in the Scope section of this policy. Where required, we will ask you for your prior consent to processing.

Collecting information from third parties

In some instances, we may collect information about you that’s publicly available, such as data from telephone directories or other websites.

There may be occasions when we gather personal information about you from a third party, including:

• Organisations we have an arrangement with, to jointly offer products.
• Organisations we exchange information with, so we can either promote or provide products and services.
• Marketing companies, who may provide us with contact information to help us promote our products and services.
• Brokers and other parties, who may have introduced you to FYNDNA.

Data from our sites and apps

To help us better tailor our service to you, we may also collect information about how you use FYNDNA.com, other websites and our apps. For example, when you click on a link from an FYNDNA website or visit a website that displays an FYNDNA ad.

Usually, the information we collect in this way does not identify you. It’s data about the number of visitors to a site, or statistics about how a site is browsed.

If we do identify you with this information (for example, if you’ve logged on to an online FYNDNA service), any use or disclosure of that information will be in accordance with this Privacy Policy.

Collecting sensitive information

FYNDNA does not collect sensitive personal information.

What cookies and similar technologies do we use?

Cookies and similar technologies (e.g., pixel tags and device identifiers) are used by FYNDNA and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in the section on the purposes for which we process personal data.

When do we use cookies and similar technologies?

Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. We place cookies in your browser when you visit FYNDNA sites and non-FYNDNA sites that may host our software. Depending on your jurisdiction, you may be presented with different consent options, including the option to reject all non-essential cookies, prior to FYNDNA placing cookies on your browser. Visitors from all jurisdictions are provided with functionality to opt out of non-required cookies using the cookie preferences tool.

We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services. FYNDNA also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioural data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded).

How can I manage my cookie preferences?

If you are a visitor to our websites, you can use our cookie preferences tool to opt out of cookies that are not required to enable core site functionality, such as advertising and functional cookies. If you are a visitor to our websites which host our software, the respective website may offer you appropriate mechanisms to disable cookies.

If you do not want to receive cookies, you can also change your browser settings on your computer or other device you are using to access our services. Most browsers also provide functionality that lets you review and delete cookies, including FYNDNA cookies.

Using your personal information

FYNDNA uses your personal information to monitor the performance and improve the quality of its products, respond to requests about the Company and its business, provide information about products and services, fulfil customer requests, and for other business purposes and/or to comply with various legal and regulatory obligations. With your consent, FYNDNA may also use your personal information to send you information about its other products and services and for other specified marketing purposes. Unless we obtain your consent to processing of your personal information, FYNDNA processes your personal information either for performance of a contract with you, our customers or in circumstances where it has a legitimate interest to do so.

FYNDNA may use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (a) customizing user visits to the Sites, (b) delivering content tailored to users’ interests and the manner in which our users browse the Sites, and (c) managing the Sites and other aspects of its business, (d) improving the performance of our products and services.

You can change your cookies settings in your browser, however please note that without cookies you may not be able to use all of the features of the Sites.

Your rights relating to your personal data

You have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws, these rights may include the right to:

• Access your Personal Data held by us;
• Know more about how we process your Personal Data;
• Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
• Erase or delete your Personal Data;
• Restrict our processing of your Personal Data;
• Transfer your Personal Data to another controller, to the extent possible;
• Object to any processing of your Personal Data;
• Opt out of certain disclosures of your Personal Data to third parties;
• Not be discriminated against for exercising your rights described above;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
• Withdraw your consent at any time (to the extent we base processing on consent).

For more details and how you can exercise your rights, you can send an email to privacy@fyndna.com

Sharing and international transfer of personal data

Sharing within FYNDNA

FYNDNA employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions. We have technical and organizational measures in place to implement need-based access to personal information.

Sharing with third parties

We may share personal information with the following third parties for a business purpose:

• Third-party service providers (for example, payment gateways, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of FYNDNA;
• Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
• As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

We may share personal information with the following third parties for a commercial purpose:

• Marketers, distributors or resellers for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising; and
• Event partners or conference sponsors for FYNDNA events such as when you scan your badge at a sponsored booth.

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

We may share your customer information in response to a lawful request issued by a court, a government agency or a regulatory authority, or as permitted by law.

Transfer to other countries

Your Personal Data may be collected, transferred to and stored by us and by our affiliates and third parties (as disclosed in the full Privacy Statement) in countries other than where FYNDNA operates from. Therefore, your Personal Data may be processed outside your jurisdiction, including in countries and jurisdictions that may not provide the same level of protection. We have implemented safeguards to ensure an adequate level of data protection where your Personal Data is transferred outside of your country or jurisdiction.

FYNDNA will require that all third parties acting on behalf of FYNDNA, and to which personal information is provided, give FYNDNA adequate contractual assurances that they will safeguard all such personal information in a manner consistent with this policy.

Retention of personal data

We may retain your Personal Data for as long as required to provide you with services such as managing your account and dealing with any concerns that may arise or otherwise if required for any legal or regulatory requirements or for establishment, exercise or defence of legal claims.

We may need to retain your information for a longer period where we need the information for our legitimate purposes, for example to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators. If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.

Managing your personal information

Protecting your personal information

We have measures in place to protect your personal information from:

• Misuse and loss
• Unauthorised access
• Unauthorised modification
• Unauthorised disclosure

And here’s how we safeguard your data:

• Implementing physical security, such as locks and security systems over our paper and electronic data stores and premises.
• Maintaining computer and network security, including firewalls, identification codes and passwords to control access.
• Maintaining and monitoring our online security systems around the clock, all year round, by our security operations team.

As a FYNDNA customer, we let you select your preferred channel of communication for marketing updates sent to you on a periodic basis. Your choices include the following:

• Receive marketing communications through any channel (post, email, SMS, telephone)
• Receive marketing communications through SMS and email only
• Receive marketing communications through SMS only
• Receive marketing communications through email only
• Opt out of marketing communications

Requesting correction of your information

If you believe your personal information is inaccurate, incomplete or out-of-date, call 022 66117999 or email privacy@fyndna.com, and we’ll update it promptly.

If you’d like us to correct information we’ve received or disclosed through the credit reporting system, we’ll consult with the relevant organisations directly.

If we don’t agree that your information needs to be corrected, we’ll tell you why, and what you can do if you’re unsatisfied with our response.

Contact information

Questions or comments about this policy, or concerns or complaints about possible violations, should be sent to privacy@fyndna.com or to: