Privacy Policy
1. Introduction
ADNTRO GENETICS SL (hereinafter ADNTRO) is the owner of the website http://n-gene.ai/ (hereinafter, the "Site") as well as the platform https://app.n-gene.ai/ (hereinafter the "Platform") and acts as the controller of the personal data of the users ("Users") who access, browse, and use both the Site and the Platform.
Through this Privacy Policy, and in compliance with Regulation (EU) 2016/679 ("GDPR") and Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights ("LOPDGDD"), ADNTRO informs Users who use the Site and the Platform of the processing of their personal data that may be carried out by ADNTRO, in order for Users to decide, freely and voluntarily, whether they wish to provide the requested information.
The User declares to have been informed of the conditions regarding the protection of personal data, accepting and understanding the content of this Privacy Policy. Otherwise, please do not accept the Privacy Policy and do not use the Site and/or the Platform.
2. Identity of the person in charge of the processing of personal data
The data controller is ADNTRO with registered office at Colonia de Sant Pere, Finca Es pinaret, C.P. 07579, Artà (ILLES BALEARS), Spain, with N.I.F B01663657 and email address legal@adntro.com.
3. Data collected, purposes, legal basis and retention period
Through the following table, we inform you which data is collected about the User by ADNTRO, as well as the legal basis for processing such data, the purpose of its processing, and the retention periods.
Data collected on the Site
| Data collected | Legal basis | Purpose | Retention period |
|---|---|---|---|
| Site Browsing Data: IP and other browsing characteristics of Users (e.g. location and/or device) derived from the use of cookies or similar technologies used on the Site. Users can find more information in our Cookie Policy. | Consent given through the cookie banner at the start of browsing. Users can withdraw their consent by following the steps indicated in the Cookie Policy. Legitimate Interest Those cookies categorized as technical are necessary for the operation of the Site. | Browsing behavior analysis and statistics: The information collected through cookies and other similar tracking technologies that allow for an analysis of Users' browsing. | Retention periods depend on each specific cookie. For more information on the retention periods of information for each type of cookie, consult the Cookie Policy. |
| User Contact on the Site Contact details: User's name and email. Content of the message | Legitimate interest to address any questions and/or incidents and provide suitable service to the User. | User support: (Email sending / ChatBot / Contact Form.) Providing support to the User in case of any query, question, and/or incident related to the provision of service to the User. | For the time necessary to answer the question and/or resolve the incident indicated by the User. |
| Newsletter Contact details: Email address. Subject to the User's consent, the order history may be processed to send personalized offers for the User's favorite products | Consent | Carry out marketing communications and inform the User about events, reports, and other services available on the Site. | This data will be used as long as the User remains subscribed to commercial communications. If the User chooses to unsubscribe, all personal data collected for this function will be deleted, without prejudice to a 5-year blocking period to address potential liabilities. |
Data collected on the platform
| Data collected | Legal basis | Purpose | Storage period |
|---|---|---|---|
| Navigation Data on the Platform: Users' IP and other browsing characteristics (e.g. location and/or device) derived from the use of cookies or similar technologies used on the Platform. Users can find more information in our Cookie Policy. | Consent given through the cookie banner when starting browsing. Users can withdraw their consent by following the steps indicated in the Cookie Policy. Legitimate InterestThose cookies categorized as technical will be necessary for the operation of the Site. | Analysis of browsing behavior and statistics: The information collected through cookies and other similar tracking technologies that allow for an analysis of the Users' browsing behavior. | The storage periods depend on each specific cookie. For more information on the storage periods of the information for each type of cookie, consult the Cookie Policy. |
| Identifying and Contact Data. Email Phone delivery and billing address, Tax ID. | Execution of the contractual relationship. | Process the purchase and delivery of the Kit (Adntro Pack / Premium Adntro) made by the User. | During the validity of the contractual relationship and during the 5 subsequent years to process any incidents or legal responsibilities that may arise from the contract. |
| Identifying data, Contact data, Personal characteristics data Email address. User's name. User profile (Gender, year of birth, weight, height, Blood type.) | Execution of the contractual relationship. | Activate the DNA Kit / Registered User's High. Manage the User account. Provide services. Make transactional and service-related communications. | During the provision of the Service and for 5 subsequent years to process any incidents or legal responsibilities that may arise from the provision of the Service. |
| Contact Data User's name and email Message content | Legitimate interest to resolve any questions and/or incidents and provide a suitable service to the User. | User Contact on the Platform. Email, ChatBot, Contact Form
Support the User in case there are any questions, inquiries and/or incidents related to the provision of the service to the User. | For the time necessary to respond to the question and/or resolve the incident indicated by the User. |
| Contact Data Email. | Consent | Newsletter
Carry out marketing communications and inform the User about events, reports and other services available on the Site | This data will be used while the User remains subscribed to commercial communications. If the User opts to unsubscribe, all personal data collected for this function will be deleted, without prejudice to being blocked for 5 years to deal with possible liabilities. |
The data collected indicated above may be used by ADNTRO for the compatible purposes recognized by the GDPR in Article 89, for the purpose of carrying out reports and statistical studies in order to increase the knowledge about products demanded by the Users, as well as to improve the quality of the services of the Site and the Platform. For this purpose, pseudonymization systems are applied, guaranteeing the confidentiality and security of the personal data of the Users.
4. Data communication to third parties and international transfers
ADNTRO will process personal data with strict confidentiality in accordance with applicable law. However, we will disclose any personal data or other type of information that you provide to us in compliance with a legal obligation or to properly fulfill other obligations in accordance with applicable regulations. ADNTRO will ensure that your identity is kept strictly confidential and not disclosed to a third party, without prejudice to what is established and agreed in this document.
Notwithstanding the foregoing, ADNTRO uses third-party technological service providers (hosting, payment gateway, CRM, and others) to ensure the operation of the Site and the Platform as well as the provision of services, which may process the personal data provided through the agreements signed with forms implemented on them, as data processors and, furthermore, may process data within the European Economic Area (“EEA”) and some may carry out international transfers outside thereof:
Technological service providers involved in the operation and hosting of the Site, as well as providers of electronic communications services contracted by ADNTRO to enable the sending of transactional communications and, where applicable and subject to the User's consent, commercial communications to the User. In particular, ADNTRO has contracted among them the following technological service providers:
Hetzner Online GmbH (“Hetzner”): we use hosting and accommodation services hosting and storage of the information and the personal data collected and generated through the use of the Site on Hetzner's servers, which will involve both the possibility of accessing them in case of technical emergency, as well as the collection, preservation and interconnection of the data hosted on its servers located in the European Union, in accordance with its particular conditions of hosting services. For more information, you can also visit their Privacy Policy at: https://www.hetzner.com/legal/privacy-policy
Google Ireland Limited, (“Google”) as
provider of hosting, accommodation and storage of the information and the personal data.
provider of services of the Google Analytics tool that allow understanding how Users of the Site and Platform interact with its content, analyze performance.
Provider of email services for communication with users.
You can consult complete information about how Google Ireland Limited processes the personal data of Users through its Google services here.
ADNTRO has formalized with Google the corresponding data processing agreement (“DPA”). You can verify it at the following link https://cloud.google.com/terms/data-processing-terms/partner as well as its privacy policy at https://cloud.google.com/terms/cloud-privacy-notice.
Payment service providers: ADNTRO has on the Platform services from payment service providers, which comply with the security measures established by the payment services regulations and have the Level 1 certification according to the Data Security Standard for the Payment Card Industry or PCI DSS: when the User enters their payment details on the Platform (cardholder name, card number, expiration date, CVV), these will be stored directly on the servers of the payment gateway provider without ADNTRO having access to or storing the User's bank card details on its servers, but the payment gateways will process them in accordance with their Privacy Policy available below. ADNTRO will receive a confirmation order once the funds transfer has been successfully completed and will issue an invoice to the User for the contracted services.
Stripe: When making payments through Stripe, the User acknowledges and accepts that the processing of their personal data linked to the payment transaction for the benefit of ADNTRO will be carried out by Stripe in accordance with its privacy statement: https://stripe.com/es/privacy. ADNTRO has taken the legal precautions established by the applicable law, signing the standard clauses for the safeguarding of the rights and freedoms of data subjects.
Paypal: When making payments through Paypal, the User acknowledges and accepts that the processing of their personal data linked to the payment transaction for the benefit of ADNTRO will be carried out by Paypal in accordance with its privacy statement:
https://www.paypal.com/es/webapps/mpp/ua/privacy-full
ADNTRO has taken the legal precautions established by the applicable law, signing the standard clauses for the safeguarding of the rights and freedoms of data subjects available at https://www.paypal.com/us/webapps/mpp/ua/data-protection
Transport service providers. ADNTRO hires third-party services for the transportation of DNA kits. ADNTRO will provide the transportation company with the buyer's identifying information, delivery address and contact details to coordinate such delivery between the User and the corresponding transportation company.
Service providers for the sending of transactional emails and/or commercial communications by email.