“Affiliated Company” refers to a company that is related to BEGENE due to joint ownership or control.

“Third Party” refers to a company or person who does not have a related relationship arising out of joint ownership or control with BEGENE (i.e., a non-affiliated company) or other non-related person, or the Customer who engage the Services from BEGENE (i.e., Clinician, Hospital, Health Professional, Healthcare Service Provider, University, Research Institution, Pharmaceutical Companies)

“Genetic Data” refers to personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result, in particular, from an analysis of a biological sample from the natural person in question

 “Personal Data” refers to any information relating to an identified or identifiable natural person (“Data Subject”), including Genetic Data. An identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Personal Data Breach” is a breach of security that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

The Personal Data can be collected by BEGENE directly from the Data Subject, or from a Third Party with the consent of the Data Subject or where permitted by law.

BEGENE is responsible for the processing and treatment of your Personal Data regarding the Services entrusted to BEGENE.

The Personal Data BEGENE processes include but is not limited to:

• full name, address and contact details
• date of birth
• gender
• weight
• height
• nationality
• sample material involving Genetic Data
• any clinical information necessary for the purpose of the services or tests required, such as medical history (including any condition for which medical advice or treatment was sought, any form of consultation, investigation, prescription or treatment), allergies, lifestyle habits, current medication
• family medical history
• other medical test results or findings necessary for conducting genetic testing or sequencing services 

Information You Directly Provide to Us

Certain Personal Data concerning you, including Genetic Data, are collected directly from you by BEGENE.

BEGENE might collect the Personal Data in the following circumstances:

• When you use this website (https://www.naleya-genomics.com/)
• When you use our genetic testing and sequencing services
• When you use our customer services
• When you cooperate with us

The information above may be necessary for the adequate performance of the contract or purchase order between you and BEGENE and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with relevant requested Services. 

Information We Collect from Third Parties

To enable us to provide better Services to you, where permitted by applicable laws, we may collect your Personal Data indirectly from a Third Party.

We will put efforts to ensure the legitimacy of the source of your Personal Data. However, please note that we do not control, supervise or respond to how the Third Party processes your Personal Data. Any request regarding the disclosure of your Personal Data to us should be directed to such Third Party.

We process your Personal Data so that we can:

• Perform our Services
• Improve our Services
• Keep you updated about our Services. 
• Contact you with other relevant Services we think you might be interested in.

The following tables provide processing purposes, type and legal basis for certain uses of your Personal Data.

When you use this website (https://www.begene.id/), BEGENE is the data controller:  

When you use our genetic testing and sequencing services, BEGENE is the data processor:

When you use our customer services, BEGENE is the data controller:

When you cooperate with us, BEGENE is the data controller: 

Genetic data, data concerning health, or other special categories of Personal Data under applicable laws and regulations will only be processed based on the explicit consent you provide to us.

BEGENE will retain the Personal Data for no longer than it is necessary for the purposes as long as needed to provide the Services requested from BEGENE or requested by applicable laws and regulations. Beyond the above retention period, we will delete or anonymize your Personal Data.

Within BEGENE, the Personal Data collected are only accessible to the members of BEGENE who, within the scope of their specific tasks, are responsible for it and whose access to these data is expressly required for the performance of their tasks.

After receiving your consent, BEGENE may also share the Personal Data collected with its affiliated companies, trusted third parties, suppliers and sub-contractors through which you have ordered one of our services and consented to receive your Personal Data, as well as the Insurance Company if their intervention is required.

We will never share or disclose your Personal Data without obtaining your consent unless when:

• It is directly relevant to public health or significant public interest;
• It is directly relevant to investigation, prosecution, trial and execution of judgment of crimes;
• It is for the purpose of protecting life, property or other significant legal rights and interests of Personal Data subjects or others, and it is difficult to obtain consents from such person;
• The Personal Data collected has been disclosed by the Personal Data Subject to the public actively; or
• It is otherwise provided by applicable laws and regulations.

Subject to applicable local legal requirements, your Personal Data may be transferred, stored and processed outside of the country where you live or have ordered our Services from, including to our subsidiaries, affiliated companies and service providers located in other jurisdictions, and may become subject to the laws of such jurisdictions. The primary location of where your Personal Data will be stored or processed for the Services you have ordered from BEGENE will be stated in the governing contract and/ or the test request form.

We only provide your Personal Data to our subsidiaries, affiliated companies and services providers where it is necessary to meet the purpose for which you have submitted your Personal Data and in particular if necessary, for the provision of services and support. We take steps to ensure that BEGENE companies follow our data protection policy, this privacy notice and applicable local law when handling Personal Data and that service providers put in place adequate safeguards to protect the Personal Data entrusted to them.

BEGENE uses a variety of security measures and technologies to help protect Personal Data from unauthorized access, use, disclosure, alteration or destruction with applicable data protection and privacy laws. The following measures are taken:

• We establish a department and appoint personnel to be responsible for protection of Personal Data, conducting self-evaluation on security of Personal Data, organization of training on relevant staff, etc.

• We take practical measures to ensure that the Personal Data is minimally collected and relevant to the purposes. Your Personal Data is retained for no longer than the necessary for the purposes as long as needed to provide the Services requested from BEGENE or requested by applicable laws and regulations.

• We use firewalls, encryption technologies to ensure the confidentiality and security of data transmission and storage, protect data and data storage servers from attacks.

• We utilize access control mechanisms to permit only authorized access to your Personal Data. The access to Personal Data will be logged and reviewed by authorized personnel at a regular interval. In addition, personnel who have the authorized access will be required to sign confidential agreement.

• We carefully select external suppliers/ subcontractors or services providers of Personal Data processing, and will put in place a written agreement which contain the requirements of Personal Data protection.

• We organize security and privacy protection training courses and publicity activities at a regular interval to raise employees’ awareness.

• In response to potential risks, such as Personal Data breaches, damage, and loss, we have developed contingency plans and conduct regular emergency drills.

• In case of Personal Data breach, we will without undue delay inform you about the basic conditions and possible influence of the data breach, response measures that are already taken or to be taken by us, suggestions for you regarding precautions and risk control, corrective measures for you, etc. To the extent permitted by law, we will inform you about relevant situations of the Personal Data Breach in a timely manner via email, fax, telephone or push notification, or any other means of communication we deem appropriate. When it is difficult to notify every Data Subject individually, we will properly and effectively issue a public announcement.

We respect your legal rights with regards to your Personal Data. Below are the rights you may exercise before us by sending an email to info@naleya-genomics.com . Please note that for the sake of security, we may ask you to verify your identity before further processing your request.

• To access the Personal Data BEGENE holds about you: You are entitled to access and request copies of Personal Data that you provided to us, unless applicable laws provide otherwise.
• To be informed about how BEGENE uses your Personal Data: We strive to be transparent about how we use your data. We keep you informed as to what we do with your Personal Data through this Privacy Policy.
• To have these data rectified promptly in case of inaccuracy/incompleteness: If you find that your Personal Data processed by us is inaccurate or incomplete, you are entitled to ask us to make rectifications.
• To have your Personal Data erased in specific circumstances: You can request us to delete your Personal Data. Depending on the circumstances, BEGENE will have to implement the right to data deletion.
• To restrict the processing of your Personal Data: You have the right to ask us to restrict how we process your Personal Data. If you restrict our processing, we will not further process but are still permitted to store the data.
• To object to the processing of your Personal Data: You have the right to object to our processing your data when the processing is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics.
• The right to data portability: To the extent permitted by laws and regulations, you have the right to request for the receipt of the transfer to another firm/organization in a structured, commonly used and machine-readable form of the Personal Data provided to BEGENE.
• To lodge a complaint to Data Protection Authority: You have the right to lodge a complaint to the local data protection authority if your privacy rights are violated or if you have suffered as a result of the unlawful processing of your Personal Data.
• Possibility of withdrawal of the consent/ subsequent refusal to transmit Personal Data: If you wish to withdraw your previous consent or withdraw the consent to transfer of your Personal Data, you can send a written statement to BEGENE. BEGENE will respect that choice in accordance with its own legal obligations. This could mean that BEGENE may not be able to perform the actions necessary to achieve the purposes as set out in this Privacy Policy and affect the way in which BEGENE deals with you and/or for any related entities. Moreover, this withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. In this case, BEGENE will not be responsible for any direct or indirect damage of any kind that might occur as result of the withdrawal of the consent.

However, please note that BEGENE is contractually obliged to retain certain information as necessary for our legitimate business interests, to comply with our legal interest, or in accordance with legislation.

Although the definition of children varies according to laws and customs in different jurisdictions, we treat anyone under 16 years old (or equivalent minimum age in relevant jurisdiction) as a child.

We will only collect and process Children’s Person Information after we have obtained explicit consent of their guardian. When we find that a child’s Personal Data is collected without explicit consent of his or her guardian, we will delete the relevant data as soon as possible.

BEGENE reserves the right to modify this Privacy Policy at any time in accordance with this provision. The circumstances where we may change our Privacy Policy include but not limited to: there is major change of our service mode, e.g. purpose of processing Personal Data, type of processed Personal Data, usage mode of Personal Data; major change in terms of our ownership structure, organization structure, e.g. change of owners due to business adjustment, bankruptcy, merging, etc.; change of main object to which the Personal Data is publicly disclosed, shared, or transferred; change of your rights involved in Personal Data processing and their exercises; change of our responsible department, contacts and complaint channels for security of Personal Data; when there is high risk according to the Personal Data impact assessment report, etc.

If we make major changes to this Privacy Policy, we will post the revised Privacy Policy on our website.

For any privacy concern, you may, at any time, contact BEGENE through begene.id@gmail.com and generally you will get our reply in thirty (30) working days or such shorter period as provided by law.