Full Privacy Statement

Last updated: 19 May 2021

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Please review this privacy statement carefully before using our services. This will help you to better understand how we collect, use, store, process and transfer your information. By using our services, you hereby acknowledge and consent to our policies and terms of use.

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At e-Beauty, your privacy is our priority, that is why we take extra precautions to maintain this trust.

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1. Key Definitions

1. We: e-Beauty (“EMEI199.COM PTE LTD”), its subsidiaries and affiliates (collectively known as “we”, “our”, or “us”).

2. Services: All websites, apps, software, pages, content, and related services owned and operated by us.

3. Aggregate Information: information that has been combined with that of other users and analysed or evaluated as a whole, such that no specific individual may be reasonably identified.

4. Anonymised Information: means any Information that we have anonymised in a manner to result in the Information no longer being able to identify you, whether directly or indirectly, and is therefore no longer Personal Information.

5. Individual-level Information: information about a single individual's genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.

6. Personal Information: information that can be used to identify you, either alone or in combination with other information. E-Beauty collects and stores the following types of Personal Information:​

   1. Genetic Information: information regarding your genotypes (i.e., the As, Ts, Cs, and Gs at particular locations in your genome), generated through processing of your DNA sample by E-Beauty or by its contractors, successors, or assignees; or otherwise processed by and/or contributed to E-Beauty.

   2. Self-Reported Information: information you provide directly to us, including your disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your account.

   3. Sensitive Information: information about your health, Genetic Information, and certain Self-Reported Information such as racial and ethnic origin, sexual orientation, and political affiliation.

   4. User Content: all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials - other than Genetic Information and Self-Reported Information-generated by users of E-Beauty Services and transmitted, whether publicly or privately, to or through e-Beauty.

   5. Web-Behaviour Information: information on how you use your Services collected through log files, cookies, web beacons, and similar technologies, (e.g., browser type, domains, page views).

   6. Pseudonymised Information: means replacing the identifying markers of your Information with artificial identifiers to reduce the association between the data subject and the Information during processing.

7. Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g., name, email, phone number, address, user ID and password, and payment information).

 

2. Data We Collect

To ensure accuracy and user experience, we generally collect data from various sources, such as:

 

1. Information you provide directly. We collect your data when you create an account, make a purchase from us, participate in surveys or by other methods of communication. This includes, but not limited to, your name, contact details, and username. When you register your test kit, we also collect your birth date, gender, name, and kit code for activation purposes.

2. Information collected automatically. When you use our services, information (such as web- behaviour) is collected automatically via cookies, third-party services, and other tracking technologies. Depending on your browser settings, this allows the system to improve your experience, by providing increased security, faster loading times, customising and improving your user experience.

3. Information from genetic service. With your consent, we extract your DNA from the sample that you submitted to us. This allows our partner laboratories to further convert it into genetic/DNA data that is used to generate your personalised report.

4. Other information provided by third parties. You may reject the kinds of data we collect; however certain functions might be limited.

 

3. How We Use Your Information

e-Beauty will use and share your Personal Information with third parties only in the ways that are described in this Privacy Statement.

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a. To provide you with Services and to analyse and improve our Services

We use the information described above in Section 2 to operate, provide, analyse and improve our Services. These activities may include, among other things, using your information in a manner consistent with this Privacy Statement to:

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1. Open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);

2. Enable and enhance your use of our website and mobile application(s), including authenticating your visits, providing personalized content and information, and tracking your usage of our services;

3. Contact you about your account, and any relevant information about our services (e.g., Policy changes, security updates or issues, etc.);

4. Enforce our terms of service and other agreements;

5. Monitor, detect, investigate and prevent prohibited or illegal behaviours on our services, to combat spam and other security risks; and

6. Perform research & development activities, which may include, for example, conducting data analysis in order to develop new or improve existing products and services, and performing quality control activities.

 

b. To process, analyse and deliver your genetic testing results

As described above, to receive results through the Personal Genetic Service, you must create a e-Beauty account, register your kit, and submit your saliva sample to be genotyped by us or our contracted laboratory. Once genotyped, we further analyse your Genetic Information to provide you with our health and/or ancestry reports, depending on the Service purchased. e-Beauty continuously works to improve our Services based on our research and product development, and genetic associations identified in scientific literature. If you are eligible to receive additional reports or updates in the future, you may be notified of or may directly access these updates.

 

c. To allow you to share your Personal Information with others

e-Beauty gives you the ability to share information, including Personal Information, through the Services. You have the option to share directly with individuals with our accounts through (i) our platform, (ii) other sharing features and tools. You may also have the ability to share information directly with individuals who have not participated in our Services through social media platform (such information is "User Content"). Some sharing features, including receiving sharing invitations, may require that you opt-out, however you will always be required to take a positive action, such as opting in, to share sensitive data.

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Our legal basis for processing your Personal Information for the purpose described above is based on your consent. You may withdraw your consent at any time; however, the withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

 

d. To allow you to share your Personal Information for Our Research purposes

You have the choice to participate in Our Research by providing your consent. "Our Research" refers to research and development projects, including but not limited to those aimed at publication in peer-reviewed journals conducted by us.

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Our Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or for healthcare companies. Our Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. Our Research uses Aggregate and/or Individual-level Genetic Information and Self-Reported Information as specified in the appropriate Consent form, as explained in greater detail below.

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1. Your anonymised Genetic and Self-Reported Information may be used for our Research only if you have consented to this use by providing consent. If you have provided consent:

2. Your Genetic Information and/or Self-Reported Information will be used for research and development purposes, but it will be anonymised and will not be linked to your Registration Information. E-Beauty may use individual-level Genetic Information and Self-Reported Information for research and development purposes.

3. e-Beauty may share summary statistics, which do not identify any particular individual or contain individual-level information, with our qualified research collaborators.

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If you have completed the Informed Consent, or additional consent agreement, in addition to the uses above under the Consent form, e-Beauty may share anonymised Individual-level Genetic Information and Self-Reported Information with select third party research collaborators for e-Beauty partners for Research purposes.

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Withdrawing your Consent. You may withdraw your consent to participate in e-Beauty Research at any time by changing your consent status within your Account Settings. If you experience difficulties changing your consent status, contact ask@emei199.com. We will not include your Genetic Information or Self-Reported Information in studies that start more than 30 days after you withdraw (it may take up to 30 days to withdraw your information after you withdraw your consent). Any research involving your data that has already been performed or published prior to your withdrawal from our Research will not be reversed, undone, or withdrawn. You may also discontinue your participation in our Research by deleting your account (as described in section 5.d).

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What happens if you do NOT consent to our Research?

If you choose not to provide consent to us or complete any additional agreement with us, your Personal Information will not be used for our Research. However, your Genetic Information and Self-Reported Information may still be used by us and shared with our third-party service providers in order for us to provide our Services to you as outlined in this Privacy Statement.

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Our legal basis for processing your Sensitive Information for the purpose described above is based on your consent. You may withdraw your consent at any time; however, the withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

 

e. To recruit you for external research

Research is an important aspect of our Services and we want to ensure interested participants are aware of additional opportunities to contribute to interesting, novel scientific research conducted by academic institutions, healthcare organizations, pharmaceutical companies, and other groups. If you have chosen to participate in our Research, from time to time we may inform you of third-party research opportunities for which you may be eligible. For example, if a university tells us about a new cancer research project, we may send an email to our research participants who potentially fit the relevant eligibility criteria based on their Self-Reported Information to make them aware of the research project and provide a link to participate with the research organization conducting the study. However, we will not share Individual-level Genetic Information or Self-Reported Information with any third party without your consent. If you do not wish to receive these notifications, you can manage them by editing your preferences in your Account Settings.

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f. To provide customer support

When you contact Customer Care, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one customer’s Personal Information to resolve another customer’s dispute or request. For example, if a customer reports behaviour that violates our Terms of Service, we will separately process both customers’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another customer without your consent.

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g. To conduct surveys or polls, and obtain testimonials

We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us. If you do not wish to receive these requests, you can manage them in your Account Settings. Our legal basis for processing your Personal Information for the purpose described above is based on our legitimate interest. We think it is important to continue improving our Services to ensure your continued enjoyment.

 

h. To provide you with marketing communications

By creating a e-Beauty account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these marketing communications at any time. To unsubscribe, click the email footer “unsubscribe” link or go to the “Preferences” section of your Account Settings to edit your email notification preferences. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

 

4. Information We Share with Third Parties

 

a. General service providers.

We share the information described above with our third-party service providers, as necessary for them to provide their services to us and help us perform our contract with you. Service providers are third parties (other companies or individuals) that help us to provide, analyse and improve our Services. While we directly conduct majority of data processing activities required to provide our Services to you, we engage some third-party service providers to assist in supporting our Services, including in the following areas:

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1. Order fulfilment and shipping. Our payment processor processes certain Registration Information, such as your billing address and credit card information, as necessary to enable you to purchase a DNA kit from our online store. Our distribution centres ship your kit(s) to you, and in some cases, help return your kit safely to us or to our third-party laboratory so your sample can be processed.

2. Customer Care support. Our Customer Care team uses a number of tools to help organize and manage the requests we receive. These tools help to ensure we provide timely, high quality support.

3. Cloud storage, IT, and Security. Our cloud storage providers provide secure storage for information in our databases, ensure that our infrastructure can support continued use of our Services by our customers, and protect data in the event of a natural disaster or other disruption to our Service. Our IT and security service providers assist with intrusion detection and prevention measures to stop any potential attacks against our networks. We have these third-party experts perform regular penetration tests and periodically audit our security controls.

4. Marketing and analytics. When you use our Services, including our website or mobile app(s), our third-party service providers may collect Web-Behaviour Information about your visit, such as the links you clicked on, the duration of your visit, and the URLs you visited. This information can help us improve site navigability and assess our Marketing campaigns.

 

NOTE: Our service providers act on e-Beauty’s behalf. We implement procedures and maintain contractual terms with each service provider to protect the confidentiality and security of your information. However, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.

 

b."Targeted advertising" service providers

We permit third party advertising networks and providers to collect Web-Behaviour Information regarding the use of our Services to help us to deliver targeted online advertisements ("ads") to you. They use cookies and similar technologies, to gather information about your browser's or device's visits and usage patterns on our Services and on other websites over time, which helps to better personalize ads to match your interests, and to measure the effectiveness of ad campaigns. We and our third-party service providers will not use your Sensitive Information, such as Genetic Information and Self-Reported Information, for targeted marketing without asking for and receiving your explicit consent.

 

c. Aggregate information

We may share Aggregate Information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. This Information is different from "Individual-level" information and is not Personal Information because it does not identify any particular individual or disclose any particular individual’s data. For example, Aggregate Information may include a statement that "30% of our female users share a particular genetic trait," without providing any data or testing results specific to any individual user. In contrast, Individual-level Genetic Information or Self-Reported Information consists of data about a single individual's genotypes, diseases or other traits/characteristics information and could reveal whether a specific user has a particular genetic trait, or consist of all of the Genetic Information about that user. We will ask for your consent to share Individual-level Genetic Information or Self-Reported Information with any third party, other than our service providers as necessary for us to provide the Services to you.

 

d. Information we share with commonly owned entities

We may share some or all of your Personal Information with other companies under common ownership or control of e-Beauty, which may include our subsidiaries, our corporate parent, or any other subsidiaries owned by our corporate parent in order to provide you better service and improve user experience. Generally, sharing such information is necessary for us to perform on our contract with you. We may provide additional notice and ask for your prior consent if we wish to share your Personal Information with our commonly owned entities in a materially different way than discussed in this Privacy Statement.

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e. As required by law

Under certain circumstances your Personal Information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. For example, we may be required to disclose Personal Information in coordination with regulatory authorities in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that we may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce our Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or our personal safety, its employees, its users, its clients, and the public.

 

f. Business transactions

In the event that we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets your Personal Information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

 

5. Your Choices

 

a. Access to your account

We provide access to your data within your account. You can access and download data processed by us within your Account Settings and within applicable Reports, Tools, and features. If you lose access to your account or account email address, please contact Customer Care for assistance. If you lose access to your account, in certain circumstances, we may require that you submit additional information sufficient to verify your identity before providing access or otherwise releasing information to you. If you choose not to submit the required documentation, or the information provided is not sufficient for the purposes sought, we will not be able to sufficiently verify your identity in order to complete your request.

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You may access, correct or update most of your Registration Information on your own within your Account Settings. You may also review and update your consent to our Research. To exercise one or more of the rights described in this Privacy Policy, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Information, please contact ask@emei199.com.

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b. Marketing communications

As noted in Section 3.h. you may be asked to opt-in to receive product and promotional emails or notifications when creating your account or when using our Services. You may view or update your notification preferences for marketing communications by visiting your Account Settings, opting out at the browser or device level, or by contacting our Privacy Administrator at ohmygenehelp@gmail.com. You can also click the "unsubscribe" button at the bottom of promotional email communications, as applicable.

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c. Sharing outside of our Services

You may decide to share your Personal Information with friends and/or family members, doctors or other health care professionals, and/or other individuals outside of our Services, including through third-party services such as social networks and third-party apps that connect to our website and mobile apps through our application programming interface ("API"). These third parties may use your Personal Information differently than we do under this Privacy Statement. Please make such choices carefully and review the privacy statements of all other third parties involved in the transaction. We do not endorse or sponsor any API applications, and does not affirm the accuracy or validity of any interpretations made by third party API applications.

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In general, it can be difficult to contain or retrieve Personal Information once it has been shared or disclosed. We will have no responsibility or liability for any consequences that may result because you have released or shared Personal Information with others. Likewise, if you are reading this because you have access to the Personal Information of a customer through a multi-profile account, we urge you to recognize your responsibility to protect the privacy of each person within that account. Users with multi-profile accounts (i.e., where multiple family members register their kits to one account) should use caution in setting profile-level privacy settings.

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d. Account deletion

If you no longer wish to participate in our Services, or no longer wish to have your Personal Information be processed, you may delete your account and Personal Information within your Account Settings. Once you submit your request, we will send an email to the email address linked to your account detailing our account deletion policy and requesting that you confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be cancelled, undone, withdrawn, or reversed. When your account is deleted, all associated Personal Information is deleted and any stored samples are discarded, subject to the following limitations:

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1. Information previously included in our Research. As stated in any applicable Consent Document, Genetic Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in our Research cannot be removed from completed studies that use that information. Your data will not be included in studies that start more than 30 days after your account is closed (it may take up to 30 days to withdraw your information after your account is closed).

2. Legal Retention Requirements. e-Beauty and/or our laboratory will retain your Genetic Information, date of birth, and sex as required for compliance with applicable legal obligations. Circle will also retain limited information related to your account and data deletion request, including but not limited to, your email address, account deletion request identifier, and record of legal agreements for a period of time as required by contractual obligations, and/or as necessary for the establishment, exercise or defence of legal claims and for audit and compliance purposes.

 

6. Protecting Your Data

e-Beauty implements physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your Personal Information.

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1. Physical. Strict limitations are in place to prevent any unauthorised access to Personal Information. We ensure that Information, its processing, production, and research environments are separated and restricted to authorized and essential personnel, based on job function and role.

2. Technical. All information provided will be kept in a protected and secured server. We use state of the art security measures to encrypt sensitive information both at rest and in transit.

3. Administrative. We ensure anonymisation and confidentiality by stripping traceable information (e.g., contact information, name) and assigning every kit a random identification number so any individual cannot be reasonably identified.

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Your responsibility. Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify us of any unauthorized use of your password. We cannot secure Personal Information that you release on your own or that you request us to release.

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7. Changes to Privacy Statement

e-Beauty modifies the Privacy Statement periodically, or when necessary, to reflect changes in our Services, how we use your information, or when the governing law requires. Such changes will be notified via our Services before made effective. This will be reflected in the "Last Updated" date at the top of the statement.

 

8. Contact Information

If you have questions about our Privacy Statement, or wish to submit a complaint, feedback, or inquiry, you may email us at ask@emei199.com, or send a letter to our main office at 61 Ubi Road 1, Oxley Bizhub 1, #02-07, Singapore 408727.

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