Privacy Notice

This Privacy Notice is made in English and may be translated into other languages. In the case of discrepancy, the English version shall prevail.

Statement of Policy

We treat your information with the importance it deserves. We are committed to protecting your information, handling it responsibly and securing it with administrative, technical, and physical measures and safeguards. All test results and any Personal Information are maintained under a strict policy of confidentiality. 

This Privacy Notice is designed to help you better understand how we collect, use, store, process, and transfer your information when using our services. It is applicable to all new and existing users of our services.

Statement of Practices

CircleX is a personalised health check offered by Prenetics Limited, a leading genomics-driven health sciences company that is seeking to revolutionize prevention, early detection and treatment of cancer. References to “we”, “us”, “our” shall refer to Prenetics Limited.  

Personal data we collect

It is voluntary for you to provide any information we request, however in the event that you do not provide such information, we may not be able to provide you with our products or services.

1. Registration Information – when your account is set up, you will be asked to provide your name, contact details and date of birth.
2.  Payment Information – payment card details will be taken at point of sale to facilitate purchases. Card details are not stored by Prenetics and are managed by our third-party card processing provider.
3. Genetic or Biomarker Information–Personal Data generated through the analysis of your saliva, stool or blood test.
4. Self-Reported Information – Personal Data, including medical conditions, sports-related information, ethnicity or family history that you voluntarily share in surveys, forms or features while entering our website may be collected by us.
5. Web behaviour Information – we may collect information on how users make use of our site, Prenetics backend portals or Prenetics software solutions. This information is collected through log files, cookies, and web beacon-, analytical- and advertising technologies.
6. Gifts - If you provide us with Personal Data about others, or if others give us your information, for the purpose of ordering our service as a gift, we will only use that information for the specific reason for which it was provided to us.
7. Children's privacy - We do not collect Personal Data from minors without prior consent from a person with parental responsibility for the individual.

Statement of Purpose

Prenetics is a leading genomics-driven health sciences company that is seeking to revolutionize prevention, early detection and treatment of cancer.

We process both Personal Data and Personal Health Information for the following purposes:

To provide our service to you: We process Personal Data in order to provide our service, which includes customer support, processing payments, shipping kits to customers, creating customer accounts and authenticating logins, analysing samples, and generating reports.

To Improve Our Products and Service: We collect information when you communicate with us regarding our products and services. We may use your Personal Data to investigate, respond to and resolve complaints and service issues.

If you interact with Prenetics via telephone, your call may be recorded for training and monitoring purposes.

We also use analytics to determine ongoing service and resource needs and perform quality control checks to maintain best standards of practice. We conduct customer surveys and constantly work to improve and provide new reports, tools, and services. We may also need to fix bugs or issues, analyse use of our website to improve the customer experience or assess our marketing campaigns.

Marketing and Advertising: With your consent we may send you direct marketing communications. We may also direct advertising to you via third party sites including social media. We will only send marketing material to you where you have opted in to such communications or as determined by your web browser/cookie settings. You can unsubscribe from receiving these marketing communications at any time via your account settings.

Who we share your personal data with

Except as stated below, we will only share your Personal Data with a third party in the following circumstances: (i)  to the extent necessary to deliver our services to us; (ii) when we are required by law or in good faith believe that such disclosure is necessary in such cases. Such disclosure includes but is not limited to:

1. Investigation, prevention, or action regarding suspected or actual illegal activities or to assist government enforcement agencies.
2. Enforce the Prenetics Terms of Service.
3. Respond to claims or allegations made by third parties against Prenetics; or
4. Protect the rights, property or Prenetics’ safety and the public.

We will only share your Personal Data with those categories of third parties listed below and under the following circumstances:

1. Current or future affiliated entities of Prenetics Limited. As Prenetics Limited grows, restructuring may take place and it may be appropriate for more than one entity to control and process Information. This Privacy notice will apply to all entities affiliated with Prenetics and part of the Prenetics group.
2. With our service providers as necessary for them to provide their services to us which include payment, order fulfilment and shipping, customer support, Cloud storage, IT and security, marketing, healthcare professionals and laboratories.
3. Companies that provide services to get your purchases to you, such as payment service providers, warehouses, order packers and delivery companies.
4. Contracted consultants, suppliers and partners used to undertake fundamental activities to enable     us to provide our services, enhance the User experience; and to effectively operate and manage our organisation. 
5. With anyone else which you explicitly consent to.

Any Processors or other third-party service providers will be required to contractually comply with the principles and objectives of any Prenetics policies, including this Privacy Notice, and other applicable laws and will be required to sign a data processing agreement to confirm that Information will not be collected, used, shared, stored or otherwise for any Purpose other than those instructed by Prenetics.

We may be unable to provide our products or services to you should you wish such data sharing to not take place.

How long your personal data will be kept

We take practicable steps to ensure that the personal data collected is kept no longer than necessary to fulfil the purpose for which it is used or fulfil our contractual and legal obligations.

Security Measures

Prenetics implements measures and systems to ensure confidentiality, integrity, and availability of the data it holds, including:

Anonymisation, encryption, and data segmentation. Registration Information is stripped from Sensitive Health Information, including genetic and phenotypic data. This data is then assigned a random ID so the person who provided the data cannot reasonably be identified. Circle uses industry standard security measures to encrypt sensitive personal data both when it is stored (data-at-rest) and when it is being transmitted(data-in-flight). Additionally, data is segmented across logical database systems to further prevent re-identifiability.

Limiting access to essential personnel. We limit access of information to authorized personnel, based on job function and role. Access controls include a strict least-privileged authorization policy.

Detecting threats and managing vulnerabilities. Prenetics uses state of the art intrusion detection and prevention measures to stop any potential attacks against its networks. We have integrated continuous vulnerability scanning in our build pipeline and regularly engage third party security experts to conduct penetration tests.

Your rights

You have the following rights:

Please contact us at privacy@prenetics.com  if you wish to make a request.