1. Introduction
ADNTRO GENETICS SL (hereinafter "ADNTRO") is the owner of the website http://adntro.com/ (hereinafter, the "Site") as well as of the platform https://app.adntro.com/ (hereinafter the "Platform") and is responsible for the processing of personal data of users ("User/s", “You”, “Your”) who access, browse and use both the Site and the Platform.
By means of 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 make use of the Site and the Platform, of the processing of personal data that may be processed 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 on personal data protection, 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 responsible for 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 e-mail address [email protected].
3. Data collected, purposes, legal basis and storage period
By means of the following table, we inform you which are the data that ADNTRO collected about the User, as well as the legal basis on which it will be legitimized to process such data, the purpose of its processing and retention periods.
Data collected on the Site.
| Data collected | Legal basis | Purpose | Conservation period |
|---|---|---|---|
| Site Navigation Data: IP and other characteristics of the User's navigation (e.g. location and/or device) derived from the use of cookies or similar technologies used on the Site. The User can find more information in our Cookies policy. | Consent provided through the cookie banner at the start of navigation. The User can withdraw his consent by following the steps indicated in the Cookies policy. Legitimate Interest Those 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 an analysis of the navigation made by the Users. | The retention periods depend on each specific cookie. For more information on the information retention periods for each type of cookie, please consult the Cookies policy. |
| User Contact on the Site: (email / ChatBot / Contact Form). Contact informationName and surname, email of the User. Content of the message | Legitimate interest to resolve any questions and/or incidents and provide an adequate service to the User. | User Support: (Sending email / ChatBot / Contact Form). Provide support to the User in case there is any query, question and/or incident related to the provision of the service to the User. | During the time necessary to answer the question and/or solve the incident indicated by the User. |
| Newsletter Contact informationE-mail address. Subject to the User's consent, the order history may be processed in order to send personalized offers on the User's favorite products. | Consent | To carry out marketing communications and inform the User about events, reports and other services available on the Site. | This data will be used for as long as the User remains subscribed to commercial communications. If you choose to unsubscribe, all your personal data collected for this function will be deleted, without prejudice to the blocking for 5 years to address possible liabilities. |
Data collected in the Platform
| Data collected | Legal basis | Purpose | Conservation period |
|---|---|---|---|
| Platform Navigation DataIP and other characteristics of the User's navigation (e.g. location and/or device) derived from the use of cookies or similar technologies used on the Platform. The User can find more information in our Cookies policy. | Consent given through the cookie banner at the start of navigation. The User may withdraw his/her consent by following the steps indicated in the Cookies 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 an analysis of the navigation made by the Users. | The retention periods depend on each specific cookie. For more information on the information retention periods for each type of cookie, please consult the Cookies policy. |
| Identification and contact information. E mail Telephone number, delivery and billing address, VAT number. | Execution of the contractual relationship. | Processing the purchase and delivery of the Kit (Adntro Pack / Adntro Premium) made by the User. | During the term of the contractual relationship and for 5 years thereafter to process any incidents or legal liabilities that may arise from the contract. |
| Identifying data, Contact data, Personal characteristics data Your email address. User name. User profile (Gender, year of birth, weight, height, blood type). | Execution of the contractual relationship. | Activate DNA Kit / Registered User Registration. Manage the User account. To provide the services. To make transactional communications and communications related to the provision of the service. | During the provision of the Service and for 5 years thereafter to process any incident or legal liabilities that may arise from the provision of the Service. |
| Contact information User's name and surname, email. Message content | Legitimate interest to resolve any questions and/or incidents and provide an adequate service to the User. | User Contact on the Platform. Email Sending, ChatBot, Contact Form
To provide support to the User in case of any questions and/or incidents related to the provision of the service to the User. | During the time necessary to answer the question and/or solve the incident indicated by the User. |
| Contact information E-mail. | Consent | Newsletter
To carry out marketing communications and inform the User about events, reports and other services available on the Site. | This data will be used for as long as the User remains subscribed to commercial communications. If you choose to unsubscribe, all your personal data collected for this function will be deleted, without prejudice to the blocking for 5 years to address possible liabilities. |
The data collected above, may be used by ADNTRO for the compatible purposes recognized by the RGPD in Article 89, for the purpose of carrying out reports and statistical studies in order to increase 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 Users' personal data.
4. Communication of data to third parties and international transfers.
ADNTRO will treat your personal data with strict confidentiality in accordance with applicable law. However, we will disclose any personal or other data you provide to us in compliance with a legal obligation or to properly fulfill other obligations under applicable law. ADNTRO will ensure that your identity will be kept strictly confidential and will not be transmitted to a third party, subject to the provisions and agreements herein.
Notwithstanding the foregoing, ADNTRO uses the services of third party technology service providers (hosting, payment gateway, CRM, and others) to ensure the operation of the Site and the Platform as well as for the provision of services, which may process the personal data provided through the agreements signed with forms implemented therein, as data processors and may also process data within the European Economic Area ("EEA") and some make international transfers outside the EEA:
- Technology 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 appropriate, subject to the User's consent, commercial communications with the User. In particular, ADNTRO has contracted with the following technology service providers:
- Hetzner Online GmbH ("Hetzner"): we use hosting and hosting services to host and store the information and personal data collected and generated through the use of the Site on Hetzner's servers, which will involve both the possibility to access them in case of technical emergency, as well as the collection, storage and interconnection of the data hosted on their servers located in the European Union, in accordance with their 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 services, hosting and storage of information and personal data.
- The services provided by the Google Analytics tool make it possible to understand how users of the Site and Platform interact with its content and to analyze its performance.
- Email service provider for communication with users.
- You can read complete information about how Google Ireland Limited treats Users' personal data through its Google services here.
- ADNTRO has formalized with Google the corresponding data processing agreement ("DPA"). You can check 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 of payment service providers, which comply with the security measures established by the payment services regulations and have Level 1 certification according to the Payment Card Industry Data Security Standard or PCI DSS: when the User enters his/her payment data on the Platform (cardholder name, card number, expiration date, CVV), these will be stored directly on the payment gateway provider's own servers without ADNTRO having access to or storing the User's bank card data on its servers, but will be processed by the payment gateways in accordance with their Privacy Policy available below. ADNTRO will receive a confirmation order that the transfer of funds has been successfully completed and will issue an invoice to the User for the contracted services.
- Stripe:By making payments through Stripe, the User acknowledges and accepts that the processing of his/her personal data linked to the payment transaction for the benefit of ADNTRO will be conducted by Stripe in accordance with its privacy statement: https://stripe.com/es/privacy. ADNTRO has taken the legal steps established by the applicable legislation, subscribing to the model clauses for the safeguarding of the rights and freedoms of data subjects.
- Paypal:By making payments through Paypal, the User acknowledges and accepts that the processing of his/her personal data related to the payment transaction for the benefit of ADNTRO will be conducted by Paypal in accordance with its privacy statement:
https://www.paypal.com/es/webapps/mpp/ua/privacy-full
ADNTRO has taken the legal steps established by the applicable legislation, subscribing to the model clauses for the safeguarding of the rights and freedoms of the interested parties available at https://www.paypal.com/us/webapps/mpp/ua/data-protection
- Transportation service providers. ADNTRO contracts third party services for the transport of DNA kits. ADNTRO will communicate to the transport company the buyer's identification information, the delivery address and contact details to coordinate the delivery between the User and the corresponding transport company.
- Service providers for sending emails transactional and/or commercial communications by e-mail.
ADNTRO may share personal data, in addition to the companies within its corporate group for purposes of business separation, customer portfolio management or other purposes related to internal business organization, with any company interested in purchasing or that purchases ADNTRO or a part of its business and, consequently, give access to any national or international auditors to carry out its "due diligence" provided that such processing is essential for the successful completion of the business transaction. As indicated in article 21 LOPDGDD, if the transaction is not completed, the data must be immediately deleted by the receiving entity.
5. Security and confidentiality
ADNTRO undertakes to adopt the necessary technical and organizational measures in accordance with current regulations in order to ensure the security of personal data and to prevent accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorized communication or access to such personal data. Personal data will be treated as confidential by the data controller, who undertakes to inform and ensure by means of a legal or contractual obligation that such confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible.
6. Retention of your data
We only retain your personal data for as long as necessary to fulfill the purposes for which we have collected it, including to comply with legal, accounting or reporting obligations.
In determining the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes by other means, and applicable legal requirements.
7. Data protection rights
The User may exercise the rights of access, rectification, deletion, opposition, and, if applicable, limitation of processing and portability of data by sending an email to [email protected]with the reference "RGPD", and the content of your request. In cases where representation is admitted, it will also be necessary the identification by the same means of the person representing the User, as well as the document proving the representation.
Likewise, the User may submit a complaint to a supervisory authority, and in particular, to the Spanish Data Protection Agency (www.aepd.es) if he/she considers that the rights set out above in this Privacy Policy are violated or if he/she considers that the processing of personal data concerning him/her infringes the applicable regulations.
8. Commercial communications
When subscribing to our newsletter, the User will receive electronic commercial communications in accordance with applicable law, including alerts, notifications, newsletters, offers and promotions about ADNTRO services. If the User do not wish to receive information related to ADNTRO services, the User may unsubscribe from any of our "Unsubscribe" (opt-out) communications or let us know by sending a notification to [email protected] .
9. Cookies
The Site uses cookies that are installed in the User's browser, if so configured, when accessing the Site and the Platform. Complete information about the cookies that are installed is specified in the Cookies policy.
10. Social Networks
ADNTRO is the owner of accounts on various social networks (Facebook, Twitter, LinkedIn). The processing carried out by ADNTRO data is the one allowed by the social networks themselves through their services, without the possibility of ADNTRO extract personal data from these social networks of their followers and users of the same. ADNTRO uses these social networks to inform of their services and offers related to the Platform itself in compliance with the terms of contract established by the owners of the social networks themselves.
11. Changes in the Privacy Policy
ADNTRO reserves the right to modify this Privacy Policy at any time. Changes or updates to the Privacy Policy will be explicitly notified to the User through a notice on the Site, together with the updated version of the Privacy Policy.
Last version: 10.07.2022
