Privacy Policy

1. Who we are

Welcome to our website.

This Privacy Policy is the agreement of understanding between you and DNAlife, a Mauritius incorporated company with the registration number 130844, with its registered address at 6th Floor, Tower A, 1 CyberCity Ebene, Mauritius. DNAlife or its subsidiary members will be referred to as “company”, “we”, “us”, “our”. By visiting or using our website, or the services that are provided therein, you agree to have read, understood and to be bound by this privacy policy.

We work under the domain of functional medicine, where our members render services such as (but not limited to) supplements, books, courses/education, functional and DNA testing services through our different web-based platforms (hereinafter referred to as “Service”).

DNAlife has the following partners, which are bound by the same privacy policy:

Nordic Laboratories ApS
Registered in Denmark
Registration number DK26672953
VAT number: DK26672953
Address: Nygade 6, 3.sal, 1164 Copenhagen K, Denmark.

Referred to as NL as on

and

Simply Nature Limited
Registered in England
Registration number 03946909
VAT number: GB621769530.
Address: Unit 11, Old Factory Buildings, Battenhurst Road, Stonegate, East Sussex TN5 7DU, UK

Referred to as “SN” as on

and

Nordic Health B.V.
Registered in Holland
Registration number 82541930
VAT number: NL862511999-B01
Address: Papirbaan 50A, 9672 BH Winschoten. Netherlands

Referred to as “NH” as on

This document refers to anyone accessing, visiting or using our website.

Please note that Nordic Group is a body corporate which has independent members. All members work independently in their own business domains, and services rendered by them have no direct or indirect connection/partnership with Nordic Group. This also includes members,; employees, consultants, agents or sub-contractors.

Therefore, for specific complaints these should be addressed merely to the company from where the services/products were ordered or rendered.

By visiting or using our websites you automatically agree to be bound by this Privacy Policy.

Our Privacy Policy governs your visit or use of our websites and explains how we collect, process, safeguard and disclose information that results from your use of our Service.

The parties acknowledge that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, and, in what concerns the UK territory, the Data Protection Act 1998 and Human Rights Act 1998 apply to our processing of personal data on behalf of the Customer. These data processing conditions are designed with a view to the parties’ compliance with Article 28 (1). 3 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (Data Protection Regulation). The Data Processing Terms take effect from the time the Customer visits or uses our websites and the Data Processing Terms replace from this time the previous Data Processing Agreement is entered into between the parties in relation to the agreed processing activities under the Cooperation. The Customer’s commencement of or continuation of the use of our websites is hereby considered the Customer’s consent of the data processing terms.

We use your data to provide and improve our Service. By using our Service, you agree to the collection and use of information in accordance with this policy.

The validity, construction and performance of this Privacy Policy shall be mainly governed by the internal jurisdiction of the country where the member is registered. Therefore, you agree that any dispute arising from it shall be litigated only in that country and in compliance of the said jurisdiction.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

2. Interpretation

Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.

3. Definitions

For the purpose of this Privacy Policy:

• ACCOUNT means a unique account created for you to access our Service or parts of our Service.
• COMPANY means any business corporation whose services and products are directly specified in the Website.
• CONSENT is any expression or action of free will by which any Data Subject automatically consents that their personal data are subject to processing.
• COOKIES are small files that are placed or stored in your computer, mobile device or any other device by a website, containing the details of your browsing history on such website among its many uses.
• DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, We are the Data Controller of your data.
• DATA PROCESSORS mean any natural or legal person who processes the data on behalf of the Data Controller. We may outsource the services of various Service Providers in order to process your data more effectively.
• DATA SUBJECT is any living individual who is the subject of Personal Data.
• DEVICE means any device that can access the Service such as a computer, mobile phone or a digital tablet.
• PERSONAL DATA means any information about a living individual who can be identified or is identifiable or that can be accessed from such data (when combined with other information either in our possession or likely to come into our possession or made available to us).
• SERVICE means any website operated by Nordic Group, including business activity carried out by the Company which runs the Website, as well as its services and products.
• SERVICE PROVIDER means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate, promote, provide or perform the Service or to assist the Company in analysing how the Service is used.
• USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).
• USER is the individual using our Service, which includes our clients and customers. The User corresponds to the Data Subject, who is the subject of the Personal Data.

4. Information Collection

We collect several different types of information for various purposes to provide and improve our Service to you.

5. Types of Data Collected

5.1 Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or to identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, Country, State, Province, ZIP/Postal code, City
• Cookies

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Your personal Data stored is also shared with postal services e.g in DHL, UPS, FedEx in order to deliver purchased good and/or services to you

5.2 Usage Data

We may also collect information that your browser automatically sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service through a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

5.3 Location Data

We do not use and store information about your location. Location data we record is listed above in Personal Data section.

5.4 Tracking Cookies Data

The Service uses only Session Cookies. These Cookies are essential to provide you with services available through the Website and to enable you to use its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided and we only use these Cookies to provide you with those services.

5.5 Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, social security (or other taxpayer identification) number, office location and other data.

6. Use of your Personal Data

We use the collected data for various purposes:

• To provide and maintain our Service.
• To allow you to participate in interactive features of our Service when you choose to do so.
• To provide customer support.
• To manage your account: to manage your registration as a user of the Service. The Personal Data you provide can give you access to different functionalities of the Service that are available to you as a registered user.
• To gather analysis or valuable information so that we can improve our Service.
• To monitor the usage of our Service.
• To detect, prevent and address technical issues.
• To fulfil any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To contact you to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

7. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or when we are legally obliged to retain this data for longer time periods.

8. Transfer of Data

Your information, including Personal Data, is stored and maintained at our Data Servers located in Germany and Finland and we process it there.

This means that every information may be transferred to and maintained on computers located outside the area/country where you are from.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

9. Disclosure of Data

We may disclose personal information that we collect, or you provide:

9.1 Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

Other cases.

We may disclose your information also (if required)

1. To our subsidiaries and affiliates.
2. To contractors, service providers, and other third parties we use to support our business.
3. To fulfil the purpose for which you provide it.
4. For any other purpose disclosed by us when you provide the information.
5. With your consent in any other cases.
6. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

10. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Nevertheless, the Company takes all steps reasonably necessary to ensure the best processing of your Personal Data and in accordance with this Privacy Policy.

11. Rights of Personal Data Holders – General Data Protection Regulation (GDPR)

One of the main goals of the General Data Protection Regulation (GDPR) is to protect and clarify the rights of EU citizens and EU residents with regards to data privacy. . As the holder of your own personal data, you are guaranteed a set of rights in relation to the way these data are processed and which can be exercised at any time.

We aim to take reasonable steps to allow you to correct, amend, oppose, delete, or limit the use of your Personal Data. Pursuant to GDPR you can always exercise your data protection entitlements through the right of access, opposition, information, portability, rectification and erasure.

The holder may also withdraw, at any time, the consent he/she has given for the processing of his/her personal data. The revocation of consent will not affect the lawfulness of the processing of personal data which up to such date has been carried out based on the consent previously given.

The exercise of rights can be done by written request to our Data Protection Officer (DPO), to the following email support@nordicvms.com .

Please note that erasure of Personal Data will result in non-recoverable deletion of requested records. In order to maintain sales and services data sold by us to you, we will keep the record of invoices but the billing and shipping details other than country will be kept anonymous.

Your Personal Data stored with postal services e.g in DHL, UPS, FedEx or etc will not be covered under this request. You will need to contact the service provider directly to get your data deleted.

Therefore, you have the following data protection rights:

1. The right to information, where any data subject is entitled to be provided with concise, clear and accessible information on how their personal data are being used.
2. The right to access, update or to delete the information we have on you.
3. The right of rectification. You have the right to have your information rectified (if that information is inaccurate) or completed (if proved to be incomplete).
4. The right to opposition. You have the right to object to our processing of your Personal Data.
5. The right of restriction. You have the right to request that we restrict the processing of your personal information.
6. The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format, as well as the right to transfer such data to another controller, under certain conditions.
7. The right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information. You can inform us of your intention through our contacts provided below. Please bear in mind that a withdrawal of consent does not compromise the lawfulness of the processing carried out on the basis of the consent previously given.
8. The right to erasure: where the data subject is entitled to obtain from the controller the erasure of his/her personal data. If you wish to delete your personal data, please inform us by emailing our DPO at support@nordicvms.com and we will take the reasonable steps to respond to your request in accordance with the legal requirements. If the personal data we collect is no longer necessary for any purposes and we are not required by law to keep it, then we will use our best efforts to permanently eliminate, destroy or anonymize it;

Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

12. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

14. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

15. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

16. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

17. Child Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”) independently. Child information is only acceptable when entered by parents or with parental consent.

We strongly advise you to monitor your child access to our Service and, therefore, assume no responsibility for the content or practices of any third party related to visit or use of our Service.

18. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are immediately effective when they are posted on this page.

19. Contact Us

If you have any questions or comments regarding this Privacy Policy, please contact us by email to: support@nordicvms.com.

If you wish to have your contact removed from our records, please send an email from that address to us at unsubscribe@nordicvms.com, with the word “unsubscribe” in the subject line of your email.

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