We Seqbiome Ltd trading as (“Seqbiome”)Company Registered Number 655549 are committed to protecting and respecting your privacy. This Privacy Notice (the “Notice”) together with any disclaimers sets out the basis on which any personal data we collect from you or that you provide to us, or that is provided to us relating to you (“Data”) by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Notice relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity. This Privacy Notice is provided to you, in line with the following Personal Data Protection Legislation:
- The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 also known as the General Data Protection Regulation (GDPR), which became enforceable across the EU and the EEA from May 25th, 2018 having replaced the previous Directive 95/46/EC; In Ireland, the national law, which amongst other things, gives further effect to the GDPR, is the Data Protection Act 2018 (‘the 2018 Act’).
- The Directive 2009/136/EC of the European Parliament and of the Council of 25 November 2009 also known as the ePrivacy Directive, amending the Directive 2002/22/EC on universal service and users’ rights relating to electronic communications networks and services, Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector and Regulation (EC) No 2006/2004 on cooperation between national authorities responsible for the enforcement of consumer protection laws;.
This Policy sets out the basis on which any personal data we collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Laws:
- Seqbiome is the data controller when we act as an employer, as a service provider, and where dealing with suppliers.
- Seqbiome is a data processor when we provide our clients with microbiome analysis services.
If you have any questions in relation to this Privacy Notice, or wish to exercise your rights relating to it, please contact our Privacy Compliance Co Ordinator at info@seqbiome.com
What Personal Data do we collect from you?
We collect Data from you which you volunteer when you provide such Data to us, or via our services with which you interact. We may also be given other Data relating to you by other persons, or we may obtain such other Data about you as may be provided to us in the course of our legitimate business activities.
We may collect and process Data, including the following in the course of providing services to you, which could contain your personal data including your special category data:
Your full name; your address; your various email addresses; and geographical area, your various phone numbers including mobile phone number; your gender, age and nationality, race and ethnicity, your occupational information, your family and relationships information your health and lifestyle data; details of your driving licence; and details of your passport and all other Data which you ask us to process on your behalf, or which is necessary for us to process in order for us to fulfil our role as providing a service to you.
We may also process other data, which is not personal data.
When you access our website your device’s browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data. This information may be used to help us to improve our website and the services we offer, and to offer services to you.
You may give us personal data by:
- Corresponding with us by phone, e-mail or otherwise. We ask you to disclose only as much information as is necessary to provide you with our services or to submit a question/suggestion/comment in relation to our services
- Filling in forms on our website such as the contact us form.
- Applying to work with us. The type of information you may provide in your CV, a cover letter, your name, address, e-mail address and phone number. CVs should include information relevant to your employment history and education (degrees obtained, places worked, positions held, relevant awards, and so forth).
What information about you do we obtain from others?
When you use our services, we may obtain the following categories of personal data health data, unique identifier and other data as is necessary to provide our service, from others to include Clinical Trail Providers, Universities, Pharmaceutical and Bio Tech Companies and /or your authorised Representatives.
Why do we collect this information?
We collect the information in order to provide you with our services, to market our services, to improve our website and to recruit staff
We will use this information:
- To set your up as a name on our systems so as to provide you with our services
- To liaise with you about services that we are providing to you.
- To deliver information about our services, where you have subscribed to receive same.
- To fulfil our statutory function.
- To create a candidate profile for you if you are a prospective employee and volunteer.
- To process employment applications, including by assessing qualifications, verifying information, conducting reference or other employment-related checks, and notifying you of future opportunities that might be of interest to you.
- To administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- As part of our efforts to keep our website safe and secure.
- To make suggestions and recommendations to you and other users about services that may interest you or them.
The legal bases for the processing of your data are:
- That you have provided consent for the processing for one of more specified purposes such as marketing for example when you subscribe to our newsletter.
- Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract.
- Processing necessary for compliance with a legal obligation to which we are subject.
Special Category Data and the lawful basis for that processing activity.
The processing of your Personal Data can include data which is regarded as Special category of Personal data under the GDPR
The legal bases for the processing of your special category data or sensitive data are:
- That you have explicitly provided consent.
- Processing necessary for compliance with a legal obligation to which we are subject.
Who Do we share this information with?
We may share your personal data with our selected business associates/ suppliers and contractors to provide you with our services. For example, these business partners may include our web hosting provider and our sequencing service providers
In addition, we may disclose your personal information to third parties:
- If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- As part of a project with our clients and services providers.
- Statutory and regulatory bodies (including central and local government) and law enforcement authorities in order to comply with any applicable laws, grant applications and /or court orders
- Your Authorised representatives
- Third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii)you ask us to share your information.
DISCLOSURE OF YOUR INFORMATION
We may share your Personal Data with
We may also share your information with selected third parties including:
- Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you.]
We attach at Schedule 1 a list of some entities with whom your personal data is shared.
How long do we keep hold of your information?
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.
We keep your Data for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Data to provide this service to you, you can request that we erase your Data. Please note that if you request the erasure of your Data:
- We may retain some of your Data as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety
- We may retain and use your Data to the extent necessary to comply with our legal obligations.
- Because we maintain our records to protect from accidental or malicious loss and destruction, residual copies of your Data may not be removed from our backup systems for a limited period of time.
Marketing
We may communicate with you, information about certain events and fundraising events via email and or text message if you have consented to this. Such consent can be withdrawn at any time. When processing is for the submission of an entry to a fundraiser or to donate or to volunteer or to submit a view or opinion, it is done so on the basis of your explicit consent which we request at the time you provide your Personal Data and which you can withdraw at any time.
Do we transfer your information outside the European Union or European Economic Area? We will, from time to time, make use of services provided by 3rd parties for the delivery of our services which may necessitate the transfer of personal data outside the EU/EEA. For example, we use a variety of cloud-based tools such as Office 365/Microsoft, Google, Dropbox. Where data needs to be transferred or processed outside the EU/EEA, we chose providers who process data on the basis of
- SCC
- An Adequacy Decision from the European Commission.
Social networks
We maintain active social network accounts. We embed widgets from these networks to provide follow buttons, like boxes and stream embeds. This will in cookies being set by these networks while using our site. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent.
Links Pages
Some of the pages on this Website contain hypertext links to websites not maintained by us. They are merely suggested websites which may be of interest to visitors to our Website.
Please be reminded that different terms and conditions of use will apply to you as a user of these websites. In addition, such websites may not have the same privacy standards that we maintain.
Videography and Photography: When you attend an event, you may be photographed and/or filmed/recorded due to your presence at the event hosted by us or by any third party authorised by us. The images resulting from the photography, videography or recordings, and any reproductions or adaptations of same, may be used for promotion, publicity and/or other purposes.
By attending at such events, you acknowledge that event run by us is in a public place and that you may have a reduced expectation of privacy. While you have a right to object to your inclusion in any photographs or video footage, any such objection must be balanced against the legitimate interests pursued by us and/or third-party media outlets and broadcasters
WHAT ARE YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA?
You have the following rights:
- The right to access the personal data we hold about you.
- The right to require us to rectify any inaccurate personal data about you without undue delay.
- The right to have us erase any personal data we hold about you in circumstances such as where it is no longer necessary for us to hold the personal data or, in some circumstances, if you have withdrawn your consent to the processing.
- The right to object to us processing personal data about you such as processing for profiling or direct marketing.
- The right to ask us to provide your personal data to you in a portable format or, where technically feasible, for us to port that personal data to another provider provided it does not result in a disclosure of personal data relating to other people.
- The right to request a restriction of the processing of your personal data.
Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.
You may exercise any of the above rights by contacting us at info@seqbiome.com
You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie.
What will happen if we change our privacy notice?
This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This notice was last updated on 23rd December 2020.
How can you contact us?
Our Privacy Compliance Co Ordinator can be contacted at info@seqbiome.com
Date 23rd December 2020
Schedule 1
We have set out below a list of third parties with whom we share your data.
| Third party name | Description of services provided |
| Cloud Service Providers | AWS, Dropbox,Mircosoft,Google |
| Sequencing Providers | Genewiz and Teasgasc |
| Website and E mail Service Providers | Ydeal |