Geneyx Genomex Ltd. (“Company” or “us” or “our”) respect your privacy and recognize that your privacy is important. This privacy policy (“Privacy Policy”) sets forth and governs the privacy practices of the Company and applies to visitors (“you” or “visitor“) that access the Company’s website at: www.geneyx.com. (the “website”) This Privacy Policy is an integrated part of the Websites terms and conditions (“Terms”). Definitions herein shall have the meaning assigned to them in the Terms.  It is your responsibility to read this Privacy Policy thoroughly.

This Privacy Policy explains what data we may collect from our visitors, how such data may be used or shared with others, how we safeguard it, and how you may exercise your rights related to your Personal Data, among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”).

IT IS HEREBY CLARIFIED THAT THROUGH OUR WEBSITE, YOU MAY LOG IN AND ACCESS TO OUR PRODUCT, THE GENEYX ANALYSIS PLATFORM (“GENEYX PLATFORM”). THIS PRIVACY POLICY SHALL NOT GOVERN YOUR ACCESS AND USAGE OF THE GENEYX PLATFORM. IT IS YOUR RESPONSIBILITY TO REVIEW GENEYX PLATFORM’S PRIVACY POLICY WHICH MAY BE FOUND HERE https://geneyx.com/privacy-statement/PRIOR TO ANY ACCESS OR USE OF GENEYX PLATFORM.

WHO ARE WE AND CONTACTING US

Geneyx Genomex Ltd.

22 Maskit St.Hertzliya, Israel

Email: DPO@Geneyx.com

The Data Protection Representative (DPR) under Article 27 to the GDPR:

GDPR-Rep.eu

Maetzler Rechtsanwalts GmbH & Co KG

Attorneys at Law

c/o Geneyx genomex LTD

Schellinggasse 3/10, 1010 Vienna, Austria

Questions, comments, requests, and complaints regarding this Privacy Policy and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.

THE TYPES OF DATA COLLECTED

Under the GDPR, we act as the “Data Controller” of our visitors Personal Data collected or processed by us.

When you access and browse our Website, we collect certain types of data that can be classified as follows:

• non-identifiable aggregated data (“Non-Personal Data“), for example, technical information transmitted by the device you are using and certain aggregated data regarding your use of the Services.
• Individually identifiable information (“Personal Data”, or “Personal Information”, subject to applicable law definitions). This may include name, email address, and online identifiers, as detailed in the table below.

It is important to mention that the Company will not combine Personal Data you voluntarily provide with Non – Personal Data. However, if we will combine these types of data, we will treat the combined data as Personal Data.

Please see the table which details the types of data collected while you browse our Website or use the services offered therein, as well as the purpose of collection and how we use it: 

HOW DO WE COLLECT YOUR DATA

The data detailed above can be collected if you voluntarily provide it (meaning when you contact us through filling a form, etc.), or, automatically, through the use of certain tracking technologies, for example, through cookies and pixels.

COOKIE POLICY

Our Website includes tracking technologies such as cookies and pixels. These tracking technologies are used to automatically gather information by ourselves or by service providers on our behalf.

“Cookies” are small text files that are placed on your hard drive by a web server when you access our Website or use the services. Cookies are used for many purposes, e.g., for making the interaction between you and the services quicker and easier, enabling automatic activation of certain features, efficient navigation, providing the Website in an applicable language in accordance with your country, etc., as well as for remarketing purposes (as detailed below).

You can find comprehensive information about cookies at: www.allaboutcookies.org.

We may use various types of Cookies and Pixels:

• Essential – which are necessary for the site to work properly (usually appears under our name/cookie tag);
• Functional – designated to save your settings on the Website – your language preference or other view preferences;
• Targeting – used to collect information from you to help us improve our Services and serve you with targeted advertisements that we believe will be relevant to you (e.g., Google’s Cookies).
• Social networks – Social Plug-In Cookies (e.g., Facebook, Twitter, LinkedIn Cookies, or pixels, etc.) enable sharing your usage information with your social network’s accounts.
• Analytics – give us aggregated and statistical information to improve the Website and further to develop it, e.g., Google Analytics, Google Firebase Crashlytics, etc.
• Third-party services – used by us for various purposes, e.g., example, to build a profile of your interests and show you personalized content and advertisements. They work by uniquely identifying your browser and device.

You may control how your browser responds to cookies by adjusting your web browser’s privacy and security settings. Additionally, you may opt-out of certain Advertisers’ cookies and browser-enabled, interest-based advertising at the Network Advertising Initiative’s (“NAI”) website- NAI consumer opt-out and the Digital Advertising Alliance’s (“DAA”) website- DAA opt-out page.

SHARING DATA WITH THIRD PARTIES

We will not share your Personal Data with third parties, outside as specifically mentioned herein:

• Compelled Disclosures – To satisfy any applicable law, regulation, legal process, subpoena, or governmental request;
• Enforcement of our Rights – To enforce this Privacy Policy and the terms of our agreements, including the investigation of potential violations thereof;
• Security Detections – To detect, prevent, or otherwise address fraud, security or technical issues;
• Business Transfers and Affiliated Companies – When the Company is undergoing any change in control, including by means of a merger, acquisition or purchase of all or substantially all of its assets or with our parent company, any subsidiaries, joint ventures, or other companies under common control with the Company solely if and when applicable or necessary for the purposes described in this Privacy Policy, or in the event of any of the corporate transactions listed herein;
• Service Providers – To collect, hold and/or manage your Personal Information through our authorized third-party service providers, as reasonable for our business purposes;
• Explicit Consent –If you provide us with your explicit approval to share your information prior to the disclosure.

For avoidance of doubt, we may transfer and disclose or otherwise use Non-Personal Information, information linked to anonymous random identifiers, or aggregated data in a non-identifiable way, at our sole discretion.

YOUR RIGHTS UNDER PRIVACY REGULATION

Data protection and privacy laws may grant you certain rights regarding your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i)  request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please contact us at: DPO@Geneyx.com.

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

DATA RETENTION

We retain the Non-Personal Data we collect for as long as needed to provide the service, including: carry out our business purpose, perform our contract with you, and to comply with our legal obligations, resolve disputes and enforce our agreements in accordance and compliance with applicable laws, or until an individual request us to delete its Personal Data, as detailed above.

We are entitled to rectify, replenish or remove incomplete or inaccurate information at any time and at our sole discretion.

SECURITY

We use physical, technical, and administrative security measures for the services that we believe comply with applicable laws and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost. We cannot guarantee that the Personal Data is 100% secure, and we cannot be responsible for the acts of those who gain unauthorized access. We make no warranty, express, implied or otherwise, that we will be able to prevent such access

If you feel that your privacy was treated or suffered from any attempt to abuse our Website or service inappropriately, please contact us directly at: DPO@Geneyx.com.

CHILDREN

You represent and warrant that: (i) You are above the age of 18; and (ii) you are of legal competence to enter this Policy. The service is not directed or intended for individuals under the age of 18, and we do not knowingly collect or solicit information from them. If we obtain actual knowledge that a visitor is under 18, we will take steps to delete such visitor’s Personal Data immediately. If you become aware or have any reason to believe that an individual that is under the age of 18 has shared any information with us, please contact us at: DPO@Geneyx.com.

TRANSFER OF YOUR DATA

We may store or process your information in the United States or in other countries. If you are a resident of the European Economic Area (“EEA“) we will take appropriate measures to ensure that your information receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your data requires your consent, then your consent to this Policy includes your express consent for such transfer of your Personal Data.

AMENDMENTS

We reserve the right to periodically amend or revise the Policy, which will go into effect immediately upon implementing the revised Policy on our Website. We will make a reasonable effort to notify you if we implement any changes that substantially change our privacy practices. We recommend that you review this Policy periodically to understand our privacy practices and check for any amendments.