Privacy Policy
Last update: 06/05/2024
CITOGEN S.L.U. has a Genetic Identification Unit, dedicated to DNA analysis for the determination of biological parentage.
The management of CITOGEN S.L.U. is firmly resolved to ensuring compliance with the legislation in the area of data protection, and, in this way, to ensure the legal rights and to manage personal data appropriately.
CITOGEN S.L.U. makes the following web page available to the public. https://adngen.com/en. This Privacy Policy explains how the personal data is collected through this website.
WHO IS RESPONSIBLE FOR PROCESSING THE DATA COLLECTED WITHIN THE FRAMEWORK OF THE WEBSITE, WWW.ADNGEN.COM?
The person responsible for the data collected will be:
CITOGEN S.L.U., NIF: B50600188
Mailing address:
Avenida Diagonal Plaza 40, 50197 Zaragoza (España) (en lo sucesivo “Citogen”)
Contact Data Protection Officer: cagt@cagt.es
HOW DID WE OBTAIN YOUR DATA?
Personal data collected through the web page https://adngen.com/ are collected directly from its owner through:
- Forms in which you can enter your information
- E-mails or messages to contact addresses made available to you
- The use of technologies such as cookies that collect your IP address, as described in COOKIES POLICY
- Use of social networks
Please note that when you provide us with your personal information, you warrant that you are qualified to provide this information and that the information is true, accurate and up to date, that it is not confidential and does not violate any contractual restriction or rights and you undertake not to impersonate other users using their registration data to the various services and/or contents of the website.
You are responsible for keeping your data correct and accurate and updated, and to communicate any modification that affects them. Accordingly, Citogen disclaims any and all liability deriving from the holder’s failure to comply with the data of this warranty. The owner of the data will be liable to Citogen and third parties for any damages or losses caused as a consequence of non-compliance of the obligations assumed in this clause.
WHAT TYPES OF PERSONAL DATA WILL WE COLLECT ON THE WEBSITE?
PROCESS | CATEGORIES OF DATA COLLECTED |
Contact and inquiries | E-mail address, contact information (name, surname, telephone number, address), content of the messages or e-mails |
Contacts and e-mail addresses | E-mail address, contact information (name, surname, telephone number, address), content of the messages or e-mails |
Collection and analysis of browsing data obtained through cookies | IP address, browsing habits |
Billing data | Credit card data, invoice data, name of cardholder |
Data required for ordering and payment of services | Name, surname, telephone, e-mail, address, company, zip code, city, state, province, phone number, additional notes |
Data for the collection and analysis of DNA samples and delivery of the results | Name, surname, telephone, e-mail, address, company, zip code, city, state, province, phone number, additional information, delivery address, medical history, ID number and name of the applicants and the persons donating the sample, observations. |
Social media interaction data | Name, user, interactions, photographs, texts |
WHY AND FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?
Below, we inform you of the processes and their main purposes, that Citogen currently carries out through the website web https://adngen.com/:
PROCESS | PURPOSE | LEGAL BASIS FOR LEGITIMACY |
Contact and inquiries, service calls and complaints | Attending to queries and complaints | Legitimate interest in answering the contact form or inquiry and manage incidents. |
Contacts and e-mail addresses | Maintain communication via e-mail for work-related/ mercantile reasons, as long as this is related to the mercantile or commercial relationship. | Contractual relationship and Citogen’s legitimate interest to maintain and manage the relationship and the information provided that it is related to the commercial or business relationship. |
Collection and analysis of browsing data obtained through cookies | Analyze user navigation through the website and improve the products and services. Facilitate navigation. | Citogen’s legitimate interest in analyzing and improving the navigation of its website. |
Billing data | Billing management of contracted services | Fulfillment of the contractual relationship |
Data required for ordering and payment of services | Manage services requests and placing orders | Fulfillment of the contractual relationship |
Data for the collection and analysis of DNA samples and delivery of the results | The data will be processed in order to carry out and ensure the procedure of sampling for genetic profiling: DNA analysis, certification of sample collection and chain of custody. | Consent, public interest, contract fulfillment |
Social media interaction data | The data will be processed to interact with users or followers of the Genetic Identification Unit and for advertising products and services | Legitimate interest in advertising products and services and interacting with other stakeholders. |
HOW LONG WILL WE KEEP YOUR DATA?
Contact and inquiries, service calls and complaints | The data provided will be kept for as long as necessary for the processing and response of the consultation, as long its deletion by the interested party has not been requested. Claims data will be maintained for a period of 5 years in order to meet potential responsibilities. |
Contacts and e-mail addresses | The data provided to maintain contact will be retained indefinitely, as long as its elimination is not requested by the interested party. |
Navigation data | 2 years from collection |
Billing data | 6 years from collection |
Contact information to apply for study financing | 5 years since collection |
Data required for ordering and payment of services | 5 years since collection |
Data for the collection and analysis of DNA samples and delivery of the results | Data for the collection and analysis of DNA samples and delivery of the results Samples shall be kept for 5 years and, in any case, for compliance with legal deadlines and limitation periods, which are applicable. The report data is stored for as long as is necessary for the purposes for which it was requested. |
Social media interaction data | For as long as the user interacts on social networks. |
WITH WHICH THIRD PARTIES DO WE SHARE YOUR DATA?
We inform you that the data you provide may be used for the following purposes to third parties for the fulfillment of purposes directly related to the legitimate functions of Citogen or of the third parties and for legal obligations.
Access to data held by Citogen will be granted to third party suppliers that provide services to Citogen and that operate as process management.
THE FOLLOWING TRANSFERS OF PERSONAL DATA WILL TAKE PLACE:
Subscription to the Newsletter through the Citogen website | The data is not disclosed to third parties |
Contact and inquiries service calls and complaints | The data is not disclosed to third parties |
Contacts and e-mail addresses | |
Navigation data | The data is not disclosed to third parties |
Billing data | Will be disclosed: – To the other Citogen Group companies, as well as to its distributors and marketers in compliance with the applicable legal obligations. – To the corresponding authorities in compliance with applicable legal obligations. – Payment management entity. |
Data required for ordering and payment of services | The payment data is transferred to the entity managing the payments. |
Data for the collection and analysis of DNA samples and delivery of the results | In the case of family reunification, your data will be sent to the Spanish Embassy and/or Consular office in the country of origin (this will involve an international transfer of your data). To authorities, courts and tribunals in the case of dossiers or paternity claims, to the State Security Forces. To the competent authorities for sanitary inspection. |
Social media interaction data | The social networks with which you interact with Citogen will be also responsible for your personal data. |
INTERNATIONAL DATA TRANSFERS
In the case of transferring data to third parties (such as transfer of data between Citogen Group companies) or to use suppliers to provide us with auxiliary services for our activity (lodging, housing, SaaS), from outside the European Economic Area that can have access, Citogen will implement adequate warrantees for the protection of personal data protection, such as the signing of standard protection clauses or the adoption of binding corporate standards between the group companies, which means that they are obliged to comply with requirements equivalent to European standards in terms of data protection.
In the case of family reunification,your data will be sent to the Spanish Embassy and/or Consular office in your country of origin. This transfer is done on the basis of the applicant’s consent or public interest.
Social networks will be able to carry out transfers of international data, according to their own privacy policies.
WHAT ARE YOUR RIGHTS WHEN YOU PROVIDE US WITH YOUR DATA?
The owner of the data is entitled, at any time, to the following rights, when legally applicable:
- Access: the right to know what personal data Citogen holds about you, the process applied to them and a copy of the personal data being processed.
- Rectification: To request a rectification or an update of the personal data in Citogen’s possession, if inaccurate or incomplete.
- Suppression: request its suppression when the purpose for which the processing or collection was carried out, by processing illicit data, e.g., unnecessary or obsolete data, withdrawal of your consent or due to the fulfillment of a legal obligation has disappeared
- Opposition to the process: In certain circumstances and for reasons related to their particular situation, the holders may object to the processing of their data (for example, when the process is for the purpose of direct marketing). Citogen will no longer process the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
- Data portability: under certain circumstances, the right to receive the personal data that they have provided to Citogen, in a structured, commonly used and machine-readable format, so as to transmit them to another Data Controller.
- Limitation of process: in certain circumstances, the owners of the data may request the limitation of the processing of their data (suspension of the process that in each case corresponds), in which case the data shall be retained only for the exercise or defense of the of claims.
- Revocation of consent: at any time, the holder of the data may revoke consent given in a data processing operation.
To exercise all these rights, you can contact us through the remittance of a letter including in the same the ‘Ref. Data Protection´, in which the corresponding request is specified and accompanied with a photocopy of the D.N.I. to: Avenida Diagonal Plaza 40, 50197 Zaragoza (España) or by e-mail to email cagt@cagt.es
In accordance with the applicable regulations, you will also be entitled to file a complaint with the Spanish Agency for the Protection of Personal Data, if deemed necessary, especially when you have not been satisfied in the application of your rights and how to get in contact with them. For more information you can visit the website of the Spanish Agency for the Protection of Personal Data (Agencia Española de Protección de Datos), www.agpd.es
