GENOSOPHY places particular importance on protecting the privacy and personal data of its customers, users, partners and website visitors.
This Privacy Policy explains how we collect, use, store and protect personal data, including, where applicable, genetic data and health-related information.
Personal data are processed in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation or “GDPR”), Greek Law 4624/2019, Greek Law 3471/2006 and other applicable Greek and European data-protection legislation.
The Data Controller responsible for the processing of your personal data is:
GOUSKOU – ILIOPOULOS PRIVATE COMPANY (I.K.E.)
Trading name: GENOSOPHY P.C.
Registered address: 28 Voriou Ipirou Street, Athens 10444, Greece
VAT No.: EL 802105888
G.E.MI. No.: 170056501000
Email: info@genosophy.gr
Telephone: +30 698 326 7994
Website: www.genosophy.gr
For any matter relating to the protection of your personal data or the exercise of your data-protection rights, you may contact us at info@genosophy.gr.
This Policy applies to personal data processed in connection with:
Depending on the services you use, we may collect the following categories of information.
Identity and contact information, including your name, date of birth where required, sex where relevant to the analysis, postal address, email address and telephone number.
Order and transaction information, including the product or service purchased, order number, delivery and billing information, payment status and transaction history.
GENOSOPHY does not necessarily receive or store full payment-card details where payments are processed by an independent payment-services provider.
Biological sample information, where you undertake a genetic test, including buccal cells or other biological material collected in accordance with the applicable test instructions and the unique identifier associated with the sample.
Genetic data, including genetic variants, genotypes, polygenic scores, genetic-analysis results and other information derived from the analysis of DNA.
Health and lifestyle information, where relevant to the service and provided by you, including information concerning diet, physical activity, personal or family history and other factors relevant to interpretation of the analysis.
Communications, including messages, support requests, enquiries and other correspondence with us.
Technical information, including IP address, browser and device information, website-use information and cookies, as further described in our Cookie Policy.
Genetic data and data concerning health constitute special categories of personal data and receive enhanced protection under the GDPR.
Where processing of such data is based on your consent, GENOSOPHY obtains your explicit consent before carrying out the relevant processing.
Consent to the processing of genetic or other special-category data is separate from any consent you may provide for marketing communications or non-essential cookies.
You may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing undertaken before withdrawal and may mean that we can no longer provide a service that necessarily depends on processing those data.
We may process personal data in order to:
Depending on the circumstances, we process personal data on the basis of:
Performance of a contract, where processing is necessary to manage your order or provide a service you requested.
Compliance with a legal obligation, including tax, accounting and regulatory requirements.
Your consent, in particular for non-essential cookies, certain marketing communications and, where applicable, processing of genetic or health-related information.
Our legitimate interests, where permitted by law, including information-security measures, fraud prevention, management of legal claims and improvement of our operations, provided that your rights and freedoms do not override those interests.
Processing of genetic and health-related information is also subject to the additional requirements applicable to special-category data under Article 9 GDPR.
Each biological sample is, wherever reasonably possible, associated with a unique identifier so that laboratory processing does not require direct use of your name.
Access to information capable of linking a sample to an identifiable individual is restricted to authorised personnel and service providers who require that information for the provision of the service.
Biological samples are retained only for the period necessary to complete the analysis, perform appropriate quality-control procedures and comply with any applicable legal or scientific obligations, after which they are securely destroyed unless another lawful basis or separate consent permits longer storage.
Before publication, GENOSOPHY should confirm that this paragraph accurately reflects its actual sample-retention and destruction procedure.
GENOSOPHY does not use your genetic data for advertising targeting.
Identifiable genetic data are not used for independent research or other unrelated secondary purposes without an appropriate legal basis and, where required, separate information and consent.
Anonymous information from which an individual can no longer reasonably be identified may be used for statistical analysis, methodology development or scientific purposes in accordance with applicable law.
We do not disclose personal data to third parties except where necessary and lawful.
Depending on the service, recipients may include:
Service providers processing personal data on our behalf are subject to appropriate contractual data-protection obligations.
GENOSOPHY does not sell personal, genetic or health information to advertisers, insurers or employers.
We do not disclose your genetic results to an employer, insurance company or other third party without an appropriate legal basis or your express authorisation, unless disclosure is required by law.
Where possible, we use providers processing personal data within the European Economic Area.
Where personal data are transferred outside the EEA, we use appropriate safeguards required by the GDPR, such as an adequacy decision of the European Commission, approved Standard Contractual Clauses or another legally recognised transfer mechanism.
We do not retain personal data longer than necessary for the purposes for which they were collected.
Retention periods are determined by reference to:
Information used solely for marketing is retained until consent is withdrawn or you object, except where limited continued retention is necessary to demonstrate compliance.
When information is no longer required, it is securely deleted, anonymised or destroyed.
Given the particularly sensitive nature of genetic information, we apply appropriate technical and organisational safeguards.
Depending on the relevant system and processing operation, these measures include:
Although no information system can provide absolute security, we apply safeguards proportionate to the nature and sensitivity of the information we process.
Results are provided to the person who underwent the genetic analysis or to a person who has been appropriately authorised.
Where a test is carried out through a healthcare professional or authorised partner, access may also be provided to that professional to the extent necessary and where such access has been agreed or authorised.
GENOSOPHY may use algorithmic and computational tools to process and interpret genetic information by combining and evaluating genetic variants.
These processes may include the generation of genetic or polygenic scores and personalised results.
Such tools are used in the provision of the service and are not used to make decisions producing legal effects concerning you, or similarly significantly affecting you, solely through automated processing.
Where a genetic test concerns a minor, the order, sample collection and processing of information are carried out only with the appropriate authorisation of a parent or legal guardian and in accordance with applicable law.
GENOSOPHY does not knowingly seek to collect or process a minor’s genetic information without the required lawful authorisation.
Where you have provided the relevant consent, or another lawful basis permits such communication, we may send you information about GENOSOPHY services, products or developments.
You may unsubscribe at any time by using the unsubscribe mechanism included in electronic communications or by contacting info@genosophy.gr.
Withdrawal from marketing communications does not affect any genetic testing or other service you have purchased.
Our website uses cookies and similar technologies.
Certain cookies are necessary for the operation of the website and online store. Other cookies, including analytics or advertising cookies, are activated in accordance with your consent choices.
More information is available in the separate GENOSOPHY Cookie Policy.
Subject to the conditions set out by applicable law, you have the right to:
Certain rights may be subject to lawful limitations, for example where retention is necessary to comply with a legal obligation or to establish, exercise or defend legal claims.
To exercise any data-protection right, please contact:
We may request information reasonably necessary to verify your identity before fulfilling a request concerning personal or genetic information.
If you consider that the processing of your personal data infringes applicable data-protection law, you have the right to lodge a complaint with the:
Hellenic Data Protection Authority
1–3 Kifisias Avenue
115 23 Athens, Greece
Tel.: +30 210 6475600
Email: complaints@dpa.gr
You are also welcome to contact us first at info@genosophy.gr so that we can investigate your concern.
GENOSOPHY may update this Privacy Policy when its services, processing activities or applicable legal requirements change.
The current version will always be made available on our website and will state the date on which it was last updated.
