Privacy Policy

Effective from: 24/01/2022, Version: 1.0

This Personal Data Protection Policy (hereinafter referred to as the " Personal Data Protection Policy " or " Policy ") describes the way in which Macromo s.r.o., with its registered office at Jeseniova 2760/56f, Žižkov, 130 00 Prague 3, ID: 14031493, a company registered in the Commercial Register of the Municipal Court in Prague, under no. C 359192 (hereinafter referred to as " Macromo " or " we ") collects, processes and protects your personal data. Macromo is committed to protecting your personal data in accordance with applicable data protection laws and regulations, such as GDPR.

This Privacy Policy applies to the processing of personal data in all services, applications and websites operated by Macromo that process personal data and that contain or link to this Policy. They apply to the processing of personal data of visitors to our website, users of our services and also representatives of our business partners and persons who contact us through our website or in any other way. This privacy policy applies to cases where Macromo processes personal data as a data controller.

In the event of any conflict between this Privacy Policy and the specific privacy policy applicable to any Macromo product or service, the specific privacy policy shall prevail.

In no case does Macromo process your personal data for the purpose of providing health services or medical advice. The information provided on the Macromo website is for informational purposes only. Always consult your doctor about your medical condition.

The provisions of this Privacy Policy apply as of the above-mentioned effective date.

I. What data do we process?

When you create an account on the Macromo website, visit our website, order goods from our e-shop, subscribe to the newsletter or create a user account in our application, we may process the following categories of personal data:

• identification data: for example, first name, last name, nickname, date of birth
• contact information: address, phone number, email
• information about whether you have subscribed to the newsletter,
• information about your preferences and behavior on the website,
• payment information,
• information about your DNA and health status
• information about your racial or ethnic origin
• any other information you choose to share with us.

II. How do we process your data?

When you create an account on the Macromo website or in the Macromo application, we process your data that is necessary to create your account, such as first name, last name, email address, etc. At Macromo, we also process the data needed to process your order, this data may include your contact, identification and payment data.

By ordering goods or creating an account in the Macromo application or the Macromo website, you enter into a contractual relationship with Macromo. The legal basis for the processing of this personal data is the performance of a contract or pre-contractual relations within the meaning of Article 6 (1) b) GDPR.

With regard to the services we provide you, we will process the information we obtain from your genetic analysis, which will be performed for us by our contracted laboratory. The DNA is extracted in the laboratory from the sample you provide us and converted into a machine-readable code that is used to provide our genome analysis services. This information may include information about your health, genetic information, and information about your racial or ethnic origin. We also process the DNA test kit code for pairing with our app. We may also process other information that you provide to us through questionnaires that you can fill out. This information represents a special category of personal data within the meaning of Article 9 (1) of the GDPR, and therefore we process it on the legal basis of your explicit consent according to Article 9 (2) a) of the GDPR, whereby you already give this consent when placing an order on our website . You can withdraw your consent at any time by contacting us at info@macromo.org, but withdrawing this consent will result in us not being able to provide you with the services you have ordered. Please keep in mind that the processing of your health information, genetic data and data indicating racial and ethnic origin is necessary for the provision of our services.

Macromo may use your data for marketing purposes, i.e. if you subscribe to our newsletter or other marketing communications. This communication is carried out in accordance with applicable legal regulations. Advertising and marketing communications will only be sent to you if you have opted-in to receive such communications or have not declined it, via email on our website or by other means. The legal basis for the processing of your data for marketing purposes is your consent in the sense of Article 6 (1) a) GDPR, or § 7 paragraph 3 of Act No. 480/2004 Coll. about some information society services. In the case of personalized marketing communication, the legal basis for the processing of your data for marketing purposes is your express consent according to Article 9 (2) a) GDPR.

You can withdraw your consent to receive marketing newsletters at any time by using the unsubscribe option in the footer of each email or other form of electronic communication. Opting out can also be done by contacting Macromo directly at info@macromo.org. If you opt out, Macromo will retain only such data as is necessary to provide you with services in accordance with the rules set forth in this Policy.

In some cases, legal regulations impose obligations on us on the basis of which we are obliged to process your personal data, such as tax and accounting laws, anti-money laundering laws and the provision of certain data to public authorities on the basis of law. This means that we may process your personal data in order to ensure compliance with these obligations. The legal basis for the processing of such personal data is compliance with legal obligations within the meaning of Article 6 (1) b) GDPR.

III. Cookies and other monitoring technologies on our website.

Our website uses cookies to collect information about people who visit our website. Cookies are small encrypted text files that are stored on your computer or other device. Cookies help us operate our website, provide important functions and features on our website. They help us understand how our website is used. At the same time, we use cookies for statistical and analytical purposes, for example to track and monitor from which country, which pages and how they were used to visit our website, as well as to enable personalization.

We use the following types of cookies:

(i) essential (necessary) cookies, which are necessary to ensure access to our website and to provide the services you have expressly requested, enable basic website functions such as tagging your data inputs, network management and accessibility; (if these cookies are disabled, our website may not function properly);

(ii) analytical (performance) cookies help us analyze how you navigate our website and what content is relevant to our users. Based on them, we are able to track users' navigation on our website/in our application (we track automatic events, custom events and event logging and store them in a database in real time). Analytical and performance cookies are also used to measure and improve performance.

(iii) functional cookies allow us to remember choices you have made in the past, such as which language and currency you prefer, remember your name and email and automatically fill in forms and enable personalization, such as live chats, videos and social media use such as Hotjar, Leady.cz;

(iv) advertising cookies that help deliver tailored and tailored advertising to users, such as Google Analytics, Google Tag manager, Facebook Pixel, LinkedIn Insight Tag, TikTok Pixel and UET Tag.

Through cookies, we may collect the following information: IP address, gender, time zone, browser settings, operating system, information about website visits including URL, search terms, information about what you viewed or searched for on our website, time page responses, download errors, length of visits to certain pages, information about page interaction (such as scrolling, clicking and hovering).

When you visit our website, you will be informed by the cookie banner at the bottom of the website that we are collecting cookies. This banner allows you to manage what cookies Macromo may collect. You can change your settings at any time and withdraw your consent through the privacy settings at the bottom of our website.

If we store data or gain access to data already stored on your terminal device, such as a computer or mobile device, for analytical, functional or advertising purposes, we do so only on the basis of your consent in the sense of Article 6 (1) a) GDPR.

When collecting basic cookies, the legal basis for processing this data is a legitimate interest in the sense of Article 6 (1) f) GDPR. It is not possible to disable these cookies through your privacy settings, as our website may not function properly if this type of cookie is disabled, however, if you still wish to do so, you can follow the instructions below in Blocking cookies.

If you do not want us to use cookies, you can withdraw your consent for individual types of cookies at any time after granting it or give it again on the page dedicated to managing consent to cookies, which is available in the footer of our page under the name Manage consent to cookies.

Blocking cookies

If you do not wish cookies to be collected, you can limit, block or delete them at any time by adjusting your browser configuration. Although each browser has different parameters, cookie configuration is usually found in the "Preferences" or "Tools" menu. If you disable cookies, the functionality of our website may be limited (in the case of essential cookies, you may not be able to access our website).

If you wish to prevent the installation of new cookies, or if you wish to delete existing cookies, please refer to the links below for instructions. The exact procedure depends on which browser you are using:

• Internet Explorer: Here
• Firefox: Here and here
• Google chrome: Here
• Safari: Here

For mobile devices, you can limit tracking through your device's privacy settings (by turning off the advertising identifier), see https://www.networkadvertising.org/mobile-choice/ for instructions.

In addition, you can use a third-party tool to opt out of targeted advertising. Third-party opt-out tools available include the Digital Advertising Alliance, the Network Advertising Initiative, and the European Interactive Digital Advertising Alliance (Europe only).

To opt out of receiving cross-device website advertising (i.e. tracking a user across devices), you can access your device settings or visit and use the controls described on the NAI Mobile Choices page.

IV. How long will we process your data?

In general, personal data is kept for as long as is necessary for the purpose for which it was processed. The period for which Macromo will store your personal data also depends on the legal basis on which your data is processed. If the processing is based on a legitimate interest, your data will be processed for the duration of the given legitimate interest of Macromo. In the case of data stored on the basis of legal obligations, the data retention period is determined by applicable legal regulations. For data processed on the basis of the performance of the contract, the data is processed for the duration of the contractual relationship and for the relevant limitation period. If the processing is based on your consent in the sense of Article 6 (1) a) GDPR, your personal data will be deleted after withdrawal of consent. You can withdraw your consent to the processing of personal data at any time by sending a message to info@macromo.org. Please keep in mind that the same data may be processed on the basis of several legal bases, in which case your withdrawal of consent or request for deletion of personal data may not mean complete deletion of your personal data. Revocation of consent does not affect the legality of processing based on consent granted before its revocation.

Macromo will not collect excessive amounts of Personal Data or other information that is not relevant to the purposes for which the Personal Data is collected.

If you create an account on our website or in the application, we will process your personal data for the duration of this registration. You can request the deletion of your account at any time.

V. Data sharing, processors and transfers to third countries

Your personal data will not be shared with any third party except in the following situations:

• the data is necessary for the provision of Macromo services,
• based on your consent,
• entrusting personal data to processors who process personal data on behalf of Macromo,
• Macromo is obliged to provide personal data based on the law or on the order of a public authority.

Processors

Macromo uses the services of verified suppliers (hereinafter referred to as "Processors") who assist us in providing our services. These Processors process your personal data based on instructions from Macromo. At Macromo, we use the following categories of Processors:

• hosting,
• analytical tools,
• marketing tools,
• IT tools,
• our contractors and other partners who help us provide our services (including laboratories that will analyze your DNA),

Transfers to third countries

In some cases, Macromo may transfer your data to countries outside the EU/European Economic Area. Such a transfer can only take place if it is in compliance with the GDPR. This means, for example, that the provider is based in a country for which the European Commission has issued a decision that it provides an adequate level of personal data protection, or that standard contractual clauses issued by the European Commission and/or other transfer mechanisms are in place that ensure adequate safeguards with regard to the protection Your personal data. It may be necessary to apply certain additional measures to provide the data subject with a level of protection essentially equivalent to that guaranteed by the GDPR.

You have the right to receive a copy of the Standard Contractual Clauses ("SCC") that we have entered into with our Processors who are established outside the EU/EEA and who are used to transfer personal data outside the EU/EEA. If you wish to obtain a copy of the SCC applicable to a specific transfer of your personal data, please contact us at info@macromo.org.

VI. Data security

Macromo is committed to ensuring that your personal data is stored securely. Therefore, Macromo has taken appropriate technical and organizational measures to secure personal data processed by Macromo, including e.g.:

• data encryption,
• use of passwords and other barriers when accessing user data (several levels of system logs, strong password policy)
• the implementation of sufficient physical barriers when entering the premises where data is stored (entry control),
• automated and manual QA tests,
• two-factor authentication when logging into the development environment.

These measures do not release you from the obligation to take appropriate measures to secure your personal data. Among other things, you should regularly change your passwords. On the other hand, you should not, among other things, use predictable usernames and/or passwords, share your passwords with other persons or provide access to your administrator account and/or share your personal information with others. Macromo will never ask you for your password in any unsolicited communication. Notify us immediately of any unauthorized use of your administrator account or any other suspected breach of security.

VII. Your rights

In terms of the EU General Data Protection Regulation 2016/679 ("GDPR"), you are entitled to the following rights:

Right of access

You have the right to be informed, among other things, about what personal data Macromo processes about you, for what purposes and who are the recipients of your personal data. If you wish to receive such information, please contact us via our email info@macromo.org. If we process your personal data, we will provide you with the following information:

• purposes of processing this data,
• category of personal data concerned,
• recipients or categories of recipients of your personal data,
• if possible, the period for which your personal data will be stored, or at least the criteria that determine this period,
• the existence of the right to request from the administrator the correction or deletion of personal data or the restriction of the processing of personal data concerning the data subject or to object to such processing,
• the right to lodge a complaint with the supervisory authority,
• information about the source of your personal data that is not obtained directly from you, and
• information about the existence of automated decision-making, including profiling

Right to rectification (addition)

You have the right to correct any incomplete, inaccurate or out-of-date personal data about you.

Right to erasure (to be forgotten)

You have the right to delete some of the personal data we have collected and processed about you without undue delay. Please note that Macromo may be entitled or even obliged to retain some personal data despite your request for deletion. These are especially situations where we have to process your personal data to fulfill legal obligations or to determine, exercise and defend legal claims.

Right to restriction of processing

In given cases, such as

• if you question the accuracy of the personal data, for a period that allows us to verify the accuracy of the personal data,
• the processing is unlawful and you do not agree to the erasure of your personal data and request the restriction of their use,
• We no longer need your data for processing purposes, but your personal data are needed for the determination, exercise or defense of legal claims,
• you have objected to processing in connection with profiling until it has been verified that our legitimate grounds outweigh yours.

you can request the restriction of processing.

Right to data portability

You have the right to receive the personal data that you provide to us in a structured, commonly used and machine-readable format and to request that it be transferred to another controller if technically feasible. Please note that the right to data portability only applies to data that you have provided to us and that we process as a controller based on your consent or performance of a contract.

The right to object

For reasons relating to your particular situation, you have the right to object at any time to the processing of personal data concerning you that is carried out in the public interest or for the purposes of Macromo's legitimate interests, including profiling.

The exercise of your rights may be limited if Macromo is required to retain any of your personal data for the purposes of fulfilling legal obligations, for the determination, exercise or defense of legal claims or for other serious reasons established by applicable data protection legislation.

The right not to be subject to automated individual decision-making

You have the right not to be the subject of a decision based solely on automated processing, including profiling, which has legal effects on you or similarly significantly affects you. This does not apply if the decision:

• is necessary for the conclusion or performance of the contract between you and Macromo
• is permitted by law and the law provides appropriate measures to protect your rights and freedoms and legitimate interests; or
• is based on your express consent.

Macromo does not make decisions based solely on automated processing that would have significant effects on its users. For completeness, Macromo uses cookies and similar technologies, the use of which may constitute profiling. Information on how to withdraw your consent to the use of cookies or disable cookies can be found in Chapter III. The cookies of this Privacy Policy.

The right to file a complaint

If you believe that your data has been processed unlawfully, please contact us and we will try to resolve the issue. According to the GDPR, you have the right to file a complaint with the Office for the Protection of Personal Data, which is located at the address Pplk. Sochora 27, 170 00 Prague 7, Czech Republic.

VIII. Contact information

If you wish to exercise any of your rights listed above, please contact us at info@macromo.org.

If you would like to learn more about Macromo, its privacy practices, or this Privacy Policy, you can contact Macromo at info@macromo.org.

Please help Macromo to keep your data up-to-date. If you believe that any data processed by Macromo is incorrect, or if you believe that Macromo is not following this Privacy Policy, please contact Macromo at info@macromo.org.

IX Final Provisions

Our website, services and applications are not intended for persons under eighteen (18) years of age. If you are under the age of eighteen, do not provide your personal information to Macromo. We do not knowingly collect any personal information from children under the age of eighteen on the Website. Users under the age of eighteen (18) (or the age of majority in the applicable jurisdiction) should not use Macromo's Websites, Services and Applications without the permission of a parent or legal guardian.

Macromo may change this Privacy Policy at any time. If there is a change to this Privacy Policy, we will post the changes on our website and/or in other places we deem appropriate. We may, but are not obligated to, send you an email or other notice of such change, but you should review this Privacy Policy from time to time for material changes to its text.