This Policy explains what personal data we process, for what purpose, on what legal basis, for how long, and what rights you have. It is part of the contract along with the Legal Terms, Informed Consent, and Cookie Policy.
Informed Consent elaborates in detail on the processing of the animal's sample, results, and voluntary options, and prevails over this Policy in those matters.
Data Controller: GENELINK, S.L., owner of the Koko Genetics™ brand. NIF B98649494. Address: calle Arquitecto Mora 5, 2nd floor, apartment 4, 46010 Valencia, Spain.
Koko Genetics, tellmeGen and Vivabioma are brands of GENELINK, S.L. and may share corporate infrastructure and support channels. This does not authorize the combination of data from their services: any combination requires prior information and a valid legal basis or, where applicable, a specific voluntary option.
The service is organized from Spain and we apply Regulation (EU) 2016/679, Organic Law 3/2018 and Law 34/2002 on information society services.
Applies to those who visit the Web, create an account, contract our services, participate in promotions or raffles, use genetic matching functionalities, or communicate with our support team.
3.1 Your animal's DNA, considered in isolation, is not personal data of a natural person within the meaning of the Regulation and does not inform you about your own genetics or health.
3.2 However, the kit identifier, ownership or care of the animal, your account, your contact details, questionnaires, messages, and results linked to you do constitute your personal data and are processed in accordance with the Regulation.
3.3 The method is directed at the DNA of the species analyzed. We do not look for or interpret human DNA; any incidental human signal is not interpreted or incorporated into a report.
4.1 Data Categories:
4.2 Source. The data comes from you or is generated during the provision of the service. We do not acquire personal data from external sources to profile you.
When processing is based on your consent, you can withdraw it at any time without affecting the lawfulness of previous processing. When it is based on our legitimate interest, you can object and we will consider your particular situation; the weighing analysis is available to you by writing to dpo@tellmegen.com.
6.1 Participation is voluntary, separable, and revocable, and does not condition the service or its price. It is authorized separately for internal research and improvement, for external scientific projects, and for research and development with commercial collaborators.
6.2 When you authorize it, we may use the analysis data and, where applicable, your questionnaire responses, in minimized, pseudonymized, or anonymized form, to develop, train, validate, and improve analytical models and artificial intelligence systems.
6.3 Participating third parties receive pseudonymized or aggregated data, under contract and with an express prohibition of re-identification.
6.4 These authorizations refer to data, not to the physical sample: any research use of the sample requires separate consent.
6.5 You may withdraw any of the authorizations as easily as you granted them. Withdrawal prevents new inclusions and ends future processing based on it, but does not affect lawfully processed data, already published publications, irreversibly anonymized data, or already trained models.
7.1 Koko Genetics services are aimed at people over 18 years of age, who are the ones who can contract and register a kit.
7.2 In the Web forms aimed at the general public, and in accordance with Spanish regulations, children under fourteen years of age must not provide their personal data without the consent of the person exercising parental authority or guardianship. If we detect that data has been provided in these circumstances, we will delete it as soon as possible.
7.3 Participation in promotions and sweepstakes is reserved for people over 18 years of age.
8.1 If you request the deletion of the technical analysis data, updates and reinterpretations will no longer be possible without a new sample. We will warn you before executing it.
8.2 When you request the deletion or close your account, the information we must retain due to legal, tax, quality, or defense against claims obligations is blocked, with restricted access, without use for any other purpose, and is deleted upon expiry of the applicable period.
8.3 Backups are deleted or overwritten according to their ordinary cycles, with a maximum objective of 30 days from operational deletion.
9.1 We do not sell or rent your personal data. We may disclose it to the following categories of recipients:
9.2 All processors are bound by contract in accordance with Article 28 of the Regulation, with appropriate technical and organizational measures. Replacing a provider does not extend the purposes or reduce your rights.
9.3 You may request the specific list of current processors and sub-processors at any given time, with their location and function, by writing to lopd@tellmegen.com.
10.1 Data analysis and storage are carried out in the European Economic Area, with providers identified in the list in section 9.3.
10.2 If any ancillary function involves processing outside the European Economic Area, we will apply adequate safeguards: an adequacy decision from the European Commission, standard contractual clauses with impact assessment and complementary measures, or binding corporate rules. The transfer will be identified in that same list.
10.3 You may request information about the safeguards applied and, where applicable, a copy of them, by writing to dpo@tellmegen.com.
11.1 Animal matching functionalities are deactivated by default and require separate activation. Before activating them, you will be informed of which elements of your profile other users will see and how messaging works.
11.2 Your contact details are not revealed to other users without further unequivocal action on your part.
11.3 You can deactivate the function at any time. Deactivation stops new visible matches and removes your profile from the active index, but it does not delete messages or notifications that another user may have already lawfully received.
11.4 We may apply automated filters and human review to detect fraud, abuse, or illicit content, and to limit visibility, remove content, or suspend accounts, informing you of the reason and the means of appeal when required by law.
12.1 In promotions and sweepstakes, we may collect your name, email address, relevant social network profile, and the data necessary for prize management and delivery.
12.2 Winners are selected using online sweepstakes tools and are announced or contacted through the channels indicated in the rules. If they do not respond or provide delivery details within the timeframe specified in the rules, the prize may be reassigned.
12.3 For physical prizes, we may request a shipping address, which will be used solely for that delivery.
12.4 Subscription to commercial communications is always optional and separate from participation: it does not condition access to the sweepstakes.
12.5 We may exclude a participant in case of fraud or non-compliance with the rules, with justification.
We may send you information about products or services from Koko Genetics when you have consented or when it concerns products or services similar to those you have already contracted. You may object at any time, simply and free of charge, from the link included in each communication or by writing to lopd@tellmegen.com.
14.1 We use technical and analytical cookies and, only with your consent, advertising cookies. On the first level of the panel you can accept, reject or configure your preferences, and change them whenever you want. The details are in the Cookies Policy.
14.2 For analytical and advertising functions, we share information with our partners, including Google, in accordance with their European Union User Consent Policy.
14.3 These tools do not in any case access your animal's sample, your analysis data, or the content of your reports.
15.1 We apply technical and organizational measures appropriate to the risk, suited to the state of the art, the nature of the data and the existing risks: encryption in transit and at rest, logical separation of identifiers, role-based access control, logging and monitoring, incident management, and privacy by design and by default.
15.2 No information system is completely immune to risks. If a security breach occurs that poses a high risk to your rights, we will inform you without undue delay, stating the nature of the incident, its possible consequences, and the measures taken.
16.1 You may exercise your rights of access, rectification, erasure, restriction of processing, data portability, and objection, withdraw any consents you have given, and not be subject to decisions based solely on automated processing with legal or similar effects.
16.2 To exercise them, write to lopd@tellmegen.com or by postal mail to GENELINK, S.L. (reference: Data Protection), calle Arquitecto Mora 5, 2nd floor, door 4, 46010 Valencia, Spain. We may ask you for reasonable proof of identity when there is reasonable doubt, without requiring unnecessary documentation.
16.3 We will respond within one month, extendable by two additional months if the request is complex, informing you of the extension within the first month.
16.4 The exercise is free of charge, except for manifestly unfounded or excessive requests, particularly repetitive ones, in which case a reasonable fee may be charged or the action may be refused, with justification.
16.5 You may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the supervisory authority of your country of residence.
17.1 GENELINK may be subject to corporate operations such as a merger, spin-off, financing, or the total or partial transfer of the business, including the separate transfer of the Koko Genetics brand.
17.2 In the preliminary negotiation and audit phases, only strictly necessary aggregated, statistical, or pseudonymized data may be shared, under a confidentiality agreement and access control. Individually identifiable files will not be provided in any case.
17.3 If the operation materializes, the acquiring entity will be subrogated as the data controller and will be bound by the Informed Consent and by this Policy, without expanding the purposes. We will inform you without undue delay and, whenever possible, before they begin to process your data.
17.4 For materially different purposes, the new controller must inform you and obtain a valid legal basis or, where applicable, new consent.
17.5 In the event of bankruptcy or liquidation, your data may only be transferred within the framework of service continuity and with equivalent guarantees; otherwise, it will be deleted or anonymized, except for mandatory retention archives. These rules do not authorize by themselves an autonomous sale of personal data or samples.
18.1 We may update this Policy due to legal, technical, or service changes. Each version has a code and date, and you may request the version history from lopd@tellmegen.com.
18.2 If the change expands the purposes, data categories, or recipients, or affects any of your consents, we will notify you before it takes effect and, where appropriate, we will ask for your new affirmative action. We will not apply new purposes to data already collected without that basis.
18.3 We retain proof of each consent given, with the version of the text shown to you, the date and time. You can consult and download it from your account.
For any questions regarding this Policy, you can write to lopd@tellmegen.com or, for matters requiring the intervention of the Data Protection Officer, to dpo@tellmegen.com.
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