Privacy Policy

The purpose of this Privacy Policy (the “Policy”) is to inform you of the ways by which we collect, use and process your information when using our Service. We advise you to carefully review this Policy, as well as the Shafra Terms and Conditions (the “Terms”), which can be found here.

Note that all defined terms used in this Policy possess the same meaning given to them in the Terms, unless expressly defined below.

Upon using our Service, you are requested to accept our Terms. This Policy constitutes an integral part of the Terms; therefore, you may only use the Service upon acceptance. If you do not accept the provisions contained in this Policy or in our Terms, you may revoke your acceptance by discontinuing your use of our Service at any time.

1. Definitions

  • The preceding paragraphs shall constitute an integral part of these Terms and shall be read and construed in light of them.
  • The following capitalised terms, when used in these Terms, shall have the respective meanings set out below unless a different meaning is expressly stated:

De-identified Information

means information that has been coded and any Registration Information or other identifying data is removed such that you cannot reasonably be identified as an individual.

Genetic Information

means information regarding your genetics, as derived from your saliva sample and generated by Shafra.

Login Information

means Information used to access your Shafra Account, such as your own user ID and password.

Privacy Policy

means our Privacy Policy, as contained in this document and amended from time to time;

Registration Information

means all information provided by yourself when registering for a Shafra Account. This may include, your name, email, address, user ID, password and payment information;

Shafra Research

means research conducted by Shafra using your Genetic Information as concluded by the Service.

Your participation in this Research is voluntary and subject to your express consent and acceptance of such participation in our Consent and Acknowledgment Form.

Terms

means the Terms and Conditions of Shafra, and as amended from time to time.

2. Collection of Information

  • By using our Service, you may be prompted to provide information directly to us.
  • This information includes: 

    Registration Information:

    When you create a Shafra Account, we request certain information in order to complete the registration process. This information is personal in nature and enables us to identify you as a Registered User. We may ask for details such as your name, date of birth, billing and shipping address, payment information and contact information.

    Customer Service:

    When you contact our customer service team for reasons, including but not limited to, resolving issue, requesting further information or asking questions about the Service, you agree to provide us with additional information we may request. This information is used in order to adequately respond to or resolve your enquiry.

    Saliva Sample:

    Our Service involves the extraction of your saliva sample. This shall be done by you, in accordance with our instruction manual provided in the DNA Kit. The process of obtaining a DNA Kit from Shafra is detailed in Clause 2 of our Terms.

  • From the sources of information, you provide to us directly, we may indirectly derive other types of information.
  • These types of information include the following: 

    Genetic Information:

    Once you provide us with your saliva sample, we will use to it to extract your DNA and undergo the genetic sequencing process thereafter. The information we obtain from such a process is Genetic Information. It can be stored in multiple formats, whether as raw data or as formulated reports, similar to those issued in your Shafra Report.

  • Other types of Information:

    As we are continuously enhancing our Service; therefore, we may request other types of Information in addition to those detailed above. All information we request will be collected and processed in accordance with this Policy, as amended from time to time.

3. Protection of Information

  • As soon as we collect your information, we implement highly technical and administrative measures in order to protect your information from any security breaches or unauthorized access.
  • In order to ensure that our security measures are consistently up to date, we regularly review and improve our tactics and methods of information protection.
  • The methods we apply include but are not limited to codification and limited access to essential personnel.
  • Codification is the industry standard process of storing data in the form of codes such that any information that may identify the Registration User, or any information that may be used to derive identity information is concealed and minimized to a code whereby the Registered User is unidentifiable.
  • Codification enables us to implement a further level of security, whereby access to information that may be used to gain access to the codes is limited only to essential personnel, whose access is reasonably necessary, in order to provide you with our Service. Such personnel include those responsible for formulating and preparing your Shafra Report.

4. Processing of Information

  • In order to provide you with the Service, it is essential for Shafra to share your information with third parties. We will only share your information in ways that are detailed in this Policy.
  • The reasons and ways by which we use and process your data are as follows:

    Account Registration and Communication

    • As detailed in our Terms, you must be a Registered User in order to use our Service. Therefore, the first way by which we process your information is to register your account and process payments.
    • We may also use your account to communicate with you regarding any notices that you may receive, any policy changes or security updates, promotions and other marketing strategies.
    • Your Registration Information may also be used to resolve your customer service complaints, issues or questions as necessary.

    Provision of Service

    • In order to provide you with our genetic sequencing services, we share your collected saliva samples with our Lab Partners.
    • We do not share your Registration Information with our Lab Partners. The saliva sample is collected by our Lab Partners in your DNA Kit, inclusive of your De-identified Information only. This enables Shafra to maintain and preserve the identity of all Registered Users.
    • We expressly allow our Lab Partners to extract your DNA from the saliva sample as this is an essential element of providing our service and deriving your Genetic Information. After processing and analysis, any remaining saliva or extracted DNA is immediately destroyed and discarded by our Lab Partners.
    • The Genetic Information derived by our Lab Partners is issued in the form of raw data. Thereafter, we formulate your Genetic Information in such a way that is accessible and user-friendly, as issued in your Shafra Report.

    Shafra Research

    • Upon consenting for the service as a whole, you are presented with an option to participate in Shafra Research. Your participation in this research is voluntary and wholly based on your consent. In addition, your consent is flexible such that you may withdraw your consent at any time, as detailed in Clause 6 below.
    • Shafra research may be conducted by Shafra with its own resources and at its own accord, by Shafra in collaboration with third parties, or by third parties with the use of Shafra resources. Your consent to participate in Shafra Research includes an express agreement by you, as a Customer, to have your information shared with such third parties who collaborate with Shafra for research purposes.
    • For research purposes, Shafra will only share De-identified Information. However, Shafra reserves the right to use Registration Information and Genetic Information in the preparation of reports, summaries, statistics or studies in preparing bundles of De-identified Information for research purposes.
  • Other reasons we may share your information with third parties are as follows:

    Shipping Services

    • We collaborate with third party service providers in order to provide you with the delivery and collection services of the DNA Kits. Our courier service provider ships your DNA Kit to you and return them safely to our Lab Partners.
    • We share your information with such service providers to the extent necessary to enable us to serve you in the most efficient way possible. This information includes Registration Information such as your name, number, shipping address and contact information.

    Legal requirements

    If so required by the laws, regulations, or official authorities, Shafra reserves the right to disclose any and all of your information in compliance with such orders and to the extent necessary to discharge its legal obligations.

    Assignment

    If Shafra undergoes any business transaction in which a portion of its assets are transferred, all of your information constitutes part of such transferrable assets. However, if such a transaction occurs, your information will be collected and processed in accordance with this Policy until such time as it is amended or modified.

5. Customer Responsibility

  • In order to access your Shafra Account, you will have access to your Login Information. By using our service, you acknowledge and accept that you must be responsible for safeguarding your Login Information. If you lose access to your Shafra Account, you may follow the procedure available on Shafra.me to recover your lost Login Information.
  • If you suspect any breach or unauthorized use of your Shafra Account, you must notify us immediately. Shafra will not be held liable for any information that you release at your own accord.
  • Any material downloaded or otherwise obtained through the use of the services is at your own discretion and risk and you will be solely responsible for any damage to your computer system, loss of data or breach of privacy that results from the download of any such material.
  • In addition, you are wholly responsible for ensuring that the information you provide is updated, accurate and complete.

6. Withdrawing your Use of the Service

  • If you no longer wish to use the Service or this Policy or the Terms are unacceptable to you, you may delete your account at any time. This will result in the deletion of all your Registered Information, as well as any other Genetic Information contained in your Shafra Report as stored in our database.
  • Account deletion is a permanent action that cannot be cancelled or withdrawn. The account and information contained within it cannot be recovered after deletion. Shafra will not retain any of your information, except if it was used in previously published research or if it was legal required to retain your information for a certain period of time.
  • If you wish to continue using the service but wish to withdraw your consent to Shafra Research by contacting us. By withdrawing your consent, Shafra will not use your Information in any upcoming research; however, if the research had already been conducted prior to your withdrawal and at a time in which your consent was valid, the Shafra Research will not be reversed and your information will not be removed from Such research.

7. Modifications to the Policy

  • Shafra reserves the right, from time to time, to modify this Policy. If we modify this Policy, we shall make it available through our website.
  • By continuing to access or use the Service after modifications become effective, you agree to be bound by the revised Policy. If any modifications are unacceptable to you, you may stop using our Services and delete your account at any time.

If you require any further information on our Service, please read our Terms here.

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