STRAITS GENOMICS SDN BHD and its affiliated companies (hereinafter referred to as “STRAITS GENOMICS” or “we “) is committed to protecting and respecting your privacy and is the data controller for your Personal Information under this Privacy Policy.

This Privacy Policy outlines how we collect, use, process, disclose, transfer, and store your Personal Information when you use our websites, mobile applications, and/or our genetic testing and sequencing services (collectively the “Services”). Please read this Privacy Policy carefully to understand how we treat your Personal Information and/or Genetic Data that we may obtain while providing our Services.

This Privacy Policy will help you understand the following:

1. Definition
2. What and How We Collect Your Personal Information
3. How We Use Your Personal Information
4. How Long We Keep Your Personal Information
5. How We Share and Disclose Your Personal Information
6. How Your Personal Information is Transferred
7. How We Protect Your Personal Information
8. Your Rights
9. How We Process Children’s Personal Information
10. How This Privacy Policy Is Updated
11. Contact Us

1) Definition

“Affiliated Company” refers to a company that is related to STRAITS GENOMICS due to joint ownership or control.

“Third Party” refers to a company or person who does not have a related relationship arising out of joint ownership or control with STRAITS GENOMICS (i.e., a non-affiliated company) or other non-related person, or the Customer who engage the Services from STRAITS GENOMICS (i.e., Clinician, Hospital, Health Professional, Healthcare Service Provider, University, Research Institution, Pharmaceutical Companies).

“Genetic Data” refers to personal data relating to the inherited or acquired genetic characteristics of a natural person which give unique information about the physiology or the health of that natural person and which result from an analysis of a biological sample from the natural person in question.

“Personal Information” refers to any information relating to an identified or identifiable natural person (“Personal Data Subject”), including Genetic Data. An identifiable natural person is one who can be identified directly or indirectly, by reference to an identifier such as a name, an identification number, location information, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Sensitive Personal Information” refers to any Personal Data that the leakage, disclosure, or abuse of which could easily endanger personal and property safety, and easily lead to the harm of one’s personal reputation and mental and physical health or lead to discriminatory treatment.

2) What and How We Collect Your Personal Information

The Personal Information can be collected by STRAITS GENOMICS directly from the Personal Data Subject or from a Third Party with the consent of the Personal Data Subject or were permitted by law.

STRAITS GENOMICS is responsible for the processing and treatment of Personal Information of you regarding to the Services entrusted to STRAITS GENOMICS. For the information which may constitute sensitive Personal Information in certain jurisdictions and regions, relevant terms and articles would be marked in bold for your special attention.

The Personal Information collected by STRAITS GENOMICS can include but is not limited to:

• full name, address and contact details
• job title and employer details
• date of birth
• gender
• weight
• height
• nationality
• identification
• banking information
• sample material involving Genetic Data
• any clinical information necessary for the purpose of the services or tests required, such as medical history (including any condition for which medical advice or treatment was sought, any form of consultation, investigation, prescription, or treatment), allergies, lifestyle habits, current medication
• family history
• other medical test results or findings necessary for conducting genetic testing or sequencing services

2.1) Information You Directly Provide to Us

Certain Personal Information concerning you including Genetic Data are collected directly from you by STRAITS GENOMICS.

STRAITS GENOMICS might collect the Personal Information in the following circumstances:

• when you fill in a contract or place a purchase order for one of our Services
• when we or our contracted local service provider issue you with a test request form for the purposes of conducting a genetic test
• when you sign up on our website for a STRAITS GENOMICS Customer Account
• when you sign up on our website for our newsletter
• when you sign up on our website to request a quotation and place an order of our Services
• when you submit a request for quote or send an enquiry via the contact forms on our website
• when you request us to claim insurance compensation on behalf of you
• when you fill in a contact form or consent to have your details recorded by us at a conference/event/tradeshow
• when you reply to an email from STRAITS GENOMICS that you have previously consented to be sent to you
• if you contact us or send us a message through social media channels

The information above may be necessary for the adequate performance of the contract or purchase order between you and STRAITS GENOMICS and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with relevant requested Services.

2.2) Information We Collect from Third Parties

To enable us to provide better Services to you, where permitted by applicable laws, we may collect your Personal Information indirectly from a Third Party.

We will put efforts to ensure the legitimacy of source of your Personal Information. However, please note that we do not control, supervise, or respond for how the Third Party processes your Personal Information. Any request regarding the disclosure of your Personal Information to us should be directed to such Third Party.

2.3) Information We Automatically Collect from You with Cookies and Similar Technologies

A Cookie is a plain text file that is stored on computers or mobile devices by web servers. The contents of Cookies can only be retrieved or read by its creating server. Every Cookie is unique to your web browser or mobile application. A Cookie usually includes identifier, site name and some numbers and characters. Using Cookies, a website can store data of user preferences or products in shopping basket, etc.

To ensure that our website is working normally and to personalize and customize your experience, we will use Cookies or similar tracking technologies, such as web beacons, pixels, and mobile identifiers to analyse trends, operate our website, track users’ movements around the websites, and to gather demographic information about our user base. We will not use Cookies for any purpose other than those stated in this Privacy Policy.

As true of most websites, our website gathers certain information automatically. This information may include Internet Protocol (IP) addresses, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our website (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyse trends in the aggregate and administer the site.

You may manage or delete Cookies based on your preferences. You can clear all Cookies on your computer and most web browsers have Do Not Track function. If Do Not Track is enabled on your browser, all our websites will respect your choice.

If you want to know more about how to change browser settings, please click the following links for popular browser software: Microsoft Internet Explorer, Microsoft Edge, Mozilla Firefox, Google Chrome, Safari for macOS and Safari for iOS.

STRAITS GENOMICS does use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics does make use of cookies to facilitate analysis of how users use the Site and to track Site traffic. This data does not identify individual users and STRAITS GENOMICS is not able to use this data to individually identify any user of the site. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that should you refuse the use of cookies, you may not be able to use certain features otherwise available on the Site.
STRAITS GENOMICS does use HubSpot to record and store customer information when it has been voluntarily submitted to us through a form on our website or obtained through other legitimate means. HubSpot may also be used to contact customers for marketing or commercial purposes where consent has been given or where local laws allow.

3) How We Use Your Personal Information

We collect your Personal Information so that we can:

• perform our Services
• improve our Services
• keep you updated about our Services
• contact you with other relevant Services we think you might be interested in

3.1) Use Upon Your Consent

We may process your Personal Information for the purposes as follows with your consent.

• Provide and improve our Services: The Personal Information we collect will be used to provide you with our Services, process your orders or fulfil the contract between you and STRAITS GENOMICS. We will not use your Genetic Data for any purpose other than to provide our Services without your prior consent.
• Advertising and marketing: The Personal Information we collect will be used to personalize and improve our advertising, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences. You can opt-out of receiving marketing messages from us easily by following the unsubscribe instructions included in our marketing messages. After you choose to opt-out, we will stop processing and delete your relevant Personal Information promptly.

We will acquire your consent in advance when the information is to be used for a purpose that is not specified in this Privacy Policy. We will acquire your consent in advance when the information collected for a specific purpose is to be used for other purposes.

3.2) Use Without Your Consent

In accordance with applicable laws, STRAITS GENOMICS may process your Personal Information for the one of the following purposes without your consent:

• To perform its contractual obligations;
• To protect the vital interests of the Personal Data Subject or another natural person if the Personal Data Subject is physically or legally incapable of giving consent;
• To comply with applicable laws, regulations, and guidance, during our legitimate interests.

4) How Long We Keep Your Personal Information

STRAITS GENOMICS will retain the Personal Data for no longer than it is necessary for the purposes if needed to provide the Services requested from STRAITS GENOMICS or requested by applicable laws and regulations. Beyond the above retention period, we will delete or anonymize your Personal Information.

5)  How We Share and Disclose Your Personal Information

Within STRAITS GENOMICS, the Personal Information collected are only accessible to the members of STRAITS GENOMICS who, within the scope of their specific tasks, are responsible for it and whose access to these data is expressly required for the performance of their tasks.

STRAITS GENOMICS may also share the Personal Information collected with its affiliated companies, trusted third parties, suppliers, and sub-contractors through which you have ordered one of our services and consented to receive your Personal Information, as well as the Insurance Company if their intervention is required.

6) How Your Personal Information is Transferred

Subject to applicable local legal requirements, your Personal Information may be transferred, stored, and processed outside of the country where you live or have ordered our Services from, including to our subsidiaries, affiliated companies and service providers located in other jurisdictions, and may become subject to the laws of such jurisdictions. The primary location of where your Personal Information will be stored or processed for the Services you have ordered from STRAITS GENOMICS will be stated in the governing contract and/or the test request form.

We only provide your Personal Information to our subsidiaries, affiliated companies, and services providers where it is necessary to meet the purpose for which you have submitted your Personal Information and if necessary for the provision of services and support. We take steps to ensure that STRAITS GENOMICS companies follow our data protection policy, this privacy notice and applicable local law when managing Personal Information and that service providers put in place adequate safeguards to protect the Personal Information entrusted to them, as outlined below.

6.1) Transfer outside of EU

For Personal Information of Personal Data Subjects who are in EU: STRAITS GENOMICS will implement appropriate measures to ensure that Personal Information remain protected and secure when transferred outside EU, in accordance with applicable data protection and privacy laws, such as:

• The country to which the Personal Data are transferred has benefited from an adequacy decision by the European Commission under Article 45 of the GDPR; or
• Standard data protection contractual clauses as approved by the European Commission pursuant to Article 47 of the GDPR have been established.

In the absence of the above appropriate safeguards, we will ask you for your explicit consent for cross-border transmission of your Personal Information. In the meantime, security measures such as encryption or de-identification will be adopted for the safety of your Personal Information.

7) How We Protect Your Personal Information 

STRAITS GENOMICS uses a variety of security measures and technologies to help protect Personal Information from unauthorised access, use, disclosure, alteration or destruction with applicable data protection and privacy laws.

Amongst others, when STRAITS GENOMICS shares the Personal Information of a Personal Data Subject with external suppliers/subcontractors or services providers, STRAITS GENOMICS may put in place a written agreement which commits the suppliers/sub-contractors or services providers to keep these Personal Information confidential and put in place appropriate security measures to keep this information secure.

Some of the safeguards we use to protect your information are firewalls, data encryption, and access controls. The administrative measures we use include establishment of department and designation of person responsible for protection of Personal Information, conducting self-evaluation on security of Personal Information, organization of training on relevant staff, etc.

In case of Personal Information security incident, we will in a timely manner according to laws and regulations inform you about the basic conditions and influence of security incident, response measures that are already taken or to be taken by us, suggestions for you regarding precautions and risk control, corrective measures for you, etc. To the extent permitted by law, we will inform you about relevant situations of the incident in a timely manner via email, fax, telephone or push notification, or any other means of communication we deem appropriate. When it is difficult to notify every Personal Data Subject individually, we will properly and effectively issue a public announcement.

8) Your Rights

We respect your legal rights with regards to your Personal Information. Below are the rights you may exercise before us by sending an email to enquiry@straitsgenomics.com. Please note that for the sake of security, we may ask you to verify your identity before further processing your request.

• To access the Personal Information STRAITS GENOMICS, hold about you: You are entitled to access and request copies of Personal Data that you provided to us, unless applicable laws provide otherwise.
• To be informed about how STRAITS GENOMICS uses your Personal Information: We strive to be transparent about how we use your data. We keep you informed as to what we do with your Personal Data through this Privacy Policy.
• To have these data rectified promptly in case of inaccuracy/incompleteness: If you find that your Personal Information processed by us is inaccurate or incomplete, you are entitled to ask us to make rectifications.
• To have your Personal Information erased in specific circumstances: You can request us to delete your Personal Information if we do not have a legal reason to continue to process and hold it.
• To restrict the processing of your Personal Information:You have the right to ask us to restrict how we process your Personal Data. If you restrict our processing, we will not further process but are still permitted to store the data.
• To object to the processing of your Personal Information: You have the right to object to our processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics.
• The right to data portability: To the extent permitted by laws and regulations, you have the right to request for the receipt of the transfer to another firm/organization in a structured, commonly used, and machine-readable form of the Personal Data provided to STRAITS GENOMICS.
• To lodge a complaint to STRAITS GENOMICS:You have the right to lodge a complaint by contacting enquiry@com or to the local data protection authority if your privacy rights are violated or if you have suffered as a result of the unlawful processing of your Personal Information.
• Possibility of withdrawal of the consent/ subsequent refusal to transmit Personal Information: If you wish to withdraw your previous consent or refuse the transfer of your Personal Data, you can send a written statement to STRAITS GENOMICS. STRAITS GENOMICS will respect that choice in accordance with its own legal obligations. This could mean that STRAITS GENOMICS may not be able to perform the actions necessary to achieve the purposes as set out in this Privacy Policy and affect the way in which STRAITS GENOMICS deals with you and/or for any related entities. Moreover, this withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. In this case, STRAITS GENOMICS will not be responsible for any direct or indirect damage of any kind that might occur as result of the withdrawal of the consent.

However, please note that STRAITS GENOMICS is contractually obliged to retain certain information as necessary for our legitimate business interests, to comply with our legal interest, or in accordance with legislation.

9)  How We Process Children’s Personal Information 

Although the definition of children varies according to laws and customs in different jurisdictions, we treat anyone under 16 years old (or equivalent minimum age in relevant jurisdiction) as a child.
We will only collect and process Children’s Person Information after we have obtained explicit consent of their guardian. When we find that a child’s Personal Information is collected without explicit consent of his or her guardian, we will delete the relevant data as soon as possible

10)  How This Privacy Policy is Updated

STRAITS GENOMICS reserves the right to modify this Privacy Policy at any time in accordance with this provision. The circumstances where we may change our Privacy Policy include but not limited to: there is major change of our service mode, e.g. purpose of processing Personal Information, type of processed Personal Information, usage mode of Personal Information; major change in terms of our ownership structure, organization structure, e.g. change of owners due to business adjustment, bankruptcy, merging, etc.; change of main object to which the Personal Information is publicly disclosed, shared, or transferred; change of your rights involved in Personal Information processing and their exercises; change of our responsible department, contacts and complaint channels for security of Personal Information; when there is high risk according to the Personal Information impact assessment report, etc.

If we make major changes to this Privacy Policy, we will post the revised Privacy Policy on our website and update the “Last Updated” date at the top of this Privacy Policy.

11) Contact Us

For any privacy concern, you may, at any time, contact STRAITS GENOMICS through enquiry@straitsgenomics.com and generally you will get our reply in thirty (30) working days or such shorter period as provided by law.