1. We at hei are committed to maintaining the privacy and security of your personal information.  We appreciate that health and wellness information is particularly sensitive.  This Privacy Policy applies to the hei website at https://hei.imagenelabs.com (the “Website”), hei’s mobile application (the “Mobile App”), and the saliva, swab and microbiome tests carried out as part of the hei program (the “Program”), and any other information you provide us with in relation to the Program. This policy (together with our Terms and Conditions) sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By registering for the hei program you are accepting and consenting to the practices described in this policy. For the purpose of data protection legislation, the data controller is Imagene Labs, registered in Singapore with UEN 201601438E, whose operating office is 115 Eunos Avenue 3 #05-01 Singapore 409839, referred to as ‘we’ in this policy and the Privacy Headlines you accepted when registering for the service.

 

2. Information we collect from you

 

We will collect and process the following data about you:

 

2.1. Information you give us

 

2.1.1.“Personal Information” is information you give us that can be used to identify you either alone or in combination with other information. We collect the following types of Personal Information:

2.1.2. “Registration Information” is information you provide when registering for and/or purchasing the Program. The information you give us is, your full name, address, payment method details, e-mail address, phone number, and a password to be used for your account.

2.1.3. “Samples” are the actual saliva, swab, and microbiome samples you provide to our partner labs to process on our behalf and the associated reference number. They would not be considered Personal Information unless they were accessed by a person also having access to the link between the reference number and your Registration Information, which is kept under secure conditions by us alone. But we have included reference to them in this Policy to inform you as to our use of them.

2.1.4. “Sample Information” is data generated through the analysis of your saliva, swab, and microbiome samples, including DNA data relating to your genotype.

2.1.5. “Phenotypic Information” is your Personal Information, including your health history, dietary habits, exercise, sleep, and wellness goals that you enter during the online assessment part of the Program; any recommendations we provide to you as part of the Program; and any information you submit from any fitness trackers, wearables or apps.

 

3. Information we collect about you

 

3.1. With regard to each of your visits to hei we will automatically collect the following information:

3.1.1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions.

 

4. Uses made of the information

 

We use information held about you in the following ways:

 

4.1. Registration Information.

 

We will use this information:

4.1.1. to provide you with the information that you request from us.

4.1.2. to provide you with information about other services we offer that are similar to hei.

4.1.3. to provide you with information about goods or services we feel may interest you.

4.1.4. to notify you about changes to our Program.

 

4.2. Samples

 

We use Samples to derive Sample Information (see below).

We will discard or destroy your Sample and its associated DNA material, upon completion of your Sample processing and data generation at our or our partner’s Laboratory facilities. We will not return your Sample and its associated DNA material to you.

 

4.3. Sample Information

 

We will use this information:

4.3.1. to provide you with information and recommendations as part of the Program.

4.3.2. with or without combination with your Phenotypic Information, and personal data from other users of the Program, for the purposes of research and product development. This might be conducted by us, or by someone else to whom we provide the data. We will seek your consent to use your Sample Information/Phenotypic Information for this purpose. In no circumstances will we provide to any person for research or product development purposes any Sample Information/Phenotypic Information which is linked to your Registration Information (or indeed any other personal data we hold about you), and without your consent.

 

4.4. Phenotypic Information

 

We will use this information:

4.4.1. to provide you with information that you request from us, and information you request that we share with your healthcare or well-being professionals.

4.4.2. with or without combination with your Sample Information, and personal data from other users of the Program, for the purposes of research and product development. This might be conducted by us, or by someone else to whom we provide the data. We will seek your consent to use your Sample Information/Phenotypic Information for this purpose. In no circumstances will we provide to any person for research or product development purposes any Sample Information/Phenotypic Information which is linked to your Registration Information (or indeed any other personal data we hold about you), and without your consent.

 

4.5. Information we collect about you

 

4.5.1. to administer hei and for internal operations, including troubleshooting, data analysis, testing, statistical and survey purposes;

4.5.2. to improve hei to ensure that content comprised in the Program is presented in the most effective manner for you and for your computer;

4.5.3. as part of our efforts to keep hei and your Personal Information safe and secure; and

4.5.4. to make suggestions and recommendations to you and other users of hei about goods or services that may interest you or them.

4.5.5. The legal basis for us processing your Sample Information is that you have given your explicit informed consent both by accepting this Privacy Policy and by giving your consent in the Consent Form. The legal basis for us processing your Phenotypic Information and your Registration Information is that you have given your explicit informed consent by accepting this Privacy Policy. Additionally, the data you provide to us is necessary for the provision of the Program to you.

4.6. You may withdraw your consent to us processing your Personal Information at any time by emailing us at dpo@imagenelabs.com. We will cease providing you with any aspects of the Program that require use of that information immediately and you will not be entitled to any refund for any services or products still pending to be provided to you. If you remove your consent to the use of your Sample Information or Phenotypic Information, we will stop using it for the purposes of the Program, and for new research or development projects from the receipt of your request. Any research or development projects involving your Information that has already been performed or is in the course of being performed will not be reversed, undone, or withdrawn.

5. Cookies

 

5.1. This website uses Google Double Click Ad Exchange and Google Tag Manager software provided by Google. These services allow website providers to address their visitors in a targeted fashion by displaying personalised, interest-based advertisements when they visit other websites that are part of the Google Display Network. Google places what are known as cookies to analyse how users use a website. The information collected  these cookies form the basis for interest-based advertising. To do so, Google stores a small sequence of numbers in your browser. This number is used to record the visits to the website and collect anonymised data on how the website is being used. No personal data of the people visiting the website are collected in the process. If you subsequently visit another website that is part of the Google Display Network, you will be served advertisements that are highly likely to be related to the products or information that you have previously viewed. You can permanently deactivate the cookies used by Google if you click on the following link and download and install the plug-in contained therein: https://www.google.com/settings/ads/plugin.

5.2. Our site also uses Google Analytics. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it. Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site. You can do so by visiting this page – https://tools.google.com/dlpage/gaoptout.

 

6. Disclosure of your information

 

You agree that we have the right to share your Personal Information with:

6.1. Any healthcare or well-being professional you request us to share your Phenotypic Information with;

6.2 Any member of our group of companies, which means our subsidiaries, our ultimate holding company, and its subsidiaries;

6.3 Any Third-Party Service Provider that requires the Phenotypic Information for data processing.

6.4. Any prospective seller or buyer of our business or assets, in the event that our business or assets is being sold. If Imagene Labs (or substantial of its assets) is acquired by a third-party Company, all Information of our customers will be one of the assets transferred to the acquiring Company;

6.5. Any entity in the event that we are under a duty to disclose or share your Information and data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements;

6.6. Any entity in order to protect our rights, property, or safety, or the rights, property or safety of our customers and other individuals.

 

7. How long we will keep your data

 

7.1. We will archive and stop using any Registration Information and other identifiable information about you immediately upon the termination or expiration of your Program. We will delete such information from our archives 6 months after your last access to hei.

7.2. De-identified copies of your Sample Information and Phenotypic Information that do not contain any identifiable information about you will not be subjected to these deletion requirements.

 

8. Your rights

 

8.1. You have the right to request us not to process your Personal Information for marketing purposes. We will inform you (before collecting your Personal Information) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking the relevant boxes on the forms we use for obtaining permission to collect your data.

8.2. You have the right to access information we hold about you, together with an explanation of the categories of data being processed, the purposes of such processing, and the categories of third parties to whom the data may be disclosed. You can also request us to provide you details of the period for which the data will be stored (or the criteria used to determine such period of storage) and information about your other rights regarding our use of your data. We will provide you with this information within one month of your request. Subsequent repeat request for this information will be chargeable at USD30 to help cover our cost of processing your request.

8.3. You also have the following rights:

8.3.1. The right to request us to rectify any inaccurate Personal Information about you.

8.3.2. The right to be ‘forgotten’ by us and have us erase any Personal Information we hold about you if it is no longer necessary for us to hold such information for the purposes of your use of hei.

8.3.3. The right to request us to port your data to another service (if technically feasible) or to provide you with a copy of data we hold about you in a structured, commonly used machine-readable format so that you can provide such data to that service provider. We will not carry out such request to the extent that it involves disclosing data about any other individual).

8.3.4. You can exercise any of these rights at any time by contacting us at dpo@imagenelabs.com.

 

For deletion request of account or any personal information we hold about you, we will send you an email to confirm this notice. The deletion request will be effective after receiving a second email confirmation from you. Your account data will be deleted within 30 calendar days.

To the extent that it does not involve disproportionate effort on our part, if you exercise any of the above rights, we will inform any third parties to whom we have transferred your data.

9. Security

 

9.1. hei is committed to keep the trust you place in us. To prevent prohibited access or disclosure, to maintain information accuracy, and to ensure using the information appropriately, hei uses various physical, technical, and administrative measures to keep your Personal Information. Particularly, all connections to our website and our mobile application are encrypted using Secure Socket Layer (SSL) technology.

9.2. Please understand that protecting your Personal Information is also your responsibility. We ask for you to be responsible for keeping your password secure, as well as other authentication information that you use to access the Program. You should not share your authentication information to any third parties, and you should inform hei immediately upon discovery of any prohibited use of your authentication information.

9.3. As with all web-based services, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to hei via the internet including over mobile devices; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

 

10. Other data users

 

10.1. hei may provide signposts to resources to help users navigate external health and wellness resources available to them. If you follow a link to any of these external resources, please note that these websites have their own privacy policies, and we will not be responsible or liable for their policies. Please check these policies before you submit any personal data to these websites.

10.2. In requesting us to provide your information to any healthcare or well-being professionals, you should ensure that they will take the utmost care of your information. We are not responsible for any actions or behaviour of any such person regarding their use of your information.

10.3. The Program Is not designed for, intended to attract, or directed towards minors. Our terms and conditions prohibit any minors from accessing the Program and we do not intentionally process any personal information of any minors. You confirm that you are above the age of consent in the jurisdiction you reside in.

 

11. Changes to our privacy policy

 

11.1. Any changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently for any updates or changes to our privacy policy.

 

12. Contact

 

12.1. Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to hei@imagenelabs.com.

 

 

 

hei INFORMED CONSENT FORM

 

This informed consent form is used by Imagene Labs, trading as hei (‘hei’ or ‘us’) to record your consent to tests being carried out by our laboratory partners on your saliva, swab, or stool samples. If you have any questions regarding the laboratories we use, our testing processes or the nature of the results which the tests are designed to produce, please contact us at hei@imagenelabs.com.

 

Please review the following statements and tick the boxes that you agree to:

 

1) I agree to my saliva, swab, stool, and other biological samples being collected, profiled, and analysed by laboratories for the purposes of determining a number of indicators of my health and well-being.

 

2) I understand and agree that my anonymised personal data will be processed and stored by hei and their laboratory partners carrying out the tests, for the purposes of analysing my biological samples.

 

3) I understand that the tests I purchase via the hei platform are sold and shipped by trusted third-party partners, and my biological samples are processed and analysed by trusted third-party laboratories.

 

4) I understand the tests that will be carried out on my biological samples and the nature of the results that will be notified to me in respect of the test.

 

5) I acknowledge that genetic and other biological testing are constantly improving, and that no genetic or other biological test can claimed to be 100% accurate and reliable. As with any genetic and other biological test, despite the laboratories taking all efforts to ensure their validity, it is possible that the genetic and other biological tests on my biological samples may not produce an accurate reading.

 

6) I am above the age of consent in the jurisdiction I reside in at the time my biological samples are being collected.

 

7) I consent to my biological samples being disposed of or stored for additional testing by the testing laboratory, and acknowledge that they will not be returned to me.

 

8) I understand that the supplements, functional foods or other health and wellness products I purchase via the hei platform are sold and shipped by trusted third-party sellers and partners who take ultimate responsibility for the quality of the sold products.

 

9) I consent to my anonymised and pooled test results being used by hei or selected third parties for statistical and demographic analysis or other research and product improvement purposes.

 

10) I consent to my personal information being used by hei or selected third parties for marketing purposes or for hei to serve me marketing contents or products relevant to my personal information.

 

11) I understand that the biological tests are carried out for informational purposes only and are not meant for any medical purposes, including the diagnosis or treatment of any illness or disease.

 

12) I understand that all advice, recommendations, and guidance provided to me in the hei platform is for informational purposes only and are not meant to supersede or be used in place of any medical advice provided to me by a medical professional.

 

13) I understand that my samples and personal data will be processed in accordance with the Terms and Conditions and Privacy Policy I accepted when subscribing to hei.

 

 

Updated as of 12 July 2023.