Welcome to SITABThe SITAB platform is owned by GENinCode Plc.
Access is restricted for professional use only.
SERVICE USER TERMS
These Service User Terms apply to your use of the SITAB platform (SITAB Platform) and the These Services (as defined below). These Service User Terms are published on 17th of February 2022.
Affiliate: means, in respect of any entity, any entity that directly or indirectly controls, is controlled by or is under common control with that entity within the meaning set out in section 1124 of the Corporation Tax Act 2010.
Applicable Laws: mean all applicable statutes, common law, statutory instruments, orders, regulatory policies, binding codes of practice, binding guidance notes, bye-laws, rules of court and regulations, directives, notices or legally enforceable requirements of any local, statutory, governing or public authority or body, or any other lawfully constituted regulatory body having authority (including to the extent applicable EU regulations, directives, decisions and notices as applicable and all subordinate or delegated legislation made by such bodies or under such legislation).
Applicable Data Protection Laws: means: (i) to the extent the UK GDPR applies, the law of the United Kingdom or of a part of the United Kingdom which relates to the protection of personal data; and/or (ii) to the extent the EU GDPR applies, the law of the European Union or any member state of the European Union to which GENinCode is subject, which relates to the protection of personal data.
Authorised Users means, the named users authorised by GENinCode to use the SITAB Platform in accordance with the terms of these Service User Terms.
Clinic Data: means all data (in any form) that is provided to GENinCode or uploaded or hosted on any part of the SITAB Platform or otherwise provided or transmitted by you or by any Authorised User and in connection with the Services, including the Clinic Personal Data.
Clinic Personal Data: any personal data which GENinCode processes in connection with the SITAB Platform and the Services, in the capacity of a processor on behalf of you as a controller.
Clinic Systems means all software and systems used by you or on your behalf, or any Authorised User in connection with the provision or receipt the Services and the SITAB Platform otherwise, links, inter-operates or interfaces with or utilises (in each case whether directly or indirectly).
Confidential Information means all information (whether in oral, written or electronic form) relating to a party's business which may reasonably be considered to be confidential in nature including information relating to a party's technology, know-how, Intellectual Property Rights, assets, finances, strategy, products and customers.
Documentation means any relevant instructions, information and processes relating to the Services or the SITAB Platform, including in respect of how to use any aspect of the SITAB Platform made available by GENinCode from time to time.
EU GDPR: the General Data Protection Regulation ((EU) 2016/679) and any EU national regulation implementing and/or developing it, including Spanish Data Protection Act 3/2018.
Force Majeure means an event or sequence of events beyond a party’s reasonable control preventing or delaying it from performing its obligations under these Service User Terms (provided that an inability to pay is not Force Majeure), including any matters relating to transfer of data over public communications networks and any delays or problems associated with any such networks or with the internet.
Intellectual Property Rights means any and all copyright, rights in inventions, patents, know-how, trade secrets, trade marks and trade names, service marks, design rights, rights in get-up, database rights and rights in data, semiconductor chip topography rights, utility models, domain names and all similar rights and, in each case; whether registered or not; including any applications to protect or register such rights; including all renewals and extensions of such rights or applications; whether vested, contingent or future; and wherever existing.
Permitted Downtime means: (a) scheduled maintenance; (b) emergency maintenance; or (c) downtime caused in whole or part by Force Majeure.
Permitted Purpose means for the purpose of GENinCode providing you with the SITAB Platform solely as necessary for you to receive the full benefit of the Services in accordance with the applicable Documentation and these Service User Terms. Permitted Purpose expressly excludes any of the following to the maximum extent permitted by law: (a) copying, reproducing, publishing, distributing, redistributing, broadcasting, transmitting, modifying, adapting, editing, abstracting, storing, archiving, displaying publicly or to third parties, selling, licensing, leasing, renting, assigning, transferring, disclosing (in each case whether or not for charge) or in any way commercially exploiting any part of the SITAB Platform or Documentation; (b) permitting any use of the SITAB Platform or Documentation in any manner by any third party (including permitting use in connection with any timesharing or service bureau, outsourced or similar service to third parties or making the SITAB Platform or Documentation (or any part) available to any third party or allowing or permitting a third party to do any of the foregoing; (c) attempting to reverse engineer, observe, study or test the functioning of or decompile the SITAB Platform (or any part); all except as expressly permitted under these Service User Terms.
Services: means the provision of genetic testing services by GENinCode and the access to the bioinformatics tools for In Vitro Diagnostic to you (and your Authorised Users) from time to time.
Services Agreement: means any other terms, conditions or agreement entered into between GENinCode and you from time to time under which GENinCode agrees to provide the Services to you and/or access to the SITAB Platform.
Service Period: means the period of service agreed between you and GENinCode from time to time.
UK GDPR: has the meaning given to it in the Data Protection Act 2018.
DETAILS OF PROCESSING OF PERSONAL DATA
This Schedule 1 includes certain details of the processing of personal data as required by Applicable Data Protection Laws.
|Subject matter and duration of the processing of personal data
|processing pseudonymised patient data, together with personal data of clinicians, physicians and your employees and contractors to allow us to provide you with the Services and the SITAB Platform for the Service Period.
|The nature and purpose of the processing of personal data
|for the purposes of providing the Services and the SITAB Platform.
|The types of personal data to be processed
|processing pseudonymised patient data provided by you, which shall include data of birth, ethnicity, weight, height, cholesterol levels, blood pressure and details of medical conditions. GENinCode is unable to establish the identity of the patient as it is provided solely with a barcode and no 'key' to identify the relevant individual, together with the names, emails addresses and contact details of clinician and physicians, and of your employees and contractors.
|The categories of data subject to whom the personal data relates
|patients, clinicians, physicians and your employees and contractors.
GENINCODE PLC takes the privacy of personal data from the Users very seriously and undertakes to implement all the required measures and policies to protect and grant such privacy on any personal data controlled and/or processed by GENinCode.
GENinCode (includes either GENinCode Plc and its affiliate GENinCode S.L.U, which ever entity you are contracting with) is a "controller" for the purposes of the EU General Data Protection Regulation 2016/679 and the Data Protection Act 2018 (together the "Data Protection Legislation") of your personal data. Therefore, any Personal Data collected from the GENinCode website www.genincode.com or from any other domain or subdomain owned and controlled by GENinCode, including SITAB platform for Health Care Professionals (“Website”) and/or its social media profiles (LinkedIn, Twitter, Facebook etc.), will be handled and processed in accordance with this legislation.
GENinCode is registered with the Information Commissioner's Office, or ICO, under registration number ZB080422.
If you have any question about how GENinCode uses your personal information please contact our Data Protection Officer at email@example.com
“Data Controller”’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
“Data Processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.
“Health Care Professionals” means physicians or any other health care professionals such as hospitals, nurses and other professionals offering specialized health care services (e.g., Genetists, laboratory technicians and medical experts etc.).
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“User” means any person using and acceding the Website and/or the social media profiles pertaining to different subject categories which includes, but it is not limited to general users of the Website and social media, Health Care Professionals, patients or consumers, notifying third parties, job applicants, clients, suppliers and collaborators.
In addition to the right to be informed about how we use your personal information (as set out in this privacy notice), you have various other rights in respect of the personal information GENinCode hold about you – these are set out in more detail below. If you wish to exercise any of these rights, please contact firstname.lastname@example.org
Some of these rights only apply in certain circumstance, so we may not be able to fulfil every request. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
The User is entitled to file a complaint with the relevant Data Protection Agency (“DPA”) of your EU country (list of DPA in the EU: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm), or in the UK, the ICO: https://ico.org.uk/
For any questions and requests regarding Data Protection Legislation and Personal Data use and processing within the UK or the EEA or related to UK or EEA citizens, please contact us at: email@example.com
DATA COLLECTED BY GEN INCODE
GEN inCode may collect Personal Data from the following sources:
Please note that the Health Care Professionals also share Personal Data with us on a pseudoanomised basis relating to patients. In those cases, GEN inCode acts as a Data Processor on behalf of the Health Care Professionals who are the Data Controller. We recommend you review your Health Care Professional's privacy notice.
In all cases, GENinCode will only process personal and sensitive Personal Data for the intended use, previously unlinked and pseudonymised and as expressly instructed by the Health Care Professionals and always following Data Protection Legislation.
The Personal Data used, handled, processed, and stored by GENinCode can be classified in the following general groups or categories:
Please that that in the event a Healthcare Professional uploads any patient data to our website or SITAB as part of the services that we provide, that in processing any such patient data, we are acting as a processor on behalf of the relevant Healthcare Professional acting as controller. If your personal data has been submitted to our website or SITAB by a Healthcare Professional, we would suggest reviewing the applicable Healthcare Professional's privacy notice which they are obliged to provide to you as the controller of your personal data.
Special Category Data
Special protection is given to personal information that is particularly sensitive. This is information about your health status and/or genetic data.
We may receive pseudoanonymised data from our Health Care Professionals. As set out above, we act as processors for certain Healthcare Professionals who are controllers of your data, therefore, we recommend you view your Health Care professional's privacy notice to understand how your personal data will be processed.
USE OF THE PERSONAL DATA
Personal Data will be used for the following purposes:
We collect and use personal data directly from you and also from other sources in the manner permitted by Data Protection Legislation.
GENinCode collects personal data on the following lawful basis:
In the table below we have provided specific examples of what data we collect and our lawful basis for processing that data.
|Type of data
|Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|To process and deliver our service
|User management, to respond to inquiries through the Website and obtain feedback on our services, products and content
|Management of job applicants and the selection processes of GEN inCode.
| To manage our relationship with you which will include:
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|To make suggestions and recommendations to you about goods or services that may be of interest to you
PERSONAL DATA DISCLOSURE
We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the GENinCode Group.
Whenever we transfer your personal data out of the UK and/or the EEA., we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will retain your personal data in accordance with our data retention policies, unless we are required to retain your personal information for a longer period to satisfy any legal and accounting or reporting requirements.
According to the Data Protection Legislation GENinCode declares that applies the security technical, administrative, and organisational measures to protect the Personal Data collected against accidental or illicit destruction, alteration, disclosure or unauthorised access, especially when the processing implies the transmission of data over a network and in regard to any other illicit form of processing.
Last updated: 17 February 2022
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