LAST UPDATED: March 17th, 2020
forms a part of the DNA ROMANCE User Agreement, as amended (the “Agreement”), between DNA ROMANCE
LTD. (“DNA ROMANCE”, “us”, “we” or “our”), the owner and operator of https://www.dnaromance.com/ (the
“Site”) and the DNA ROMANCE mobile applications (“Apps”), and you (“you” or “your” or “user(s)”), a user of
and retain information and data through your use of the Services.
LEGALLY BINDING AGREEEMENT BETWEEN YOU AND DNA ROMANCE, AND IS DEEMED ACCEPTED
BY YOU UPON YOUR FIRST ACCESS, USE OR DOWNLOAD ANY OF THE SERVICES. FOR CERTAINTY,
BY ACCESSING, USING OR DOWNLOADING ANY PART OR WHOLE OF THE SERVICES, YOU
EXPRESSLY CONSENT TO OUR COLLECTION, USE, SHARING AND STORING OF YOUR PERSONAL
POLICY, DO NOT ACCESS, USE OR DOWNLOAD ANY OF THE SERVICES.
person and could be used to identify that specific person whether from that data or other information that DNA
ROMANCE has or is likely to have access to. We do not consider Personal Information to include information that
has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in
combination with other information or otherwise.
DNA Romance has taken rigorous steps to ensure compliance with all applicable privacy laws, including the general
data protection regulation (GDPR).
2. Information Collection
(a) General Use: We collect, process, and retain information from you and any devices (including mobile
you may use when you: register for an account with us; update or add information to your account; participate
in community discussions, chats, or dispute resolution; engage or communicate with us, other users or third
parties in connection with the Services; post or complete transactions using the Services; or otherwise access,
use or download any part or whole of the Services. Such information includes without limitation:
• identifying information such as your name, address, telephone number and email address;
• DNA and/or genetic information;
• geographic or location information, which data may be precise or imprecise;
• content of your communications via the Services;
• financial information (such as credit card or bank account numbers) in connection with the Services;
• information relating to the performance of the Services you experience; and
• information you provide via web form, community discussion, chats and dispute resolution.
(b) Automatic Collection: By using the Services, we may automatically collect information about how you
the Services, the areas of the Services that you visit, as well as information about your computer or mobile
device, such as your Internet protocol (IP) address, device ID, physical location, browser and operating system
type, resolution of your screen, language settings in your browser, referring URLs, and other technical
information. This information is necessary for providing personalized and location-based content and services,
as well as for analyzing web traffic, troubleshooting problems, preventing fraud, and improving the Services.
(c) Third Party Data: We may obtain data from third parties. We protect data obtained from third
to the practices described in this statement, plus any additional restrictions imposed by the source of the data
and applicable laws. These third-party data sources vary over time, but may include without limitation: data
brokers from which we purchase demographic data to supplement the data we collect; social networks when
you grant permission to us to access your data on one or more networks, service providers that help us
determine a location based on your IP address in order to customize certain products to your location, DNA
testing facilities and service providers, and partners with which we offer co-branded services or engage in joint
(d) Feedback: Any suggestions or comments for improving or modifying the Services that are included in your
communications with us (“Feedback”) will be deemed to be non-confidential and non-proprietary to you, and
you agree that:
(a) DNA ROMANCE is therefore not subject to any confidentiality obligations with respect to
(b) the Feedback is not confidential or proprietary information of any third party and you have
all of the necessary rights to disclose the Feedback to us;
(c) DNA ROMANCE may irrevocably freely use,
reproduce, publicize the Feedback; and
(d) you are not, nor is any other party, entitled to receive any
compensation or reimbursement of any kind from us in relation to the Feedback.
3. Information Use
You hereby consent to our using any of the information we collect on you (the “Information”), which includes
limitation your Personal Information:
(a) to deliver our Services to you;
(b) to improve our Services in order to better serve you;
(c) to provide you with a personalized experience when using our Services;
(d) to provide targeted advertising to you;
(e) to appropriately respond to your communications and provide you with customer service;
(f) to contact you about feature updates and informational and service-related communications;
(g) for internal statistical, marketing or operational purposes, including without limitation generating sales
and measuring and understanding demographic, user interest, purchasing and other trends among our
(h) to detect, prevent, mitigate and investigate fraudulent or illegal activities, which includes without
If you submit DNA information to us, directly or through a third party service provider, you remain the owners of
such information and material. Any derivative material we produce relating to that information, such as the
a compatibility search, will be owned by us, provided that such derivative material does not include any Personal
Information and is otherwise anonymous.
4. Information Disclosure
minimize the amount of Personal Information we disclose to what is directly relevant and necessary to
accomplish the specified purpose. DNA ROMANCE retains ownership of any and all Information that is not
(b) Other Users: When interacting with another user, the other user may request and we may provide him/her
your Personal Information as necessary for the ordinary use of the Services, such as your name, account ID,
email address or contact details. The other user receiving your Personal Information is not allowed to use such
information for purposes unrelated to the transactions or services engaged, such as to contact you for marketing
purposes, unless you have express consented to it. Contacting users with unwanted or threatening messages is
a violation of our Agreement. Other users may be provided Personal Information about you that is necessary
to facilitate the ordinary use of the Services.
Notwithstanding the foregoing, we will not disclose raw DNA information with other users, but will only
disclose the results of our compatibility assessment derived from such information, and only if we have
determined there to be a reasonable likelihood of compatibility based on our proprietary algorithm and
assessment. For certainty, we do not publicly display your raw DNA information.
(c) Service Providers: We may provide your Personal Information to third parties that provide services
with our business activities and the provision of the Services. For example, we may use third party service
providers to help us analyze DNA, analyze usage of our Services, provide personalized advertising, track the
effectiveness of our marketing campaigns, strategies and communications, provide payment processing
services, assist with the prevention, detection, mitigation and investigation of potentially illegal acts,
error and crash reports, host web servers and store data. These third parties are authorized to use your Personal
Information only as necessary to provide these services to us.
(d) DNA Romance Reorganization: We may also disclose or transfer your Personal Information to an
a third party in the event of a proposed reorganization, merger, sale, joint venture, assignment, transfer or
disposition of all or any portion of DNA ROMANCE’s business, assets or equity, including, without limitation,
in connection with any bankruptcy or similar proceeding. In connection with same, your consent to the
and its assigns, without notice to you.
(e) Legal Disclosure: Subject to applicable laws in your jurisdiction, DNA ROMANCE may also disclose
Information about you to others as we believe to be necessary or appropriate: (a) under applicable law or
regulation, including laws or regulations outside your country of residence; (b) to comply with legal process,
respond to legal claims; (c) to respond to requests from public authorities and law enforcement officials,
including officials outside your country of residence; (d) to assist or support theft investigations involving our
operations or those of any of our affiliates; (g) to protect the rights, privacy, safety or property of DNA
ROMANCE, its affiliates, you and others; or (h) to permit us to pursue available remedies or limit the damages
that we may sustain.
(f) International Transfer and Storage: Your Information may cross international borders in order to
Services. In some cases, your Personal Information may be disclosed, processed, and stored outside Canada,
and therefore may be available to government authorities under lawful orders and laws applicable there.
5. Information Security
We protect your Personal Information using technical and administrative security measures to reduce the risks of
misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data
encryption, and information access authorization controls. If you believe your account has been abused, please
us. DNA ROMANCE follows generally accepted industry standards to protect the Personal Information submitted to
us, both during transmission and once we receive it. No method of transmission over the Internet, or method of
electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
6. Third Party Policies
your Personal Information to others, or if you engage any a third-party sites or services, such third-party’s
notices and practices will apply.
We cannot guarantee the privacy or security of your Personal Information once you provide it to a third party and
encourage you to evaluate the privacy and security policies of each such third-party before any such engagement or
disclosure. This is true even where the third parties to whom you disclose Personal Information are buyers or
using our Services.
The Services may contain links to third party websites or applications that are not owned, maintained or operated
DNA ROMANCE. Any such links are provided solely as a convenience to you and not as an endorsement by DNA
ROMANCE. DNA ROMANCE is not responsible for the content of such linked third-party websites or applications
and does not make any representations, warranties or guarantees regarding the content or the privacy practices of
third parties. For certainty, DNA ROMANCE disclaims any liability associated with your access to, use of, download
of, or reliance on, such third-party websites or applications and their content. If you decide to access, use or
any such third-party website, application or content, you do so at your sole risk.
you to help personalize and maximize your DNA ROMANCE experience. We may also engage one or more third
party service providers to provide online advertisements on our behalf. We may use, or authorize the use of
pixel tags, web beacons or other similar technology to collect information about your visits to the Services, and
may use that information to send you targeted advertisements.
If you do not wish to accept cookies, you have the option of blocking or disabling cookies. Your computer provides
you with the ability to clear all cookies that have been stored onto your hard drive, should you wish to do so.
please be aware that you may be unable to access certain parts of the Services if you block or disable our
8. Marketing & Advertising
deemed consent to receive marketing communications from us via email or any other form of communication you
have provided us contact information for. You may opt-out at any time by clicking “Unsubscribe” in any such
communication or by contacting us.
The Services are not intended for, nor does DNA ROMANCE knowingly collect information from children. If we learn
that we have collected Personal Information from a child under fourteen (14), we will
take steps to delete the information as soon as possible. If you are aware of a user under the age of sixteen (16)
the Services, please contact us immediately.
10. Withdrawal of Consent & Changes to Personal Information
DNA ROMANCE takes reasonable steps to help ensure that the Personal Information we collect from you is accurate,
complete and current. You may request access to your Personal Information and request that erroneous or inaccurate
Personal Information be updated.
You may withdraw your consent for our collection, use and disclosure of your Personal Information at any time. If
you wish to withdraw your consent you can delete your profile from within your account settings, or by contacting
our Data Protection
Officer (DPO). This will affect your ability to access, use and download the
Services. Your access to the Services will be revoked if you withdraw consent, and if you continue to use the
11. Data Retention
DNA ROMANCE retains Personal Information for as long as necessary to provide the Services and fulfill the
transactions you have requested, or for other essential purposes such as complying with our legal obligations,
disputes and enforcing our agreements. Because these needs can vary for different data types in the context of
products, actual retention periods can vary significantly.
After it is no longer necessary for us to retain your Personal Information, we dispose of it in a secure manner
to our data retention and deletion policies. We are not responsible for any liability or loss you experience as a
of our disposal of Personal Information.
12. Contact Us
If you have any questions about DNA ROMANCE’s privacy and data management policies, contact our Data Protection
Officer at firstname.lastname@example.org