PRIVACY POLICY

PROGENUS S.A.

 

PROGENUS aims to enable its customers to perform easy and reliable tests through innovative, autonomous and customized DNA analysis. PROGENUS has three departments: R&D, Kit Production and Laboratory Services.

This policy deals with your legal rights and obligations in accordance with EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016, better known as GDPR. You can find full GDPR text here.

The purpose of this Privacy Policy is to explain to you:

• What we do with the personal data;
• The reasons for which we collect or process this data;
• The conditions under which we can transfer them.

 

I. Concepts

In the data processing policy below, the following concepts are addressed:

• Personal data: any information concerning an identified or identifiable natural person (e.g. name, e-mail address, address, mobile phone, etc.).
• Data Processing: operation carried out on personal data (collection, recording, storage, destruction, deletion, etc.)
• A controller: a natural or legal person determining the means and purposes of processing.
• A processor: a natural or legal person who processes data on behalf of the controller.

 

II. The company

Company is named as follows: PROGENUS SA

Company is registered with the CBE under N°.: 0476.355.815

Head office located at: 7a rue Camille Hubert, 5032 Gembloux, Belgium

 

III. Personal data used

PROGENUS processes the personal data of its clients, candidates and visitors for various purposes.

For processing purposes related to the use of laboratory services, directly or via our WebShop, a client may be required to communicate the following categories of personnel data to PROGENUS:

1. • contact details (address, telephone number and Email if available)
   • company's administrative details (company contact person)
   • bank details
   • the name and chip number of the animal concerned
   • identity data and contact details of the sampling veterinarian
   • the PROGENUS number of the analysis already performed

    

For processing needs related to the use of kits and R&D, a customer may be required to communicate the following categories of personal data to PROGENUS:

1. • identity data
   • contact details (postal address, telephone number and Email if available)
   • administrative details (company contact person)
   • bank details

    

For the purposes of processing CVs received for unsolicited applications, a candidate may be required to communicate the following categories of data to PROGENUS:

1. • identity data
   • contact details (postal address, telephone number and Email if available)
   • education, training and professional experience

    

For the purposes of processing data related to the use of the PROGENUS website, a customer may be required to provide the following categories of data:

1. • IP address

   PROGENUS does not carry out any other type of processing of personal data (no cookies, no follow-up marketing, resale of information, profiling, etc.).

IV. The purposes for which your data is used and the lawful basis on which it is used

The table below lists the different treatments and the lawful basis of these treatments:

Treatments	Lawful basis
Accounting treatments related to laboratory services, kit sales and R&D, directly or via our WebShop	Necessary to fulfil the contract.
Operational processes (sample analysis) related to laboratory services	Necessary to fulfil the contract.
Retention of interesting CVs received during spontaneous applications	Consent
IP address processing during website visits	Legitimate interest (website security and performance)

 

V. Retention period

• Data relating to laboratory analyses shall be kept for 30 years.
• Data relating to clients of our WebShop are kept for 10 after last order
• Data relating to spontaneous applications are kept for 1 year.
• Data relating to connections to the website are kept for 1 year.

 

VI. Conditions relating to processors (subcontractors)

PROGENUS has the right to use processor (subcontractors) to perform tasks entrusted to it by its customers. These subcontractors will only receive the data necessary for the execution of these tasks and may only use this data to carry out the said task.

PROGENUS is responsible for the subcontractor's compliance with PROGENUS' obligations under the GDPR and will enter into an agreement with each subcontractor guaranteeing the rights and obligations under the GDPR.

The customer may, at any time and on simple request, know the list of subcontractors involved in the processing of the personal data he has provided.

Generally speaking, the different categories of subcontractor are:

• Outsourcing of certain animal analyses (pedigree, disease, comfort)
• Subcontracting of certain food analyses and traceability
• Subcontracting of certain DNA identification analyses

 

VII. Transfer of your personal data

PROGENUS does not transfer personal data to subcontractors located outside the European Union.

In certain cases, PROGENUS may have to communicate your data within a legal or judicial framework in compliance with the legal provisions specific to certain matters.

 

VIII. Technical and organizational measures

PROGENUS undertakes to take appropriate technical and organizational measures to protect the data from accidental or abusive destruction, loss, unauthorized distribution or access and other forms of illegal processing. PROGENUS guarantees a level of security appropriate to the risks associated with the processing and nature of the data to be protected, taking into account the technical possibilities and costs involved.

 

IX. Your rights

You have following rights regarding the processing of your personal data:

1. The right to consult and access your data.

If you wish to consult the data we process about you, you can exercise your right of access, we will provide you with as complete an overview of your data as possible.

 

2. The right to rectify your data.

It may happen that some data we hold about you is not correct or no longer correct. You can always request that this data be corrected or completed unless we are unsure of the authentic source of the data.

 

3. The right to request the deletion of your data.

If you believe that the processing of certain data is inappropriate, you may request that such data be deleted under certain conditions because certain legal texts relating to our legal mission require the use of certain personal data without which we could no longer fulfil our mission.

 

4. The right to object to a specific use of your data.

If you do not agree with a specific use of certain data in the context of processing based on a legitimate interest, you have the right to object. We will accept this opposition, unless there is a compelling reason.

 

5. The right to refuse that your data be processed automatically.

Some data processing and procedures take place in a fully automated way, without human intervention. If you do not agree with the result of this fully automated procedure, you can contact us. You can ask for the intervention of one of our collaborators or let us know the reason why you contest this answer.

 

6. The right to obtain the transfer of your data to a third party.

You have the right to ask to transfer directly to a third party, the personal data that you have communicated within the limits set by the contract.

 

7. In order to exercise your rights.

Please be precise in your request, so that we can process your request in a concrete and correct manner.

 

When you exercise a right, we may ask you to prove your identity in order to prevent someone else from exercising your rights for you. A copy of the identity card may therefore be requested.

 

X. PROGENUS data controller and his representative

• The designated data controller is Mr. Robert Renaville, Managing Director of PROGENUS S.A.

          Address: 7a rue Camille Hubert, 5032 Gembloux, Belgium

 

• The representative of the designated controller is the quality coordinator

           Address : 7a rue Camille Hubert, 5032 Gembloux, Belgium

           Email: This email address is being protected from spambots. You need JavaScript enabled to view it.

 

If you disagree with PROGENUS S.A.'s response, you may consult the Data Protection Authority's website and, in this case, exercise your rights with the latter.