Privacy Notice

Thank you for choosing to be part of our community at MeaVitae Limited (Company number 11556365), a trading style of RDEL Limited (“MeaVitae”, “we”, “us”, or “our”). We are the controller of your personal information collected through our Sites and are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy or our practices with regard to your personal information, please contact us at [email protected].

When you visit our websites: https://www.meavitae.com; https://app.meavitae.com; any mobile application, and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the most transparent way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read it carefully, as it is essential. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our Sites or Apps and our services.

This privacy policy applies to all information collected through our websites (such as https://www.meavitae.com and https://app.meavitae.com ), any mobile applications (“Apps”), and/or any related services, sales, marketing or events. We collectively refer to this in this privacy policy as the “Sites”.

It is important that you read this privacy policy together with any other privacy notice or fair processing notices that we may provide on the Sites at or around the time that we collect or process personal information about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we may use data.

This privacy policy supplements other notices on the Sites, including our Terms of Use, Terms of Purchase and Cookie Policy, and should be read alongside such terms. This privacy policy is not intended to override or replace these terms.

Please read this privacy policy carefully, as it will help you make informed decisions about sharing your personal information with us.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, such as name, address, contact information, passwords and security data, and payment information.

We collect personal information you voluntarily provide when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services or contacting us.

The personal information we collect depends on the context of your interactions with us, the Sites or Apps, the choices you make, and the products and features you use. The personal information we collect can include the following:

Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. We collect passwords and similar security information used for authentication and account access. Such data is encrypted and not visible to MeaVitae.

Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument. All payment data is processed by our payment processor, Stripe, and you should review their privacy policies and contact the payment processor directly to respond to your questions.

All personal information you provide must be true, complete and accurate, and you must notify us of any changes to such personal information.

We have no visibility of any information, personal or otherwise, you enter into your secure digital vault on the Sites

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps.

We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information collected through our Apps

In Short: We may collect information regarding your geo-location and mobile device when you use our apps.

If you use our Apps, we may also collect the following information:

• Geo-Location Information. We may request access or permission to track location-based information from your mobile device continuously or while you are using our mobile application to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s contacts, storage, social media accounts, microphone, camera, calendar, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, and third parties. Examples of the information we receive from other sources include social media profile information, marketing leads and search results and links, including paid listings (such as sponsored links).

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Sites or Apps for various business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”).

We use the information we collect or receive:

• To facilitate account creation and logon process. If you choose to link your account with us to a third-party account, we use the information you allow us to collect from those third parties to facilitate account creation and the logon process.
• To send administrative information to you. We may use your personal information to send you the product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• Fulfil and manage your orders. We may use your information to fulfil and manage your orders, payments, returns, and exchanges through the Sites or Apps.
• To protect our Sites. We may use your information to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
• To enable user-to-user and user-to-third-party communications. We may use your information in order to enable user-to-user and user-to-third-party communications with each user’s consent.
• To enforce our terms, conditions and policies.
• Respond to legal requests and prevent harm. If we receive a witness summons or other legal request, we may need to inspect the data we hold to determine how to respond, notwithstanding that we have no visibility to the information you store in your secure digital vault.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluating and improving our Sites or Apps, products, services, marketing and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent to comply with laws, to protect your rights, or to fulfil business obligations.

We may process or share data based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a witness summons (including in response to public authorities to meet national security or law enforcement requirements) notwithstanding that we have no visibility to the information stored in your secure digital vault.
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Intra-Group. We may share or transfer your information with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Our Cookie Policy sets out specific information about how we use such technologies and how you can refuse certain cookies.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a more extended retention period is required by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than the period in which users have an account with us. We may , however keep your personal information for a short period after a subscription expires to allow you to reactivate your account if desired.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. Although we will do our best to protect your personal information, the transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment and over networks, you know you to be safe.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 16.

We do not knowingly solicit data from or market to children under 16. Using the Sites or Apps, you represent that you are at least 16. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under the age of 16, please contact us at [email protected]

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have rights that allow greater access to and control over your personal information. You may review, change, or terminate your account at any time.

If you are a resident of the UK or the EEA, then the following information about your rights is relevant to you. This part of the privacy policy is a mandatory statement summarising certain laws applicable in your jurisdiction. It is not a replacement for, nor an extension of, your legal rights, so it should be read-only as a summary of that legislation.

This section does not apply to you if you do not reside in one of the regions described above.

You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information that is visible to us, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to processing your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however that this will not affect the lawfulness of the processing before its withdrawal.

We have no visibility to the information stored in your secure digital vault.

If you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority, the Information Commissioner’s Office (ICO).

How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request via d[email protected]. We will respond to your request within 30 days.

Account Information

If you would, at any time, like to review or change the information in your account or terminate your account, you can:

■ Log into your account on https://app.meavitae.com and update your user profile.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails necessary for the administration and use of your account.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

In Short: We do not currently support ‘Do-Not-Track’ technology.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference and not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

10. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy to stay compliant with relevant laws.

We may update this privacy policy at any time to reflect changes to our business or the law. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO) by email at [email protected] or by post to:

The Data Protection Officer

MeaVitae Limited

Data Protection Officer (DPO)

1a The Quadrant Courtyard

Weybridge, KT13 8DR

United Kingdom