Genes Reunited Legal
Your privacy is a top priority for Findmypast. We are dedicated to looking after your Personal Information in a way you feel is 100% safe and secure, handling it in a responsible manner and complying with data protection laws.
When it comes to your privacy, we follow 3 main principles:
Transparent. We want to be transparent about the personal information we collect, why we collect it and how we process it.
Control. We give you control over the Personal Information you provide to us. We let you choose how and when it is used, shared, kept or deleted.
Our full Privacy Statement is below and we suggest you take the time to read and understand it.
This policy includes:
- 1. About us
- 2. The information we gather and track
- 3. Emails from Genes Reunited
- 4. Sharing with other websites and applications.
- 5. Sharing and use of information
- 6. What if I don’t provide some or all of the information requested?
- 7. What grounds (legal basis) are we processing the data under?
- 8. Sharing your information with third parties
- 9. Sale of the Business
- 10. Cookies
- 11. How we protect your data
- 12. Your rights regarding your personal information
- 13. Right of complaint to the Regulator for Data Protection
- 14. How long we hold your data for
- 15. Removing your profile from the Genes Reunited Service
- 16. Links to third-party websites
- 18. Contacting us
1. About us
This website https://www.genesreunited.co.uk/ is owned and operated by Findmypast Limited (FMP), a company registered in England and Wales no. 04369607, having its registered offices at The Glebe, 6 Chapel Place, Rivington Street, London, EC2A 3DQ.
Genes Reunited is committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of the data protection legislation in the UK and we are registered on the Data Protection Public Register number Z6639808. Our Data Protection Officer will be happy to deal with any queries or requests regarding the data we hold about you. They can be contacted at email@example.com or by post to Data Protection Officer, The Glebe, 6 Chapel Place, Rivington Street, London, EC2A 3DQ.
2. The information we gather and track
We always aim to gather only the information that we need in order to provide you with the service you have subscribed to.
Registration and other information. When you register for the Genes Reunited Service, you provide your name (including a previous name, where relevant), your email address, your gender, your year of birth and country of residence and some optional information about yourself such as place of birth. They are available to you, and capable of being changed, through the My Account page. We also receive information from you when you pay for a product, get in contact with us, and sometimes when you reply to a survey. Sometimes, we may ask you to provide other contact details to carry out our surveys, such as phone number or address. You will always be given the option to withhold additional contact details at the time you complete the survey.
Information you choose to share. If you create content on the website, which may include uploading personal information in the My Account section or uploading family trees, photos, videos, comments and notes, we also receive that information. This may include personal information about you and other people (for example, details about other individuals in your family tree).
Information other members share about you. We may also receive information from other members, such as when they upload content relating to you or post comments in relation to your uploaded content.
Other information we receive about you. We do not collect sensitive information (also known as special categories of information) about you except when you specifically knowingly provide it and have consented to this. Examples are adding your religious belief to a family tree. More details about the privacy of the family tree are available below.
We also receive some information about the computer or other device you use to access your service, such as your IP address, the browser you use, your location, how big your screen is, or the pages you visit.
When you upload a photo or video, we may also receive additional information through metadata about where that photo or video was taken, such as the time, date and location.
We may also receive statistical information that does not personally identify you from our advertising partners who work with us to deliver more relevant, higher quality advertising to you on the website and to understand online activity.
In order to purchase a subscription or credits for Findmypast you must be over 18 years old. More information about our age restrictions can be found in our terms and conditions.
3. Emails from Genes Reunited
You are probably most interested in how we will use your email address to communicate with you, so here's our email promise, in plain English.
Service Emails. The team at Genes Reunited hate spam and will never send you unsolicited emails. But there are some emails that we will need to send you to provide you with a good Genes Reunited service. These include notifications that you have a message from another member, reminders about your membership expiring and guides on how to use the site. A full list of the types of emails you will receive to help you use the service most effectively (which we call Service Emails) are shown below:
- Welcome emails - this series of emails provide all the information you need to get started on Genes Reunited.
- Payment receipt - this is sent if you upgrade to Full Membership
- Renewal notices - these remind you to renew your Full Membership
- Automatic Full Membership renewal alerts - if you have selected automatic renewal of your Full Membership, we will alert you before this happens
- Key service messages - if we need to notify you about changes to the service
- New message notification and reminders - when you receive messages from other Subscribed Members
- Service suspension notices - if you break the house rules
Newsletters. When registering, you are given the option to receive our occasional newsletters. We use these to notify you about new features on the site, ask your opinion, and tell you about services you might not be using yet. We only send a newsletter when there is something worthwhile to tell you about. Generally, you'll get a newsletter about once a month.
Email Preferences. If you decide you no longer want to receive these emails - or if you aren't currently receiving it and want to - all you need to do is change your email preferences. You'll find this in the My Account area once you're logged in.
4. Sharing with other websites and applications
Logging into the website using Facebook. You can log in to the website using the Facebook Platform. When you log in using Facebook, Facebook shares selective information with us, such as your gender, date of birth, name and location, but we do not share information we hold about you with Facebook through your use of this facility.
Sharing links from Genes Reunited. By using the 'Share' links which may be available on the website, you can share links to certain content with non-members using Facebook, Twitter and email. The content will remain at all times on the website and only the link and other limited information will appear on Facebook and Twitter, or in the email. There are restrictions on the sharing of content that we provide to you on the website. You can find out more about these restrictions in our Terms and Conditions.
5. Sharing and use of information
- Managing the website (including your account);
- Providing advanced website features to you;
- Suggesting and providing relevant content to you on the website;
- For analysis to understand your needs to help us improve the website;
- Improving search results;
- Understanding website usage to help us improve our marketing or the way we do business;
- Sending you emails and other communications;
- We may show you relevant advertising on third party sites (e.g. Facebook, Google, and Twitter);
- We may use and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
- We use IP addresses and device identifiers to identify the location of users, to establish the number of visits from different countries, to limit/cap adverts of a certain type, and to personalise content and emails.
You give us permission to use your information for the above purposes in relation to our current service, and also in relation to any new products and features which we may provide to you in the future as part of our service.
The over-riding principles we apply are these:
- We, and (where relevant) our credit card processing agents will not supply your information to a third party for commercial exploitation - thus, you can rest assured that we will not sell the lists of our Members' email addresses to a third party;
- We occasionally use third-party companies to process information that you provide us with: for example, when you complete a survey or make a payment. When we do, we keep the amount of personal information they hold to an absolute minimum, have contracts in place to stop them using your information except on our behalf and require them to ensure they are as careful with your information as we are; and
Registration and Family Tree Information. The details you provide on Registration, and the details of those you enter into your family tree are only available to you, except that names, year of birth and place of birth for you and those in your tree are searchable by other Members. Details in your family tree can be shared with other members at your discretion. If you would like to hide details of all living relatives in your family tree, you can do so by visiting the 'My Account' page and choosing Yes in the 'Hide Living Relations' drop-down menu. Search results from your tree will only be associated with you by your first name (which will be displayed together with the search results). Your email address is never revealed.
Emailing through the Genes Reunited Service. We do not directly make your email address available to anyone on any screen of the Genes Reunited Service. The only legitimate way of making contact with a Member on the Genes Reunited Service is for a subscribed Member to enter a message that we will send on the Member's behalf. We will notify the addressee Member, using the email address he/she has provided to us, that Genes Reunited is holding an email for him/her, and the Member can collect the email when logged in to the Genes Reunited Service. Members may check and (if required) change the email address we hold for them at any time through "My Account/Email Address". Members' personal notes must not include their email address. Sent and received email may appear in a Member's Inbox on the Genes Reunited Service for an indefinite period - we do not delete it after any specific period. However, this does not mean that we will retain your email forever; there may come a time when we will need to delete some or all of it, for technical or other reasons. In this event, we will endeavour to give you advance warning that we are going to do so.
Advertising The Genes Reunited Service may include interactive advertising for other businesses. We may use, and provide to third parties, anonymised demographic data provided by Members to target this advertising more appropriately. Please see our cookies policy for more information.
Credit or debit card information. We use Worldpay plc and Datacash as our payment providers. Both operate a secure server, to process our card payments. They encrypt Members' credit or debit card information and authorise payment directly. This means that Members' full card details are never revealed to or held by us. Worldpay plc or Datacash may transfer to, process and hold your card information in countries either within or outside the European Economic Area in connection with performing their duties.
Companies in the Genes Reunited group. We may share data supplied by you (or collected about you) with our subsidiaries and other companies in our group (meaning Genes Reunited Limited, brightsolid Online Innovation Limited, and any of their subsidiaries from time to time), but only for the purposes described in this policy or if we are required or otherwise permitted to do so by law. In general, we try to make sure that people only have as much access to your information as they need to carry out their job.
6. What if I don’t provide some or all of the information requested?
The impact of this will depend on what information you withhold, but the main impacts may be:
- We will not be able to process or fully process your order.
- We will not be able to contact you to let you know of problems regarding your order or the goods/services provided.
- We will not be able to respond fully to requests and queries you may have.
- We cannot personalise the service you receive. So, if you are online you will have to search more for the content type you normally view or for similar/related products.
- We won’t be able to limit online adverts to products or services you have shown interest in and so you may receive adverts that are not related to your interests.
7. What grounds (legal basis) are we processing the data under?
There are a number of grounds we process your data under. These are:
- Contractual – we need the information to perform the contract for goods or services you have requested/ordered including payment, delivery etc.
- Legal – should we be legally required to contact you concerning a purchase or service.
- Legitimate interest – this means the processing is in Genes Reunited’s interest. It allows us to manage the customer relationship effectively and efficiently and improve the goods and/or services we provide by better understanding how our online provisions are used and which goods are popular with which groups of individuals.
- Consent – where you have given us consent to market to you.
8. Sharing your information with third parties
We may from time to time provide your personal information to third parties for the purposes of providing you with our services. These third-party providers include payment processors, providers of card validation services, and credit referencing providers. This is necessary for the performance of the contract. We do not keep a record of your credit or debit card details in our systems. Our payment processors do not decide what is done with your data and only process it on our behalf. These third parties may be located outside the European Economic Area; however, we only use providers that provide adequate protection for your information at all times.
When transferring and storing any personal information outside the EEA we only do so under one of the legally recognised transfer mechanisms for ensuring the data is safeguarded. These are:
- The country in question has been deemed safe for data transfer by the European Commission. Also known as an adequacy finding.
- The contract for data processing contains the standard contractual clauses laid down by the European Commission to safeguard the transfer of personal data.
- Binding corporate rules – this is where a large company’s own internal processes for international data transfer have been signed off and agreed by the European Commission as safeguarding the data.
- If the data is going to the USA it can be safely transferred to a company that is certified under the EU-US Privacy Shield.
- Appropriate certification schemes
We will disclose your personal data in order to comply with any legal obligation. This includes disclosing information to organisations for the purposes of fraud protection, credit risk reduction, or the order of a court or regulator.
We also share your details with service providers who assist us with hosting our marketing campaigns and surveys, but only in cases where you have consented to marketing or surveys. We will not provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us. You are entitled to decline receiving such third-party communications by not selecting the appropriate box on the web form that collects your details or at any subsequent time by logging into your account and adjusting your preferences, by contacting us by email at firstname.lastname@example.org or by post to Genes Reunited, 6 Chapel Place, Rivington Street, London EC2A 3DQ.
9. Sale of the Business
In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.
We do collect some information from cookies and similar software that allows us to understand how you arrive on our websites and use and navigate around them so we can improve the sites. We obtain some information from Google Analytics and Facebook. The Facebook information provided is limited to your email address and only that which you have previously agreed with Facebook that they may share.
11. How we protect your information
We follow strict security procedures in the storage and disclosure of information which you have given us, to prevent unauthorised access to, and loss, misuse or alteration of your personal information in accordance with UK data protection legislation. These include firewalls and virus-checking procedures.
You are responsible for keeping secret any confidential passwords or other login or access details that you select or which we allocate to you. While we take steps to ensure the security of your information, there is a risk that any information transmitted over the Internet and stored on a computer may be intercepted or accessed by an unauthorised party. It remains each Member's responsibility:
- to protect against unauthorised access to Your Details;
- to ensure no-one else uses the Genes Reunited Service on that Member's machine while it is "logged on" to the Genes Reunited Service;
- to log off or exit from the Genes Reunited Service when not using it; and
- to keep his/her password secret.
If you think that someone has accessed your information held by us without your permission or gained unauthorised access to your login details, you must notify us at email@example.com
We also recommend that if you use a shared computer or a computer in a public place such as a library that you close your browser when you have finished your session.
12. Your rights regarding your Personal Information
Under the Data Protection law, you have a number of rights with respect to your personal information, which are:
- Correcting your Information
You are entitled to have your personal information updated to ensure it is up to date and accurate. In order to maintain the accuracy of the information we hold, you can update your personal details through your ‘My Account’ page or by sending us an email to firstname.lastname@example.org.
- Withdrawing Consent
You have the right to withdraw your consent to any processing that is currently being done under your consent, such as marketing. Consent can be withdrawn by updating your preferences in the email preference centre or through ‘My Account’. You can also email to email@example.com.
- Obtaining a copy of your Information
You have the right to receive a copy of the personal information we hold about you. You can do this by contacting firstname.lastname@example.org from the email address attached to your account, providing the full name attached to your account.
- Deleting your information
You can request that we delete personal information in certain circumstances. These will be specific to each case. You can do this by contacting email@example.com from the email address attached to your account, providing the full name attached to your account
- Data Portability
You have the right to ask us to transfer the personal information that you have given us to another controller.
- Restricting Processing
You can request a restriction on the processing of your data in some limited circumstances. Examples are concerns over data accuracy or we no longer need to hold your data but you have requested its retention by us to aid you in a legal matter. You can do this by contacting firstname.lastname@example.org from the email address attached to your account, providing the full name attached to your account.
- Right to object to processing
You have the right to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc. (also known as profiling).
You can action any of these rights by contacting our Customer Support Team or by contacting us by email at email@example.com or by post to Data Protection Officer, Genes Reunited, 6 Chapel Place, Rivington Street, London EC2A 3DQ.
13. Right of complaint to the Regulator for Data Protection
The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this via the ICO’s website, follow the links or have an online Live Chat.
Call the ICO helpline on 0303 123 1113
Postal address: Information Commissioner's Office
14. How long we hold your data for
Some of the information you provide to us will be necessary to carry out repeated tasks, such as verifying your identity or payment details when signing in to use an account, providing our services to you or when you are using an online checkout. We will keep this information for as long as you remain a registered user of any of our sites and for so long as reasonably necessary. After this time, we may need to hold your personal data in order to meet our financial obligations or identify or resolve issues or causes of action.
If your account is inactive for more than five years and you are no longer paying for a service, we reserve the right to delete any information you have provided to us, including all information in your family tree. We will send an email to the address attached to your account before deleting the information in your family tree.
15. Removing your profile from the Genes Reunited Service
You may remove your profile from the website by clicking here. Any public content you have added to the website will remain; however, your profile page will not be accessible, and other subscribed Members will not be able to contact you. Any content you chose to share publicly, understandably, may be copied or stored by other subscribed Members even after your profile has been removed. When your profile has been removed, we will archive and store your information for a reasonable time period for legal and administrative reasons and for the purposes of re-activating your account with us, if you wish to do so.
16. Links to third-party websites
17. Updates to this policy
We may update this policy at any time without notice. We will tell you that we have updated the policy by emailing you at the email address you have provided to us and/or by posting an announcement on the website. By continuing to use the website after we have emailed you or posted a notice informing you of an update, you accept the changes to this Policy.
Privacy statement last updated 8 May 2018.
18. Contacting us
If you have any questions about privacy, or wish to update your details or have them removed from our mailing list at any time, please contact us at:
Post: Data Protection Officer
6 Chapel Place
London EC2A 3DQ