Privacy Policy

Purpose of this privacy policy

This privacy policy aims to give you information on how 20/30 Labs Ltd (“We”,
“Us” or “Our”)
collects
and processes your personal data through your use of this website and in relation to the provision of
the goods/services we provide. This website is not intended for children and we do not knowingly collect
data relating to children. You must be over the age of 18 to purchase services from us. It is important
that you read this privacy policy together with any other privacy policy or fair processing policy we
may provide on specific occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. This privacy policy supplements other notices
and privacy policies and is not intended to override them.

Controller

We are the data controller and we are responsible for your personal data. Our finance
director takes
responsibility for overseeing the protection of your personal data and is responsible for overseeing
questions in relation to this privacy policy. If you have any questions about this privacy policy,
including any requests to exercise your legal rights in relation to it or its subject matter, please
contact our IT helpdesk in the first instance stating that your request relates to 20/30 Labs Ltd, they
will route your enquiry accordingly.

Email address: helpdesk@blucando.it

You have the right to make a complaint at any time to the Information Commissioner’s Office
(“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however,
appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the
first instance.

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review. It is important that the personal data we
hold about you is accurate and current. Please keep us informed if your personal data changes during
your relationship with us.

Third-party links.

This website may include links to third-party websites, plug-ins and applications. Clicking
on those links or enabling those connections may allow third parties to collect or share data about you.
We do not control these third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy policy of every website you visit.

Personal data means any information about an individual from which that person can be
identified.
It does not include data where the identity has been removed (anonymous data). We may collect, use,
store and transfer different kinds of personal data about you (including a person being tested if that
person is different to the person/business ordering a testing service) which we have grouped together as
follows:

• Identity Data includes first name, last name, username or similar identifier, title, gender and
  test results.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of services
  you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and
  version, time zone setting and location, browser plug-in types and versions, operating system
  and platform, and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website and health testing services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and
  our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any
purpose. Aggregated Data could be derived from your personal data but is not considered personal
data in law as this data will not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal data which will be used in accordance
with this privacy policy.

We do not generally collect any Special Categories of Personal Data about you but you may elect to
provide it (this includes details about your race or ethnicity). However, your health testing
results may generate health data and medical information about you and we will share that data only with
you for the purposes of communicating your test results to you. By purchasing goods/services, you
explicitly consent to us communicating with the person/organisation who made the booking.

We use Stripe for payment, analytics, and other business services. Stripe collects identifying
information about the devices that connect to its services. Stripe uses this information to operate and
improve the services it provides to us, including for fraud detection. You can learn more about Stripe
and read its privacy policy at https://stripe.com/privacy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and
you fail to provide that data when requested, we may not be able to perform the contract we have or are
trying to enter into with you and will notify you at the earliest opportunity.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by a number of
  methods, filling in forms or by corresponding with us by post, phone, email or otherwise. This
  includes personal data you provide when you apply for our health testing services or create an
  account on our website.
• Automated technologies or interactions. As you interact with our website, we will
  automatically collect Technical Data about your equipment, browsing actions and patterns. We
  collect this personal data by using cookies, server logs and other similar technologies. We may
  also receive Technical Data about you if you visit other websites employing our cookies. Please
  see our separate cookie policy for further details
• Third parties or publicly available sources. We will receive personal data about you
  from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google based outside the United Kingdom;
  • Contact, Financial and Transaction Data from providers of technical, payment and
    delivery services based both inside and outside the United Kingdom.

We will only use your personal data when the law allows us to. Most commonly, we will use
your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you
  and processing your personal data is necessary for the performance of or entry into the
  contract;
• Where it is necessary for our legitimate interests (or those of a third party) and your
  interests and fundamental rights do not override those interests. Broadly, legitimate interest
  means the interest of our business in conducting and managing our business to enable us to give
  you the best service and the best and most secure experience. We make sure we consider and
  balance any potential impact on you (both positive and negative) and your rights before we
  process your personal data for our legitimate interests. We do not use your personal data for
  activities where our interests are overridden by the impact on you (unless we have your consent
  or are otherwise required or permitted to by law). You can obtain further information about how
  we assess our legitimate interests against any potential impact on you in respect of specific
  activities by contacting us;
• Where we need to comply with a legal obligation we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data
although we will get your consent before sending third party direct marketing communications to you via
email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We use your personal data as that we can meet performance obligations in relation to any contract we
have agreed with you, and for other legitimate purposes that are directly related (i.e recover debts
from you, meet our legal obligations, assess the effectiveness of our marketing activities).

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which services and offers may
be relevant for you (we call this marketing). You will receive marketing communications from us if you
have requested information from us or purchased services from us and you have not opted out of receiving
that marketing.

We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us
as a result of a service purchase.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information about the cookies we use, please see our
cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we
will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out above:

• External third parties as follows:
  • service providers acting as processors based both inside and outside the United Kingdom
    who provide services such as payment processing, internet hosting, IT and system
    administration;
  • delivery/courier service providers located in the United Kingdom;
  • professional advisers including lawyers, bankers, auditors and insurers based in the
    United Kingdom who provide consultancy, banking, legal, insurance and accounting
    services;
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who
    require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our
  assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change
  happens to our business, then the new owners may use your personal data in the same way as set
  out in this privacy policy.

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 may transfer your personal data outside the United Kingdom, for example, to the external third
parties mentioned in section 5 above. Whenever we transfer your personal data out of the EEA, we ensure
a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:

• the country in which your personal data is received has been deemed to provide an adequate level
  of protection for personal data by the European Commission;
• where we use certain service providers, we may use specific contracts approved by the European
  Commission which give personal data the same protection it has in Europe;
• where we use providers based in the US, we may transfer data to them if they are part of the
  Privacy Shield which requires them to provide similar protection to personal data shared between
  Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring
your personal data out of the United Kingdom.

We have put in place:

• appropriate security measures to prevent your personal data from being accidentally lost, used
  or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your
  personal data to those employees, agents, contractors and other third parties who have a
  business need to know. They will only process your personal data on our instructions and they
  are subject to a duty of confidentiality; and
• procedures to deal with any suspected personal data breach and will notify you and any
  applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We may retain your personal data for a longer period in the event of a complaint
or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal, regulatory, tax, accounting or other
requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for 6 years after they cease being customers.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes, in which case we may use this information indefinitely
without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal
data. You have the right to:

1. Request access to your personal data (commonly known as a “data subject access request”).
   This enables you to receive a copy of the personal data we hold about you and to check that we
   are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have
   any incomplete or inaccurate data we hold about you corrected, though we may need to verify the
   accuracy of the new data you provide to us.
3. Request erasure of your personal data. This enables you to ask us to delete or remove
   personal data where there is no good reason for us continuing to process it. You also have the
   right to ask us to delete or remove your personal data where you have successfully exercised
   your right to object to processing (see below), where we may have processed your information
   unlawfully or where we are required to erase your personal data to comply with local law. Note,
   however, that we may not always be able to comply with your request of erasure for specific
   legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing of your personal data where we are relying on a legitimate interest
   (or those of a third party) and there is something about your particular situation which makes
   you want to object to processing on this ground as you feel it impacts on your fundamental
   rights and freedoms. You also have the right to object where we are processing your personal
   data for direct marketing purposes. In some cases, we may demonstrate that we have compelling
   legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing of your personal data. This enables you to ask us to
   suspend the processing of your personal data in the following scenarios:
   • if you want us to establish the data’s accuracy;
   • where our use of the data is unlawful but you do not want us to erase it;
   • where you need us to hold the data even if we no longer require it as you need it to
     establish, exercise or defend legal claims; or
   • you have objected to our use of your data but we need to verify whether we have
     overriding legitimate grounds to use it.

6. Request the transfer of your personal data to you or to a third party. We will provide to
   you, or a third party you have chosen, your personal data in a structured, commonly used,
   machine-readable format. Note that this right only applies to automated information which you
   initially provided consent for us to use or where we used the information to perform a contract
   with you.
7. Withdraw consent at any time where we are relying on consent to process your personal data.
   However, this will not affect the lawfulness of any processing carried out before you
   withdraw your consent. If you withdraw your consent, we may not be able to provide certain
   services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your
right to access your personal data (or to exercise any of your other rights). This is a security measure
to ensure that personal data is not disclosed to any person who has no right to receive it. We may also
contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than a
month if your request is particularly complex or you have made a number of requests. In this case, we
will notify you and keep you updated.