Safe Harbor Privacy Policy

The DNA Hustisya Project (TDHP) is a leading provider of private DNA testing to the Philippines, Southeast Asia and the world. We offer comprehensive DNA testing services in several specialty areas, focusing primarily on relationship establishment.

Protecting the privacy of our clients is important to us and so TDHP and its subsidiaries, branches, divisions, and business units adhere to the Safe Harbor Principles published by the U.S. Department of Commerce with respect to all such data.

This statement outlines the general policy and practices of TDHP for implementing these Principles, including the types of information we gather, how we use that information, the choices affected individuals have regarding TDHP’s use, and the individual’s ability to correct, that information.

Set forth below is TDHP’s Privacy Policy:

Scope

This Policy applies to all personal information received by TDHP in the Philippines from the European Union (EU) in any format, including electronic, paper, or verbal.

Definitions

The following definitions apply throughout this Policy:

Agent

Any third party that uses personal information provided to TDHP to perform tasks on behalf of and under the instruction of TDHP.

TDHP

The DNA Hustisya Project, its subsidiaries, branches, divisions, and business units in the Philippines.

Personal Information

Any information or set of information that identifies an individual, or could be used by or on behalf of TDHP to identify an individual. Personal information does not include information that is publicly available that has not been combined with non–public personal information.

Sensitive Personal Information

Personal information that reveals race, ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, TDHP will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

Privacy Principles

Notice

When TDHP collects personal information directly from individuals in the EU, it will inform them about the purposes for which it collects their personal information and the choices and means, if any, that TDHP offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to TDHP, or as soon as practicable thereafter, and in any event before TDHP uses or discloses the information for a purpose other than that for which it was originally collected.

If TDHP receives personal information from its subsidiaries, affiliates, or other entities in the EU, it will use such information in accordance with the notices such entities provided and the consents or choices made by the individual about whom such personal information relates.

Choice

TDHP will offer individuals the opportunity to choose whether their personal information is (a) to be disclosed to a non-agent third party (unless allowed or required by contract), or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, TDHP will give individuals the opportunity to affirmatively and explicitly consent (e.g., through a signature) to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. TDHP will provide individuals with reasonable methods to exercise their choices.

Data Integrity

TDHP will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. TDHP will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

Onward Transfer

TDHP will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. If TDHP has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, TDHP will take reasonable steps to prevent or stop the use or disclosure.

Access

Upon request, TDHP will grant individuals reasonable access to personal information that it holds about them. In addition, TDHP will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

Security

TDHP will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

Enforcement

TDHP will conduct compliance reviews of its relevant privacy practices to verify adherence to this Policy. Any employee that TDHP determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution

Any questions or concerns regarding the use or disclosure of personal information should be directed to the TDHP Privacy Department at the address given below. TDHP will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy. For complaints that cannot be resolved between TDHP and the complainant, TDHP has agreed to participate in the dispute resolution using JAMS International as a third party resolution provider to resolve disputes pursuant to the Safe Harbor Principles.

Limitation on Application of Principles

Adherence by TDHP to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule, or regulation.

Contact Information

Questions or comments regarding this policy should be submitted to:

The DNA Hustisya Project
Attn: Privacy Department—Safe Harbor
Fuentes Square II, Barangay Cagay
Roxas City, Capiz
Philippines 5800
036.620.0481

email via our Contact Us page

Changes to this Policy

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. TDHP will post appropriate notice about such changes and amendments.

The DNA Hustisya Project complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. TDHP has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view DNA Diagnostics Center’s certification, please visit http://www.export.gov/safeharbor.