Privacy Policy

This document describes how GENOGRA S.r.l. processes the personal data of users who visit the website https://genogra.com/ (“Website”) and of the business contacts with whom it communicates, including people met at trade fairs and events, prospects, customers, partners and recipients of its newsletters and marketing emails (together, “User/Users”).

This privacy notice is provided pursuant to Art. 13 et seq. of Regulation (EU) 2016/679 (“GDPR”) and Art. 122 of Legislative Decree 196/2003 (“Privacy Code”). It does not apply to other websites that may be accessed via links on the Website or in GenoGra’s emails.

1. Data Controller

The data controller is GENOGRA S.r.l., with registered office at via Giorgio Chavez no. 4 – 20131 Milan, Italy, Tax Code and VAT no. 12995970964, Business Register no. MI-2697589; email: info@genogra.com (“GenoGra” or “Data Controller”).

2. Categories of personal data processed

2.1 Navigation data

The computer systems and software procedures used to operate the Website acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified persons, but by its very nature could allow Users to be identified. This category includes: (i) IP addresses or domain names of the computers used by Users who connect to the Website; (ii) URI (Uniform Resource Identifier) addresses of the requested resources; (iii) the time of the request; (iv) the method used to submit the request to the server; (v) the size of the file returned in response; (vi) the numerical code indicating the status of the server’s response (successful, error); and (vii) other parameters related to the User’s operating system and IT environment.

This data is used solely to obtain anonymous statistical information on the use of the Website and to ensure its proper functioning, and is deleted immediately after processing.

2.2 Cookie

For more information about the use of cookies on the Website, please see the cookie policy.

2.3 Data provided voluntarily by the User

Any optional, explicit and voluntary sending of email to the addresses indicated on the Website entails the collection and processing by the Data Controller of such data and of any other information contained in those communications, for the purposes described in point 3 of section 3 below.

Completing the online form for information requests, available in the “Contact us” section of the Website, entails the collection and processing of the User’s personal data (first and last name, affiliated company, job title, genomic analysis focus) and of any other information contained in those communications, for the purposes described in point 3 of section 3 below.

2.4 Data published on social media

The Data Controller processes the data that the User posts on its social media pages (such as LinkedIn and Instagram) through the functionalities of the social media platforms that the User has enabled when registering on those platforms, for the purposes described in point 1 of section 3 below.

2.5 Business contact data and marketing communications

GenoGra processes the business contact data of the people it communicates with: first and last name, business email address, phone number, company or institution, job title and area of interest. GenoGra also keeps a record of the communications exchanged and of the User’s subscription preferences.

This data is collected:

  • directly from the User, for example through the forms on the Website, by email or in meetings;

  • at trade fairs, conferences and events, when the User has their badge scanned at GenoGra’s booth through the lead-retrieval app made available by the event organiser. In this case the data is shared with GenoGra by the organiser, on the basis of the consent the User gave to the organiser when registering for the event;

  • through business introductions and publicly available professional sources.

GenoGra uses this data to send newsletters, event invitations, product updates and other marketing communications about its platform and activities, for the purposes described in point 4 of section 3 below. The User can choose which communications to receive, or unsubscribe from all of them, at any time through the “Manage preferences” and “Unsubscribe” links in every email.

2.6 Email tracking

GenoGra’s newsletters and marketing emails sent to Users who have given their consent contain tracking pixels and tracked links. A tracking pixel is a tiny, invisible image that is downloaded when the email is opened. A tracked link records when the User clicks on it.

Through these tools GenoGra collects:

  • whether and when the email was opened, and how many times;

  • which links were clicked;

  • technical data such as the type of device, operating system and email client, and the approximate location derived from the IP address.

This information is linked to the individual recipient and stored in GenoGra’s email marketing platform (HubSpot). GenoGra uses it to measure the effectiveness of its campaigns and to send communications that are more relevant to the User’s interests, for the purposes described in point 5 of section 3 below.

Users who have not given their consent receive GenoGra’s emails without tracking pixels or tracked links.

The User can give or withdraw consent to email tracking at any time, while continuing to receive GenoGra’s communications, through the “Manage preferences” link in every email or by writing to privacy@genogra.com. The choice applies to the following emails and is recorded by GenoGra.

3. Purposes and legal basis for the processing

The Data Controller processes the User’s personal data for the following purposes:

  1. to manage interactions with Users (comments, posts) on its social media pages, pursuant to Art. 6.1 (f) GDPR. Regarding the processing carried out by the administrators of the social media platforms, please refer to the privacy notices of those platforms;

  2. to pursue its legitimate interest, pursuant to Art. 6.1 (f) GDPR, in ensuring the security of the Website and of the information exchanged through it, i.e. the ability of the Website to withstand, at a given level of security, unforeseen events or unlawful or malicious acts that compromise the availability, authenticity, integrity and confidentiality of the personal data stored or transmitted, as well as the security of the related services;

  3. to respond to requests submitted by the User via email to the addresses indicated on the Website or through the contact form, pursuant to Art. 6.1 (b) GDPR;

  4. to send newsletters, event invitations and other marketing communications about GenoGra’s platform and activities: on the basis of the User’s consent pursuant to Art. 6.1 (a) GDPR, including the consent given to the event organiser for contacts collected at trade fairs, or, for business contacts with whom GenoGra already has a professional relationship, on the basis of GenoGra’s legitimate interest in promoting its services pursuant to Art. 6.1 (f) GDPR. The User can object or withdraw consent at any time, without affecting the lawfulness of the processing carried out before;

  5. to track the opening of emails and the clicks on their links, as described in paragraph 2.6: on the basis of the User’s consent pursuant to Art. 122 of the Privacy Code and Art. 6.1 (a) GDPR, given together with the consent to receive marketing communications or through the “Manage preferences” page linked in every email. This consent can be withdrawn at any time from the same page, without unsubscribing from the communications.

4. Consequences of any refusal to provide data

Providing personal data for the purposes described in section 3 is optional. However, failure to provide the data needed for purposes 1 to 3 would make it impossible for the User to communicate with the Data Controller and for the Data Controller to fulfil the User’s requests and to ensure the security of the Website.

Refusing or withdrawing consent for purposes 4 and 5 has no consequences other than not receiving GenoGra’s marketing communications or, for purpose 5 only, not having one’s interaction with GenoGra’s emails tracked individually.

5. Methods of data processing

Personal data is processed using electronic or, in any case, automated, IT or telematic tools, with logic strictly related to the purposes described above and in a manner that ensures the security of the data.

The User’s personal data is processed by individuals who have been duly authorised, identified and/or appointed, appropriately trained and made aware of the legal obligations imposed by applicable law. The data is protected by security measures designed to safeguard the User’s privacy and to prevent loss or destruction, unauthorised access and processing that is unlawful or not in line with the purposes above. Security measures are continuously improved in line with technological developments.

6. Recipients of data

Personal data shall not be disclosed, sold or transferred to third parties, except in the cases provided for by law.

Without prejudice to the foregoing, data may be communicated to companies expressly appointed to carry out specific services within the Data Controller’s activities or on its behalf. Such entities act as independent data controllers or data processors, as appropriate. In particular, marketing communications are sent through HubSpot, Inc., which acts as data processor on behalf of GenoGra and stores contact data and email engagement data. Data of contacts collected at events is received from the event organisers, who act as independent data controllers for the processing they carry out.

Data may also be disclosed, in accordance with the law, to law enforcement authorities, judicial authorities, intelligence and security agencies or other public entities for purposes related to national defence or security, or for the prevention, investigation or prosecution of criminal offences.

7. Data retention period

The User’s personal data is processed only for the time strictly necessary to achieve the purposes set out in section 3. Thereafter, it is retained solely to comply with legal obligations, for administrative purposes and/or for the establishment, exercise or defence of legal claims in the event of disputes or pre-litigation proceedings.

Business contact data processed for marketing purposes is kept until the User unsubscribes or withdraws consent, and in any case for no longer than 24 months from the User’s last interaction with GenoGra. Email tracking data already collected is kept for the same period. After the User withdraws consent to tracking, no new tracking data is collected.

8. Transfer of data outside the EU

User data may be transferred to countries outside the European Union, in accordance with Art. 44 et seq. GDPR, including through the service providers mentioned in section 6. Such transfers take place on the basis of an adequacy decision adopted by the European Commission (Art. 45 GDPR) or, for countries where no such decision exists, on the basis of appropriate safeguards such as standard contractual clauses or other suitable instruments pursuant to Art. 46 GDPR.

9. Data subjects’ rights

The User, as data subject, holds the rights granted by the GDPR. In particular, pursuant to Art. 15 et seq. GDPR, the User has the right, at any time and free of charge, to obtain information about the existence of any processing of their data and its retention period, to obtain a copy, and to request the rectification, supplementation, update or erasure of the data. The User also has the right to request the restriction of the processing, to receive the data in a commonly used and machine-readable format, to object to the processing and to lodge a complaint with the competent supervisory authority.

The User can withdraw consent to marketing communications at any time through the “Unsubscribe” link in every email, and withdraw consent to email tracking only through the “Manage preferences” link in every email or by writing to privacy@genogra.com, continuing to receive GenoGra’s communications.

To exercise these rights, Users may submit a written request to privacy@genogra.com.

***

This privacy policy was last updated on 29 October 2026. Any updates will always be published on this page.