Privacy Policy

Your Data - You Own it, We Respect it. We follow guidance from the UK ICO, EU GDPR and the upcoming Jamaican Data Protection Act.

Privacy Notice

At Whos The Daddy we understand that protecting the privacy of visitors to our website is very important. Whos The Daddy respects your privacy and is committed to protecting your personal information.

This notice explains how and why we use personal information when you visit our website (regardless of where you visit it from), including any information you may provide when you use our ‘contact us’ form. It also provides details of how we use cookies and similar technologies to enable you to browse our website effectively.

Our website is not intended for children and we do not knowingly collect information relating to children without parental or guardian express written consent.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are fully aware of how and why we are using your information. This privacy notice supplements the other notices and is not intended to override them.

If you would like further details about how we protect your personal information at Whos The Daddy , please email our Compliance Team at compliance@whosthedady.net and we’ll contact you as soon as possible.

About us

Whos The Daddy is a brand of Aqua Sports & Entertainment Xaymaca Ltd. A company legally registered in Jamaica under Company No 88584.

Whos The Daddy is the controller and responsible for your personal information. Our Compliance Officer is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Compliance Officer at compliance@whosthedaddy.net

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.

We also follow the GDPR EU regulation. Although the UK left the EU on 31st January 2020 it entered into a transitional period that ended on 31st December 2020. Since this point we have and will continue to follow the new UK GDPR as according to the "Keeling Schedual for UK GDPR" published by the UK Government

What information we collect

Personal data, or personal information, 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 personal information about you when you access our website and employ our services, as follows:

Information you provide directly to us

Identity Data – includes your name, date of birth, title, gender, ethnicity and company name (if applicable). We may collect your presumed relationship status to other individuals. If you apply for a role at Whos The Daddy you will be asked to send your CV and a covering letter which may include additional information about yourself.
Contact Data – includes your e-mail address, home address and telephone number.

Financial Data – includes your financial details which will be used for the purposes of processing payments in accordance with your contract with us.
Biometric Data – Includes photographic images for the purposes of confirming your ID.

Information related to our genetic testing services

Biological sample, routinely saliva sample – The biological sample will be identified with a minimum of your name and date of birth (Identity Data). Samples will be analysed and processed so that we can perform the genetic testing services you have requested from us.
Genetic Information – Genetic information refers to the features of your DNA that distinguish you from other people, we will extract your DNA from the biological sample you provided us. We use this genetic information to provide information such as your connection to genetic relatives in accordance with your contract with us.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our genetic testing services). In this case, we may have to cancel a product or service but we will notify you if this is the case at the time. Please refer to our Terms and Conditions for further information pertaining to the cancellation of tests.

Information collected about you from use of our website

Technical Data – includes the domain name of the website providing you with Internet access and the Internet protocol (IP) address used to connect your computer to the Internet. We may also collect your browser type and version, the operating system your computer is running, and other site visit data such as the pages you view, and/or the information you search for.
Usage Data – includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as it does 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 information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

We will only collect any Special Categories of Personal Data about you through our website with your express consent (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.

Cookies and web beacons

Our website uses cookies and web beacons. A cookie is a small piece of data that is automatically sent to your browser from a web server and stored on your device’s hard drive. Web beacons are small pieces of code which are placed on websites and emails. We use this information to collect visitor access and data preferences and to understand email campaign effectiveness. This enables us to offer a better website experience and help improve our services to you.

You can block cookies by activating the setting on your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

How is your information collected?

We may collect personal information from you using the following methods:

Direct interactions. You may give us your Identity, Contact Data and Financial Data by filling in forms (such as our ‘Book This Test’ or ‘contact us’ form) or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our products or services;
use our ‘contact us’ form;
subscribe to our mailing list;
enter a competition, promotion or survey; or
give NorthGene feedback on our services.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies (as described above) and other similar technologies.
Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources including analytics providers and search information providers.

How is your information used?

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

Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal or regulatory obligation.
Where we have received your express opt-in consent.

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

We will only use your information for the purpose it was collected, 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 information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

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

We may use your Identity, Contact, Technical, and Usage 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 products, 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 goods or services from us and, in each case, 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 company outside of Whos The Daddy (and its group companies from time to time) for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time. You can also click on the relevant link in any of our emails sent to you via Mailchimp. Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Anonymised Data for statistical and research purposes

In addition our service agreement with you permits our lab partners to use your data, results and any surplus biological samples submitted in any studies relating to statistical and genetic parameters for DNA testing but only in an anonymous manner to prevent the identity of any individual being traceable. Should you not wish Whos The Daddy to use the anonymised information in this manner, or require additional clarification as to what this entails, please contact us.

Sharing your information with third parties

We will never sell your personal information or share it with third parties who might use it for their own purposes without your express opt-in consent or as set out below.

Any third parties handling personally identifiable information, such as Mailchimp and our laboratory sub-processors, will act as data processor, on behalf of Whos The Daddy. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We may have to share your personal information with the parties set out below:

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 information in the same way as set out in this privacy notice.
Service providers who provide services such as IT, laboratory sub-processors, sample collection and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers.
HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

International Transfers

We may share your personal information with our lab partners and their group of companies from time to time. This may involve transferring your information outside the European Economic Area (EEA). We ensure your personal information is protected by requiring all our group companies to follow the same rules when processing your personal information. These rules are called “binding corporate rules”.

If you request a transfer of your personal information and this involves a transfer outside of the EEA the expectation is placed upon you as our customer to ensure that appropriate levels of data protection are in place by the data recipient.

We do not transfer your personal information outside the EEA for any other reason, but in the event that we do, we will ensure at least one of the following safeguards is implemented:

We will only transfer your personal information to countries that have 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 information to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.

Security

We employ reasonable technical and organisational measures to keep personal information safe and to prevent loss, misuse and unauthorised access. These measures include encryption, firewalls and password protection. It is, however, your responsibility to ensure that your device is adequately secured and protected.

We have put in place 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.

Data retention

We will retain your data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

Our retention period will usually be 2 years from when we have fulfilled the purposes we collected it for. However, this may be adjusted when we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. You may request that your information is destroyed prior to this date by contacting compliance@whosthedaddy.net

Your rights

We want to ensure you remain in control of your personal information.

At any time you can contact us via compliance@whosthedaddy.net to:

Find out what personal information we hold about you
Ask us to rectify or erase any personal information we hold about you
Ask us not to use any personal information we collect
Ask not to be subjected to automated decision making (profiling)
Object to processing of your personal information
Ask us to restrict the processing your personal information
Request a transfer of your personal information
Withdraw your consent to processing

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

You will not have to pay a fee to access your personal information (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 may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

Links to other websites

WhosTheDaddy.net contains links to third party websites, plug-ins and applications. This privacy notice only applies to WhosTheDaddy.net and does not cover any other websites or services that we link to. If you go to another website from this one, please read their privacy policy.

How to contact us

If you want to request any further details about this privacy notice or exercise your data subject rights, please contact us at: compliance@whosthedaddy.net

Changes to this statement

Our privacy notice may be updated from time to time and the latest version will always appear on the WhoTheDaddy website.

This privacy notice was last updated on 3rd May 2023.