Version CI-2026-01 · In force as of September 14, 2026 · Replaces the version dated September 9, 2025
Applicable to tellmeGen Starter, Advanced, and ULTRA products (whole genome sequencing), in Individual, Duo, and Family formats, and to the own genetic data upload service (raw data), to the extent that each product, module, or functionality is available in your country in accordance with Annex I.
This Consent forms part of the contract together with the Legal Terms, Privacy Policy, Cookie Policy, Information Updates and Sample Retesting Policy, and Returns, Shipping, and Replacements Policy, all of which are accessible on the Website prior to contracting. Regarding genetic analysis and the processing of your data, this document shall prevail over the others.
In Duo and Family formats, the purchase may be centralized in a single person, but each adult participant must give their own consent individually, identifiably, and traceably before their sample is analyzed.
1. Summary:
This summary does not replace the full text, but highlights what matters most. Please read it in full before accepting.
• We analyze the DNA from your saliva and provide you with reports on genetic vulnerability to certain health conditions, hereditary conditions, pharmacogenetics, ancestry, traits, and wellness, depending on the purchased product and the modules available in your country.
• The information is predictive and informational. It is not a diagnosis, does not confirm or rule out any disease, and should not be used on its own to make healthcare decisions.
• Before acting on a health result, consult a healthcare professional and confirm the variant using a validated clinical method in an accredited laboratory.
• We explain the service through educational materials, tutorials, guides, and glossaries, and make consultations with qualified professionals available to you, which you can contract before or after the analysis (in Spain, for Advanced and ULTRA, the test requires prior medical prescription and the post-results consultation is free). You decide whether to use them; they are not mandatory, and your decision is recorded.
• You decide what you want to know and can hide result categories before opening them.
• The analysis may reveal unexpected information, including family relationships different from what you believe.
• Your sample is destroyed within a maximum period of six months. You can download your data and request its erasure, except for what we must retain due to legal obligations, which will be blocked and unused.
• Minors may take the test under the conditions of section 14. The kit can be purchased or gifted by anyone, but it can only be registered and the service contracted by their father, mother, or legal guardian, using their own data and consent, providing documentary proof of representation. That person receives the results; the minor does not access them directly. The report includes the same information as that of an adult with the same product.
• If you authorize research, your pseudonymized or anonymized data may also be used to develop and train artificial intelligence models. It is voluntary, severable, and revocable.
• Only the first consent is mandatory. The others are voluntary, independent of each other, revocable, and do not affect the service or its price.
2. Who provides the service to you
Data controller and service provider: GENELINK, S.L. (commercial brand "tellmeGen"), Tax ID (NIF) B98649494, Calle Arquitecto Mora 5, floor 2, door 4, 46010 Valencia, Spain. Health authorization no. 11540 from the Department of Health of the Generalitat Valenciana.
• General contact: info@tellmegen.com · Phone: +34 960 090 596
• Exercise of rights and data protection: lopd@tellmegen.com
• Data Protection Officer: dpo@tellmegen.com
• Supervisory authority: Spanish Data Protection Agency (www.aepd.es) or the supervisory authority of your country of residence.
The interpretation service is provided from Spain, and laboratory analysis is performed entirely within the European Economic Area at Eurofins (Denmark), GenePlanet (Slovenia), and MGI (Poland), which operate under quality management systems certified in accordance with ISO standards applicable to their activity.
3. What this service is and what it is not
tellmeGen analyzes the DNA present in your saliva and provides you, through your account, with reports on your genetic vulnerability to certain health conditions, your carrier status for hereditary variants, your predictable response to certain medications, your ancestry, and certain personal and wellness traits.
This information is predictive and informational in nature. It is designed for you to know and discuss with a healthcare professional.
A tellmeGen report is not a diagnosis. It does not confirm or rule out any disease, does not replace any clinical test, and should not be used on its own to make healthcare decisions, start or stop treatments, or modify medication dosage.
Having a genetic vulnerability means that certain variants in your DNA have been statistically associated with a higher or lower probability of developing a condition. It does not mean you will develop it, nor that you are free from it if the report does not show those variants. Genetics is only one of the factors involved, along with age, environment, habits, and chance.
The service is contracted freely, by the user's own decision and without medical prescription or clinical indication except in Spain for Advanced and ULTRA, where the test requires the prescription of a GENELINK, S.L. physician and, if not prescribed, the full amount is refunded. tellmeGen does not provide healthcare through the reports or establish a doctor-patient relationship with you by virtue of contracting them.
4. What each product includes
• Starter: ancestry, personal traits, and wellness. Microarray technology.
• Advanced: all of the above plus genetic vulnerability to health conditions, hereditary conditions (carrier status), and pharmacogenetics. Microarray technology, with statistical imputation where applicable.
• ULTRA: the same content as Advanced, obtained through whole genome sequencing with an approximate target average coverage of 30×. This does not imply 30× coverage at all positions in the genome or the detection of all regions or variant types, but it allows the study of a broader spectrum of variants, including rare variants.
The content and scope of the reports may vary depending on the product version, methodological updates, new scientific evidence, and the modules available in your country. The date shown on each report indicates the applicable version.
5. How the process works
You collect your own saliva sample following the kit instructions and send it to the laboratory. There, DNA is extracted and analyzed via microarray or sequencing, depending on the contracted product. Afterward, our software processes the data, identifies variants, and automatically generates your reports, which become available in your account.
In Spain, for Advanced and ULTRA, prior to taking the sample you answer a preliminary questionnaire and only send it back, using the label we provide, if a physician prescribes the test.
The quantity and quality of the DNA obtained, as well as the collection and transport of the sample, influence the validity of the analysis. If a sample is inadequate for reasons not attributable to you, we may offer you a retest in accordance with the current retesting policy, visible on the platform before contracting.
6. What you can expect from the service
• To learn information about your own DNA and better understand why certain conditions are more or less likely in your case.
• To have a documented starting point to discuss with a healthcare professional.
• Pharmacogenetic guidance that your physician can take into account when evaluating a treatment.
• Information about your ancestry and traits.
• Information that may be useful for your biological relatives.
7. Limitations you should know before accepting
7.1 Results are probabilistic
Genetic vulnerability results are based on published statistical associations and do not predict whether or not you will develop a condition. They do not express certainty nor replace the evaluation of your personal and family history.
7.2 False positives, false negatives, and residual risk
No genetic technique is infallible. A positive result that is not subsequently confirmed (false positive) or a result that fails to detect a variant actually present (false negative) may occur. A result without reportable variants reduces, but does not eliminate, the probability. The detection rate varies depending on the gene, the variant type, and your ancestry. Therefore, no result should be considered conclusive without the confirmation described in section 8.
7.3 Technical limitations
In microarray-based products, the analysis is limited to predefined markers, and any expansion by statistical imputation depends on the methods and reference populations used: those variants are not measured directly, they are inferred.
In whole genome sequencing, the target average coverage is not achieved uniformly across all positions, and there are regions and variant types that are difficult to detect, including copy number variations, complex or balanced rearrangements, repeat expansions, complex haplotypes, pseudogenes, and low-complexity or high-homology regions.
The analysis is performed on saliva and is designed primarily for germline variants. It is not validated for the systematic detection of somatic variants or low-proportion mosaicisms.
7.4 Scope per gene
In Advanced, a specific set of variants is evaluated, which does not cover all possible variants nor all structural alterations of a gene. ULTRA allows the analysis of much broader regions of the genome and included genes, but does not guarantee the complete reading of each region or the detection of all variant types. In no case does the absence of findings exclude the existence of other relevant variants.
7.5 Variants of uncertain significance
Standard reports include only variants with sufficient evidence to be classified as pathogenic or likely pathogenic in accordance with current criteria. Variants of uncertain significance—those whose effect on health is not known with sufficient evidence—are not included in the standard report, although the analysis may detect them.
If you expressly request it, you can contract a specific report of variants of uncertain significance separately, at the price indicated on the platform. This report is exploratory in nature: it should not be used to make healthcare decisions, and its content may change as scientific evidence evolves.
7.6 Science changes
The classification of a variant may change over time. We may update your reports when evidence warrants it and the functionality is available in your plan, but we assume no obligation to contact you individually every time a change occurs.
7.7 Ancestry
Estimates are probabilistic and depend on the available reference databases; world regions with lower representation show lower resolution. Genetic ancestry is not equivalent to citizenship, legal identity, or documented genealogy.
7.8 Pharmacogenetics
It describes how certain variants may influence metabolism or response to a drug, but does not determine its efficacy or safety on its own. Age, renal and hepatic function, other diseases, drug-drug interactions, and dosage are decisive factors. In some genes, the identification of complex haplotypes, duplications, deletions, or hybrid alleles requires additional techniques not included. Never modify your medication based on a report.
7.9 External files and third-party services
If you upload a genetic data file obtained from another provider, the reliability of our reports depends on that file, which we do not control. If you download your data and use it in third-party services, interpretations may differ from ours: we do not guarantee their accuracy nor do we provide support for them.
7.10 Security
We apply strict technical and organizational measures, but no information system is completely immune to risks.
8. Confirmation before any healthcare decision
Before a tellmeGen result is used to make a healthcare decision, two conditions must be met:
• That a qualified healthcare professional evaluates it in the context of your clinical and family history.
• That the specific variant on which the decision depends is confirmed by an independent, validated clinical method appropriate to the variant type, in an accredited laboratory.
You acknowledge that you have been informed of this dual requirement and that you assume it. GENELINK is not responsible for clinical decisions adopted without the intervention of a healthcare professional or without such confirmation.
9. Prior information, educational materials, and professional consultations
9.1 What we provide to you prior to contracting. This document, together with the description of each product, frequently asked questions, and informational materials on the Website and platform, explains the nature, purpose, scope, advantages, limitations, alternatives, and potential consequences of the service. It constitutes prior and pre-analytical information, and you declare that you have read and understood it before accepting.
9.2 Minimum content of the information. We gather here, in a single place, the points about which you must be informed prior to a genetic analysis:
• The purpose of the analysis: informational and educational, depending on the contracted product (sections 3 and 4).
• Its advantages, risks, limitations, and alternatives (sections 6 and 7).
• The place where the analysis is performed and the destination of the biological sample upon completion (sections 2 and 15).
• The identity of those who will have access to non-anonymized results (sections 19, 20, and 21).
• The potential significance of the results for you, the alternatives you can choose from, and your right to decide whether or not you wish to know them (sections 8 and 10).
• The possibility of unexpected findings and their potential significance, and your right to decide whether you wish to know them (section 11).
• The implications that the results may have for your biological relatives (section 11.2).
• The support we offer you once the results are issued (section 9.4).
9.3 Educational materials. Tutorials, guides, glossaries, explanations of each section of the report, and training resources are permanently and freely available to you on the platform, designed so that you can understand your results without prior knowledge of genetics.
9.4 Consultations with qualified professionals. tellmeGen maintains a consultation service available with professionals qualified in genetics, which you can contract both before sending your sample and after receiving your results, through the channels enabled on the platform; in Spain, for Advanced and ULTRA, the consultation following the results is free. This service is governed by its own conditions and its nature depends on the professional, the product, and the country; in Spain, for Advanced and ULTRA, it forms part of the genetic counseling of the healthcare service. It is not an emergency service and does not replace diagnosis, monitoring, or treatment by a healthcare professional.
9.5 Your decision. Before accepting this Consent, you are expressly informed of the availability of these consultations. You freely decide whether to use them or continue without them, and that decision is recorded along with your consent. The contracting of the service is not conditioned on your use of them, and you may request them at any subsequent time.
9.6 Scope. Neither the platform materials nor the consultations turn the reports into a clinical diagnosis, nor do they eliminate the need for the confirmation tests in section 8. In countries where local regulations require specific professional intervention, the provisions of Annex I shall apply.
10. Your right not to know
10.1 You decide what information you wish to receive. You may choose not to know all or part of the health content of your report and may change your mind later.
10.2 From your account, you can hide entire categories of results before opening them. You can also request us at any time, by writing to lopd@tellmegen.com, not to be shown a specific category.
10.3 This preference does not prevent strictly necessary communications due to legal obligations, product safety, the correction of an error, or to prevent a serious risk; in such cases, we will limit ourselves to essential information.
11. Unexpected findings and secondary findings
11.1 A genetic analysis may reveal information you did not expect: family relationships different from what you believed, consanguinity between parents, or genetic vulnerabilities you were not looking for. Such information may emotionally affect you and your family, and cannot be undone once known.
11.2 The results may have implications for your biological relatives, who share part of your DNA and have not given consent. Keep this in mind before sharing your reports.
12. Responsible use and prohibited uses
You undertake not to use the reports, nor to provide them to be used, for the following purposes:
• Employment, hiring, or promotion decisions.
• Insurance underwriting, pricing, or exclusion.
• Immigration or nationality procedures.
• Determination of legal parentage, paternity tests, or any forensic or judicial purpose.
• Any discriminatory purpose or purpose contrary to the law.
Nor may you send samples or data of another person without their valid consent or without holding their accredited legal representation, nor impersonate a third party. Breach of this section may lead to the suspension or cancellation of the account and the withdrawal of access to the reports.
13. Who can contract. Duo and Family formats
13.1 Contracting requires being 18 years of age or older and having the capacity to consent.Contracting requires being 18 years of age or older and having the capacity to consent. Minors may take the test under the conditions set out in section 14.
13.2 In Duo and Family, the purchasing person can manage the order and logistics, but cannot consent on behalf of another adult. Each adult participant receives this Consent, accepts it individually through their own identification, and decides separately on the voluntary options.
13.3 We will not initiate the analysis of a participant's sample until their individual acceptance is recorded. If it is not recorded within 30 calendar days from receipt of the sample, we will remind them and, failing that, we will cancel that analysis and apply the Returns Policy.
13.4 Each adult participant is the owner of their own account and their own data. The purchaser of the order does not gain access to the results of the other participants unless they expressly authorize it from their account. If a participant is a minor, only their father, mother, or legal guardian can register their kit and contract the service, and that person receives their results, in accordance with section 14.
14. Minors and persons requiring support for the exercise of their capacity
14.1 Minors can take the test, but cannot contract it, register, or access the results by themselves: only an adult who holds their legal representation (their father, mother, or legal guardian) can register it and contract the service. The kit may have been purchased or gifted by someone else.
14.2 A minor's test is registered and contracted by their father, mother, or legal guardian, using their own data and giving express consent on behalf of the minor. That person acts on their behalf, is the holder of the account where the minor's kit is registered, receives the reports, and is responsible for compliance with this Consent. The minor does not receive the results directly.
14.3 Mandatory accreditation. Before processing the sample, you must provide through the platform:
• Valid identity document or passport of the authorizing person.
• Identity document, passport, or birth certificate of the minor.
• Family record book (Libro de familia), literal birth certificate, or judicial guardianship/custody resolution accrediting the bond or representation.
If parental authority is shared, the signed authorization of both parents is required, unless there is a judicial resolution attributing that decision to only one, in which case it must be provided. Documents drafted in a language other than Spanish or English must be accompanied by a translation.
14.4 This verification responds to our duty to make reasonable efforts to verify that the person consenting effectively holds parental authority, guardianship, or support. We do not initiate the analysis until this documentation has been verified. If it is not provided or is insufficient within 30 calendar days from receipt of the order, we will cancel the service and apply the Returns Policy.
14.5 The accrediting documentation is kept solely as proof of legitimacy, with restricted access to authorized personnel, while the account remains active and during the statute of limitations periods for liabilities. It is not used for any other purpose.
14.6 Scope of a minor's report. A minor's report includes the same information as that of an adult with the same product, including, depending on the product, sections on genetic vulnerability to health conditions, hereditary conditions, and pharmacogenetics. It is received by their father, mother, or legal guardian, not the minor. Before contracting, that person must bear in mind that the report may reveal predispositions to conditions that only manifest in adulthood and for which there are no preventive measures in childhood, as well as information about biological relatives. You can choose on the platform which categories you consult and which you keep blocked, and contract a consultation with professionals qualified in genetics (in Spain, for Advanced and ULTRA, the post-results consultation is free).
14.7 The authorizing person undertakes to explain the content of this document to the minor in a manner appropriate to their age and maturity, and to take their opinion into account.
14.8 Upon turning 18, the interested person may request ownership of their account. From that moment on, they decide for themselves, accept this Consent in their own name, may request the issuance of health sections, and exercise all their rights, including erasure. The access of whoever was their representative ceases with this change of ownership.
14.9 Persons with support measures. When there is a judicial resolution or a deed of support measures that covers decisions of this nature, the same accreditation rules of section 14.3 will apply, replacing affiliation documentation with the document establishing the support and its scope. The person providing support must inform the person and respect their will, wishes, and preferences.
14.10 In Spain, for Advanced and ULTRA, a minor's test follows the same circuit as an adult's: their father, mother, or legal guardian answers the preliminary questionnaire and the test requires medical prescription before sending the sample.
15. Your saliva sample
Your sample is used exclusively to provide the contracted service. It is destroyed within an approximate period of 60 to 120 days from the issuance of your results and, in any case, before six months, barring a different legal obligation. It is not kept in a biobank nor transferred to third parties for other purposes.
16. Retention of your data, tellmeGen+, and mandatory archiving
16.1 Starter and Advanced. Your results and reports remain accessible while your account is active. You may request their erasure at any time.
16.2 ULTRA. The initial period of access and storage included is indicated before contracting. From the fourth month onward, the maintenance of access, active storage, interpretation updates, and re-analyses depend on the current tellmeGen+ plan. If the subscription expires, there is a 12-month grace period during which you can reactivate it and recover access.
16.3 Before the grace period ends, we will notify you by email, to the last verified address of your account, 6 months, 2 months, 1 month, 1 week, and 1 day in advance, and we will send a final notice once it has ended, before proceeding with any deletion. Throughout the grace period, and in any case for a minimum of 365 days from the end of the subscription, we will keep the download of your raw data and reports available to you in a standard, legible format. After this period, we may delete working copies and those intended for your access, and we will confirm this to you in writing.
16.4 Mandatory archiving. The termination of tellmeGen+, erasure at your request, or account closure does not extend to information we must retain due to legal, health, product quality, or tax obligations, or for defense against claims. Such information is blocked, with restricted access, is not used for any other purpose, and is erased when the applicable period expires. This archiving does not depend on the payment of any subscription nor does it entail any cost to you.
16.5 Backup copies are kept isolated and are deleted or overwritten in accordance with their ordinary cycles, with a maximum target of 90 days from operational deletion, barring the mandatory archiving of section 16.4.
17. Upload of own genetic data (raw data)
If, instead of contracting a kit, you upload a genetic data file obtained from another provider, this Consent likewise applies, with the following particularities:
• You declare that the file corresponds to your own DNA or that of the person you legally represent, and that you are authorized to transfer it to us.
• We do not verify the identity of the person to whom the file belongs nor the quality of the original analysis.
• The scope of the reports we can generate depends on the markers contained in the file and may be significantly smaller than that of our products.
• The limitations of section 7 apply more intensely to this service, and the dual confirmation of section 8 is especially necessary.
18. DNA Connect (connection with genetic relatives)
18.1 It is a voluntary feature and is disabled by default. You can enable it when accepting this Consent or later at any time from your account. In both cases, activation requires an affirmative action by you, separate from the main consent, and before completing it you are informed of which elements of your profile other users will see, what information is shared, and how contact between them works.
18.2 If you enable it, other users who have also enabled it and who share DNA segments with you will be able to see you and contact you under the conditions you choose.
18.3 It may reveal family relationships you were unaware of, including the absence of an expected kinship, and such information may affect third parties. Once known, it cannot be undone.
18.4 You can disable it at any time from your account, with the same ease with which you enabled it. Deactivation removes your profile from the comparison index and prevents new connections, but does not delete information you have already voluntarily shared with another user.
19. Professional Access
19.1 You can authorize a healthcare professional to consult your reports. Authorization is given at the time of activating it, identifying the recipient, the scope of the information, and its duration.
19.2 You can revoke it at any time from your account. Revocation prevents new consultations, but does not reach information that professional has already downloaded or incorporated into your clinical record, which remains subject to their own professional obligations.
20. Research and development (voluntary)
20.1 Participation in research is voluntary and separable from the rest of the service: it does not condition the provision, its scope, or its price. It is given through a specific authorization that you check when contracting and that you can withdraw at any time.
20.2 Scope of authorization. If granted, we may use your genetic and health data, in a pseudonymized or aggregated form, in research and development projects that may comprise:
• (a) internal research and improvement of tellmeGen: validation and refinement of our algorithms, models, reports, and knowledge bases;
• (b) external scientific projects with universities, healthcare centers, scientific societies, or non-profit organizations;
• (c) research, validation, or development projects with companies, industry, or other commercial collaborators, including commercial collaboration agreements with universities and companies.
20.3 In any of these areas, processing may include the development, training, validation, and improvement of analytical models and artificial intelligence systems.
20.4 Projects use minimized, pseudonymized, or anonymized data. Information that directly identifies you is not communicated. Each project determines whether the collaborator acts as a processor, joint controller, or independent controller, with the corresponding contracts and guarantees and an express prohibition of re-identification.
20.5 We may combine data covered by this authorization with each other, and with those from other tellmeGen services you have contracted and authorized, when necessary for the described purposes. Artificial intelligence models and systems are developed on pseudonymized or anonymized data and are designed and verified so that they do not allow the reconstruction or re-identification of a specific person's genetic data.
20.6 Research may give rise to publications, algorithms, artificial intelligence models, knowledge bases, patents, products, or services, and may involve financial compensation for tellmeGen or its collaborators. Barring a specific written agreement, your participation does not grant you financial rights over those results.
20.7 You may withdraw the authorization with the same ease with which you granted it, from your account or by writing to <lopd@tellmegen.com>, without giving explanations and without affecting the contracted service. Withdrawal prevents new inclusions and ends, from its effectiveness, future processing based on it. It does not affect treatments lawfully performed before withdrawal, publications already made, legal obligations, irreversibly anonymized data, or already trained models from which your data cannot be extracted individually due to their own technical nature.
20.8 We will communicate the withdrawal to collaborators who have received your data pursuant to this authorization, unless it proves impossible or requires disproportionate effort. If you request it, we will inform you of to whom it has been communicated.
20.9 Irreversible anonymization implies that we can no longer reasonably link such data to you; therefore, they cannot be located or erased individually.
21. Data protection information
21.1 Controller. GENELINK, S.L., with the contact details of section 2.
21.2 Categories of data. Identifying and contact data, contracting and billing data, the biological sample, your genetic data, responses you provide in questionnaires (in Spain, also medical decisions regarding the test), platform usage data, and, when contracted for a minor or a person with support measures, the accrediting documentation of section 14.3.
21.3 Purposes and legal bases:
• Provide the contracted service and issue your reports: performance of the contract (art. 6.1.b GDPR) and explicit consent for the processing of genetic data (art. 9.2.a GDPR).
• Handle your inquiries and provide the support services of section 9: performance of the contract.
• Comply with legal, health, quality, product surveillance, and tax obligations, and retain the mandatory archiving of section 16.4: legal obligation (art. 6.1.c GDPR).
• Verify identity, legal representation, and support measures, prevent unauthorized analyses, and accredit the validity of consent: compliance with applicable legal obligations (art. 6.1.c GDPR) and, when no specific obligation exists, documented legitimate interest of GENELINK and the represented person in preventing illicit or fraudulent uses (art. 6.1.f GDPR). The retention of proof of consent and representation is further supported by the formulation, exercise, or defense of claims (art. 9.2.f GDPR).
• Research and development, including the training of models and artificial intelligence systems, in the areas described in section 20: your specific and severable consent (arts. 6.1.a and 9.2.a GDPR).
• DNA Connect: your specific consent, given upon accepting this Consent or activating it later from your account. Professional Access and secondary findings: your specific consent given upon activating them (arts. 6.1.a and 9.2.a GDPR).
• Platform security, fraud prevention, and defense against claims: legitimate interest (art. 6.1.f GDPR).
21.4 Consent and contract. Consent to analyze your DNA and issue your reports is essential: without it, it is technically impossible to provide the service. The other consents are independent, do not condition the service or its price, and can be withdrawn separately.
21.5 Recipients and providers. We work with genetic analysis laboratories, hosting and infrastructure providers, logistics operators, payment gateways, and support tools, bound by data processing contracts in accordance with Article 28 of the GDPR. You can request the specific list of current processors at any time by writing to lopd@tellmegen.com.
21.6 International transfers. Genetic analysis and the storage of your data are carried out within the European Economic Area, with providers of the categories identified in section 21.5. If any accessory function were to involve processing outside the European Economic Area, it would be based on an adequacy decision by the European Commission or standard contractual clauses with complementary measures, and we would communicate it to you.
21.7 Retention periods. Your sample, in accordance with section 15. Your genetic data and reports, in accordance with section 16; in Spain, the preliminary questionnaire and the medical decision on the test, as part of the clinical record, for at least five years from the end of each care process. Billing and contracting data, during the legal tax and commercial limitation periods. The record of acceptance of this Consent and the documentation accrediting representation, as long as liability may arise.
21.8 Automated decisions. The generation of your reports is an automated process: our software identifies variants present in your DNA and associates them with the contents of our knowledge base, prepared by our genetics team based on scientific literature. This processing does not produce legal effects on you nor significantly affect you in a similar way, since the report is informational and does not determine any healthcare decision by itself. You can request the review of your report by a member of our genetics team by writing to lopd@tellmegen.com.
21.9 Your rights. You can access your data, rectify them, erase them, limit or object to their processing, request their portability in a structured and commonly used format, and withdraw any consent at any time by writing to lopd@tellmegen.com. We will respond within one month, extendable in accordance with regulations. Withdrawal of consent to analyze your DNA prevents the continued provision of the service and entails the deletion of your genetic data, with the exception of the mandatory archiving of section 16.4. You may also lodge a complaint with the supervisory authority.
21.10 Security and data breaches. We apply appropriate technical and organizational measures, including pseudonymization, encryption, and access control, and we have conducted a data protection impact assessment. If a security breach occurs that poses a high risk to your rights, we will notify you without undue delay.
22. Liability
22.1 tellmeGen is responsible for the correct provision of the service in accordance with what is described in this document and the contracted technique, and for diligence in the processing of your data.
22.2 tellmeGen is not responsible for: healthcare decisions adopted without professional evaluation and the confirmation of section 8; interpretations made by third parties from your raw data; the inaccuracy of external files provided by you; the use of the reports for any of the prohibited purposes of section 12; nor the consequences derived from your providing your reports to third parties.
22.3 The preceding limitations do not exclude or limit liability for willful misconduct (dolo) or gross negligence, mandatory rights recognized by consumer regulations in your country of residence, or liability corresponding to the manufacturer in accordance with product regulations.
23. Change of control, corporate restructuring, and succession
23.1 GENELINK may be subject to corporate transactions, such as a merger, spin-off, contribution of a branch of activity, financing operation, or total or partial transfer of its business or shares. We inform you of this possibility because it affects who processes your data.
23.2 In the preliminary negotiation and audit phases, individually identifiable genetic records are not provided to third parties. Shared information is limited to aggregated, statistical, or pseudonymized data without access to individual genomes, always under a confidentiality, minimization, and access control agreement.
23.3 If the transaction materializes, the acquiring or resulting entity is subrogated to the position of data controller and is bound by this Consent, the purposes described herein, and the preferences you have configured at that time.
23.4 If the new controller intends to process your data for purposes materially different from those described here, they must inform you and obtain a valid legal basis or, where appropriate, a new consent. This Consent does not cover new purposes.
23.5 In the event of insolvency, liquidation, or an equivalent procedure, your genetic data may only be transferred within the framework of service continuity and with guarantees equivalent to those of this Consent. If lawful continuity does not exist, they will be deleted or anonymized, barring archiving whose conservation is mandatory.
23.6 These transactions do not alter your rights or authorize incompatible uses, and are documented in our compliance records.
24. Withdrawal and returns
The right of withdrawal is 14 calendar days and is governed by applicable consumer regulations and our Returns, Shipping, and Replacements Policy, accessible before purchase. Upon contracting, you expressly request that the provision may begin during the withdrawal period. In such a case, if you withdraw after commencement but before full execution, the proportional part of the service already provided may be charged; the right lapses only when the service has been fully executed and legal requirements are met. Regarding sealed physical elements that are not returnable for reasons of health protection or hygiene, the right lapses after unsealing when such legal exception applies. Nothing herein limits mandatory rights corresponding to you.
25. Incidents, complaints, and product safety
If you detect an error in your report, an incident with the kit, or any problem that could affect the safety or functioning of the service, please notify us at info@tellmegen.com. We record and analyze all communications within our quality management system and adopt appropriate corrective measures. You may also contact the competent authority of your country.
26. Availability by country
26.1 The availability of each product, module, and functionality is checked before purchase based on your country of residence, place of purchase, place of sample collection, laboratory, and place of delivery of results.
26.2 tellmeGen may prevent contracting, withdraw specific modules, adapt the provision circuit, or cease offering the service in a country when it cannot comply with applicable local requirements. These measures are applied through technical controls on the platform.
26.3 Annex I summarizes known particularities by country and forms part of this Consent. It is not an exhaustive inventory of local legislation: the platform's current operational matrix determines the applicable circuit at any given time.
27. Modifications to this Consent
27.1 This document has a version code. We may update it to adapt it to legal, technical, or product changes.
27.2 If the change expands the purposes of processing or affects any of your consents, we will ask you to accept the applicable version again before continuing. We will not apply new purposes to data already collected without such new consent.
27.3 If the change is explanatory or drafting-related, we will communicate it to you. You can consult the version you accepted from your account at any time and request the version history at info@tellmegen.com.
28. Languages
This Consent is shown to you in the language you have selected and, in Spain, at least in Spanish. The original text is in Spanish; versions in other languages are faithful translations provided for your convenience. In case of discrepancy, the Spanish version shall prevail, unless mandatory regulations in your country of residence provide otherwise.
29. Applicable law and jurisdiction
This Consent is governed by Spanish legislation, in particular Regulation (EU) 2016/679, Organic Law 3/2018, Law 14/2007 on biomedical research, and Law 41/2002 on patient autonomy, without prejudice to mandatory consumer protection rules of the country of your habitual residence and the jurisdiction of the courts of that country.
30. Electronic record of your consent
When you accept this document, we record, for each participant and independently: their identification, the version code and fingerprint of the exact text shown to them, the date and time, the language, the applicable country, the contracted product, the information that the professional consultations of section 9.4 were offered and whether you decided to use them or not, and the decision adopted regarding each of the voluntary consents.
Such record is kept as proof of your consent and you can consult and download it at any time from your account.
Consents
Each adult participant gives these consents individually from their own identification, upon registering the kit. The checkboxes are not pre-checked. The first two are mandatory; the others are voluntary, independent of each other, and revocable at any time, and do not affect the service or its price.
☐ Mandatory. I have read and accept the Legal Terms and the policies that form part of the contract.
☐ Mandatory. I have read and understood the Informed Consent and give my express and specific consent for tellmeGen to analyze my sample and process my genetic data for the purpose of providing me with the service. I declare that I am over 18 years of age and, if the test is for a minor or a person with support measures, that I act as their duly accredited legal representative and give this consent on their behalf. I have been offered to contract a consultation with professionals qualified in genetics, before and after the results and at an additional cost indicated on the platform, and I decide to continue without it for the time being, knowing that I can request it whenever I want.
☐ Voluntary. I want to boost science and the development of new treatments: I authorize the use of my genetic and health data, in a pseudonymized or aggregated form, in research projects. I understand that this includes collaborations and commercial agreements with universities and companies, and the development and training of artificial intelligence models. Information that directly identifies me will not be shared, I may withdraw this authorization at any time, and my decision will not affect the contracted service.
☐ Voluntary. I want to receive updates, news, and special offers from tellmeGen. I can unsubscribe at any time.
☐ Voluntary. I wish to activate the DNA Connect feature to find potential genetic relatives within the tellmeGen community. I understand that I will only be compared with other users who have also activated this option, that a match is an estimate and not proof of kinship, and that I can enable or disable it at any time from my account.
The preference regarding secondary findings in ULTRA and the Professional Access authorization are not given here: they are managed from your account, the former before the issuance of results and the latter at the time of activating it, when the recipient, shared information, and duration can be identified.
Annex I. Particularities by country
This annex forms part of the Consent and summarizes known operational rules. It is not an exhaustive inventory of local legislation.
A. Countries where the service is not provided
France. tellmeGen genetic analysis services are not offered in France. The platform prevents contracting, kit shipping, and result delivery to that destination.
B. Countries with additional information or counseling requirements
In Spain, Portugal, Italy, Austria, Norway, and Switzerland, national regulations establish additional information, counseling, or professional intervention requirements for certain genetic analyses. To meet them, in these countries tellmeGen:
• makes available to you, permanently and free of charge, before and after the analysis, the information and support materials described in section 9.3: tutorials, guides, glossaries, explanations of each report section, and assistance through channels enabled on the platform;
• actively offers you, and records your response to, the consultation with professionals qualified in genetics described in section 9.4, available both before sending your sample and after receiving your results, and subject to the price indicated on the platform, except in Spain for Advanced and ULTRA, where the post-results consultation is free;
• provides the service through GENELINK, S.L., registered in the Autonomous Registry of Health Centers, Services, and Establishments of the Generalitat Valenciana under number 11540.
If the competent authority of any of these countries were to establish requirements different from those described here, such as prior medical prescription or professional intervention, tellmeGen will adapt the provision circuit in that territory in accordance with section 26.2 and will communicate it to you before it affects you.
C. Germany
If you reside in Germany, tellmeGen makes available to you permanently and free of charge the information and support materials of section 9.3, before and after the analysis, and actively offers you the consultation with professionals qualified in genetics described in section 9.4, subject to the price indicated on the platform. We expressly recommend discussing your results with a licensed physician in Germany before adopting any decision related to your health.
If the German competent authority were to establish requirements different from those described here, tellmeGen will adapt the provision circuit in accordance with section 26.2 and will communicate it to you before it affects you. The availability of health modules in this country is determined in accordance with that same section.
D. Rest of countries
In other countries, the absence of additional requirements should not be presumed. The platform confirms availability before contracting and may require additional documentation, offer a different product, or exclude certain modules.
Annex II. Glossary
DNA. Molecule containing each person's genetic information. It is inherited from parents and is practically identical in all cells of the body.
Variant. A difference in a person's DNA compared to the reference sequence. Most are harmless; some are associated with traits or health conditions.
Genome. An individual's complete set of DNA.
Microarray. Technique that analyzes a predefined number of specific DNA positions, not the entire genome.
Whole Genome Sequencing (WGS). Technique that analyzes the genome globally, rather than just predefined positions, allowing the study of rare variants as well. Coverage is not uniform across all regions.
Statistical imputation. Method that estimates variants not measured directly from those that have been measured and from reference populations.
Carrier. A person who has a variant associated with a hereditary condition without exhibiting it, and who can transmit it to their offspring.
Variant of uncertain significance (VUS). A variant whose effect on health is not yet known with sufficient evidence. It is not included in standard reports and is only communicated in the specific report described in section 7.5, if you request it.
False positive. A result indicating the presence of a variant that is not actually there, or that is not confirmed with an independent test.
False negative. A result that fails to detect a variant that is present.
Pharmacogenetics. The study of how genetic variants influence the way the body processes certain medications.
Genetic vulnerability. Higher or lower statistical probability of developing a condition associated with certain variants. It is not a diagnosis or a certainty.
Pseudonymization. Processing that replaces identifying data with a code, so that data cannot be attributed to a person without additional information kept separately.
Anonymization. An irreversible process after which data can no longer be linked to an identified or identifiable person.