PRIVACY POLICY

GENEFUEL LIMITED
Last updated: January 2026

GENEFUEL LIMITED (“Gene Fuel”, “we”, “us”, “our”) is a company registered in England and Wales (Company Number 16614919) and acts as the data controller for the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store and share your personal data when you use our website, applications, dashboards, products and services (together, the “Services”).

By accessing our Services or providing us with your personal data, you acknowledge that your data will be processed in accordance with this Privacy Policy.

1. PERSONAL DATA WE COLLECT

We may collect personal data from you when you:

Complete health, lifestyle or goals questionnaires
Provide blood test results, DNA results, wearable data or other biomarker information
Purchase, subscribe to or use our products or services
Contact us for customer support, consultations or enquiries
Register for or use our website, platform or dashboards
Provide feedback, reviews or responses to surveys
Connect third-party services or authorise third parties to share data with us

Types of Personal Data We Collect

Identity Data: name, date of birth, gender
Contact Data: email address, phone number, billing and delivery address
Health and Biomarker Data: blood test results, genetic information, lifestyle inputs, wearable and fitness data, health goals
Technical Data: IP address, browser type, device information, time zone, approximate location data
Profile Data: preferences, account information, purchase history
Financial and Transaction Data: payment details, transaction history
Special Category Data: health and genetic data (processed only with your explicit consent)
Marketing and Communications Data: preferences for receiving marketing communications

We may also receive personal data from third-party service providers, including laboratories, wearable platforms, payment providers and logistics partners, where you have authorised them to share data with us.

2. AGGREGATED AND ANONYMISED DATA

We may process aggregated or anonymised data for analytics, research, service improvement and business insights. Such data does not identify you and is not considered personal data under data protection law. We do not attempt to re-identify anonymised data.

3. OUR ROLE AS DATA CONTROLLER

Gene Fuel determines the purposes and means of processing your personal data.

We process your personal data primarily to:

Deliver personalised nutrition, supplementation and lifestyle optimisation services
Generate insights, reports and dashboards
Provide supplements, subscriptions and related services
Operate, maintain and improve our products and Services
Ensure platform security, prevent fraud and comply with legal obligations

4. LEGAL BASIS FOR PROCESSING

We process your personal data on the following legal bases:

Explicit Consent: for processing special category data, including health, genetic and biomarker data
Performance of a Contract: to provide products and services you request
Legitimate Interests: to operate and improve our Services, ensure security, prevent fraud and support business operations
Legal Obligations: to comply with applicable laws and regulatory requirements

Where we rely on consent, you may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn. In some cases, withdrawal of consent may limit our ability to provide certain personalised features of the Services.

5. AUTOMATED PROCESSING AND PROFILING

We use technology, including algorithms and data-driven tools, to analyse health, lifestyle and biomarker data in order to generate personalised insights, recommendations and supplement formulations.

These processes may involve automated profiling; however, decisions that materially affect you are not based solely on automated processing and are subject to appropriate human oversight. You have the right to request further information about this processing and, where applicable, to request human review.

6. DATA SHARING

We may share your personal data with:

Service providers (such as payment processors, logistics providers, IT and cloud service providers)
Laboratories and testing providers, where you choose to undertake blood, DNA or other diagnostic testing
Technology partners supporting dashboards, analytics and wearable integrations
Professional advisers, regulators or authorities where legally required
Business transferees in the event of a merger, sale, restructuring or asset transfer

Where you engage third-party laboratories or diagnostic providers, those providers may act as independent data controllers and their own privacy policies will apply.

We only share personal data where necessary and under appropriate contractual and security safeguards.

7. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred outside the UK or European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, including Standard Contractual Clauses or other lawful transfer mechanisms recognised under UK GDPR.

8. DATA RETENTION

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting and regulatory requirements.

Retention periods vary depending on the type of data and purpose, for example:

Account and profile data: for the duration of your account and a reasonable period thereafter
Health and biomarker data: while you use our Services and as required for regulatory or clinical governance purposes
Financial records: retained in accordance with applicable legal requirements

9. DATA SECURITY

We implement appropriate technical and organisational measures to protect your personal data, including encryption, access controls and secure systems. However, no system is completely secure, and we cannot guarantee absolute security of your data.

10. COOKIES

We use cookies and similar technologies to:

Enable essential website functionality
Analyse usage and performance
Personalise content and user experience
Support marketing activities where consent is provided

You can manage cookie preferences through your browser settings or our cookie consent tools. Further information is available in our Cookie Policy.

11. YOUR RIGHTS

You have the right to:

Access your personal data
Correct inaccurate or incomplete data
Request deletion of your data (subject to legal limitations)
Object to or restrict processing
Request data portability
Withdraw consent at any time

We will respond to valid requests within one month. We may request verification of your identity before processing a request.

To exercise your rights, contact us using the details below.

12. MARKETING COMMUNICATIONS

We may send you marketing communications where you have opted in. You can unsubscribe at any time by using the link in our emails or by contacting us directly.

13. BIOMARKER AND HEALTH DATA

We use biomarker data and self-reported health information to generate personalised insights and supplement formulations. This information is not used to provide medical diagnosis or treatment. Anonymised data may be used for research, analytics or service improvement purposes, but identifiable health data will not be shared without your explicit consent.

14. CHILDREN

Our Services are not intended for individuals under the age of 18, and we do not knowingly collect personal data from children.

15. THIRD-PARTY LINKS

Our Services may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their privacy policies separately.

16. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Any changes will be posted on this page and, where appropriate, notified to you.

17. CONTACT US

If you have questions or concerns about this Privacy Policy or your personal data, contact us at:

GENEFUEL LIMITED
Email: info@genefuel.co.uk

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk