The customer can transmit the personal data required in each case to neotes GmbH. By means of a separate declaration on data processing to neotes GmbH and on data transmission to its cooperation partner, the customer can request the FA. AGE LABS consent.
The customer receives more detailed information on this in the separate data protection declaration.
neotes GmbH (hereinafter referred to as “we”) operates the Internet pages that can be accessed on the Internet at www.neotes.com and the associated subdomains and subdirectories (hereinafter the “website”).
With this data protection declaration, we would like to inform you which data we process and in what form when you visit our website. At the same time, we are complying with our obligation to inform you in accordance with Article 13 of the General Data Protection Regulation (GDPR).
The person responsible under data protection law for the data processing that takes place on our website is
Data protection officer: Dr. med. Irmi Huber | Roman Kacer
II. Purposes and legal basis of data processing and storage period
1. General Use of the Site
Our host’s web server automatically records access to our website. So when you visit our site, data is automatically transmitted to us. This data is about
your IP address
Information about data transfers
Date and time of retrieval
The amount of data transferred
The referrer and
Your used web browser/user agent
We process this data for the purpose and based on our legitimate interest in enabling you to access our site. The legal basis for data processing is therefore Article 6 (1) (f) GDPR. After your visit, your IP address will be anonymized and the other data will not be stored in log files.
2. Opening a user account
If you want to create a user account, you must register. In order to register via the website and to be able to create a user account for you, we process the following data:
We use this data to set up a user account for you and to provide you with the corresponding functions of the user account. The legal basis for this processing is Article 6 Paragraph 1 Letter b) GDPR.
3. Purchase of Products
By ordering the bioAge Basic and bioAge Premium, the customer agrees that my submitted samples and the health-related data contained therein will be processed by neotes for the evaluation and provision of the analysis results. I can revoke my consent at any time for the future.
We would like to point out that we process the analysis results for scientific research purposes, removing all identification and allocation features so that we can no longer assign this data to you as a person.
Customers who purchase the bioAge Test Premium agree that the results of the test will be forwarded to the consulting physician for your medical consultation included in the product.
For the operation of our website and your purchase, it may be necessary for us to disclose your data to the following recipients:
When purchasing spermidineLIFE products: TLL The Longevity Labs GmbH (registered office Austria) as the recipient of the data for the purpose of processing and shipping orders. This data processing takes place on the basis of predominantly legitimate interests (Art 6 Para 1 lit f GDPR) within the EEA and affects our customers. TLL The Longevity Labs GmbH only acts according to our instructions and has been contractually obliged to comply with the data protection regulations within the meaning of Art. 28 DS-GVO.
If you want to purchase one of our products, we give you the opportunity to purchase the item as a guest. For this we need the following data:
Street and house number
Additional address / Company / c / o
In addition, further payment data, such as the credit card number, are collected as part of the payment process.
This data is used to receive, process and process your order. The legal basis for this is Article 6 Paragraph 1 Letter b) GDPR.
If you subscribe to our newsletter when ordering, we will use your e-mail address after the purchase to send you advertising about our products, offers or services. We use information about you, for example from previous purchases or surveys, to tailor advertising to you. In addition, we analyze usage data in these newsletters, such as clicked links, opened pages, etc. You can object to this use at any time. You can find more information on this below in the explanations on your right to objection. The legal basis for this is Article 6 Paragraph 1 Letter f) GDPR. Our legitimate interest is to send you advertising and to gain insights from your use.
4. Determination of the HS-Omega 3® Index
The following provisions apply to customers who order a test to determine the HS-Omega-3 Index from Omegametrix® GmbH, Am Klopferspitz 19, 82152 Martinsried, Germany:
In order to evaluate and provide the analysis results of the HS-Omega-3 Index®, we have your submitted sample evaluated by Omegametrix® on our behalf and provide you with the analysis result at the address specified during registration. Omegametrix acts according to our instructions and does not receive any personal information from You and were contractually obliged to comply with the data protection regulations within the meaning of Art. 28 DS-GVO.
We also process the analysis results for scientific research purposes in order to compare the HS-Omega-3 Index® with the results of the neotes bioAge test. To do this, we first replace all of the identification or assignment features that make the data assignable to you. We pass on the results of the research to Omegametrix, anonymously and without your identifying or attribution characteristics. The legal basis is our legitimate scientific interest in the aforementioned research in accordance with Article 6 Paragraph 1 Letter f) GDPR in conjunction with Article 9 Paragraph 4 GDPR in conjunction with Section 27 Paragraph 1 BDSG.
5. Payment in the online shop
For payment processing in our online shop, we use payment service providers to whom you provide your data directly. The payment providers will inform you about the processing of the data themselves.
We also offer payment via Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), and American Express (https:// www.americanexpress.com/de/content/privacy-policy-statement.html), Klarna (https://cdn.klarna.com/1.0/shared/content/legal/terms/0/de_de/privacy), Google Pay (https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=buyertos&ldr=DE), Apple Pay (https://www.apple.com/de/privacy/) , Ideal (https://www.ideal.nl/en/disclaimer-privacy-statement/), Bancontact (https://www.bancontact.com/files/privacy.pdf), and QPAy (http://www .qpay.com.np/privacypolicy.html). If you choose to pay via one of these payment service providers, the payment data you enter will be transmitted to the respective service provider. Your data is transmitted on the basis of Art. 6 (1) (b) GDPR. All data required for payment processing is used exclusively for making payments and is transmitted via the “SSL” method.
When you register for the newsletter, your e-mail address and first name will be saved with your consent and used exclusively for your own advertising purposes until you unsubscribe from the newsletter. The processing required for this takes place on the basis of your informed consent (Art. 6 Para. 1 lit. a) DSGVO). We store your data until further notice.
We use the so-called double opt-in procedure for this, i.e. we will only send you our e-mail newsletter if you have given us your express consent to do so. For this we will send you a confirmation e-mail in which we ask you to give us your consent by clicking on the link contained in the e-mail. You can unsubscribe from the newsletter at any time without incurring any costs other than the transmission costs according to the basic tariffs. A message in text form to the contact details specified under Section 13 (e.g. e-mail, letter) is sufficient for this. Of course, you will also find an unsubscribe link in every newsletter.
We offer you the option of contacting us via our e-mail address given above. In this case, you will automatically provide us with your e-mail address and, if applicable, your name, a subject and the content of the message. We process this data in order to be able to answer your request. Our legitimate interest in data processing also lies in this purpose (Art. 6 Para. 1 lit. f) GDPR).
We store your e-mails for as long as is necessary to process your request and then store them for a period of 3 years if you contact us again with reference to your original question. This does not apply if you initiate a contractual relationship with us in the e-mail. In this case, the storage period depends on the underlying contract. In this case, you will be informed separately about the data processing that takes place there.
III. recipient of the data
Within our company, the departments responsible for processing the request have access to your data. We use external service providers insofar as we cannot, or cannot reasonably, carry out the services ourselves. These external service providers are primarily providers of IT services, such as our hoster, e-mail provider or telecommunications provider.
Our email delivery service provider is based in the USA. However, the service provider is certified under the EU-US Privacy Shield, so that an appropriate level of data protection is ensured when processing your personal data.
Apart from that, we do not transmit your data to third countries, unless this is expressly mentioned elsewhere in this data protection declaration.
Cooperation with processors
We commission our cooperation partner AGE LABS (Oslo, Norway) with the epigenetic examination and analysis of your blood samples. For this purpose, your pseudonymous data will be transmitted to AGE LABS in Norway to fulfill this task. This only works according to our instructions. AGE LABS was contractually obliged to comply with the data protection regulations in accordance with Art. 28 DS-GVO. AGE LABS may not use your data for other purposes. In addition, AGE LABS is obliged to treat this data in accordance with this data protection declaration and the relevant data protection laws.
We commission our cooperation partner TLL The Longevity Labs GmbH (registered office Austria) to ship spermidineLIFE products: TLL The Longevity Labs GmbH (registered office Austria) as the recipient of the data for the purpose of processing and shipping orders. For this purpose, the personal data you provide will be transmitted to TLL The Longevity Labs GmbH in Austria to fulfill this task. This only works according to our instructions. TLL The Longevity Labs GmbH was contractually obliged to comply with the data protection regulations within the meaning of Art. 28 DS-GVO. TLL The Longevity Labs GmbH may not use your data for other purposes. In addition, TLL The Longevity Labs GmbH is obliged to treat this personal data in accordance with this data protection declaration and the relevant data protection laws.
8. Data subject rights
The General Data Protection Regulation guarantees you certain rights that you can assert against us – insofar as the legal requirements are met.
Art. 15 DS-GVO – right of access of the data subject: You have the right to request confirmation from us as to whether personal data relating to you are being processed and, if so, what they are, as well as the more detailed circumstances of the data processing.
Art. 16 DS-GVO – Right to rectification: You have the right to request us to rectify any incorrect personal data concerning you without delay. Taking into account the purposes of the processing, you also have the right to request the completion of incomplete personal data – also by means of a supplementary declaration.
Art. 17 DS-GVO – right to erasure: You have the right to demand that personal data relating to you be erased immediately.
Art. 18 DS-GVO – right to restriction of processing: You have the right to demand that we restrict processing.
Art. 20 DS-GVO – Right to data transferability: In the case of processing based on consent or to fulfill a contract, you have the right to receive the personal data that you have provided to us in a structured, common and machine-readable format and to transmit this data to another person responsible without hindrance from us or to have the data transmitted directly to the other person responsible, insofar as this is technically feasible.
Art. 77 GDPR i. V. m. § 19 BDSG – right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with a supervisory authority at any time, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data violates applicable law.
In particular, the right to object and the right to withdraw consent
Art. 21 DS-GVO – Right of objection: You have the right, for reasons that arise from your particular situation, at any time against the processing of personal data concerning you, which is necessary on the basis of a legitimate interest on our part or to safeguard a task in the public interest , or which takes place in the exercise of official authority, to lodge an objection.
If you declare an objection to us, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend of legal claims.
Insofar as we process your personal data in order to operate direct advertising, you have the right to object to the processing at any time. If you object to the processing for direct marketing purposes, we will no longer process your personal data for these purposes.
Withdrawal of consent: If you have given us consent, you have the right to withdraw your consent at any time. All data processing that we have carried out up to your revocation remains legal in this case. To do this, you can simply click on the link contained in each e-mail and unsubscribe from the e-mail service or send a message to one of our e-mail addresses. If you tell us in this message that you do not wish to receive future emails, we will no longer send messages to the email address you have provided.
9. Changes to Privacy Notice
As part of the further development of data protection law and technological or organizational changes, our data protection information is regularly checked for any need for adjustment or supplementation. You will be informed of changes in particular on our German website at www.neotes.com. This data protection notice is dated August 2022.
Obligation to provide data
You have no contractual or legal obligation to provide us with personal data. However, without the data you have provided, we will not be able to offer you our services.
Existence of automated decision-making (including profiling)
We do not use automated decision-making that has legal effects on you or affects you.
VII. Internet-specific data processing / cookies
We use so-called “cookies” to expand the range of functions of our website and to make it more convenient for you to use it. With the help of these “cookies”, data can be stored on your computer when you visit our website. You have the option of preventing cookies from being saved on your computer by making the appropriate settings in your browser. However, this will limit the range of functions of our offer.
When using the website, cookies are stored on your computer. Cookies are small text files that are stored on your hard drive in the browser you are using and through which certain information flows to the place that sets the cookie (in this case, us). Cookies cannot run programs or transmit viruses to your computer. They serve to make the Internet offer more user-friendly and effective overall.
Transient cookies are automatically deleted when you close your browser. These include in particular the session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the joint session. This allows your computer to be recognized when you return to the website. The session cookies are deleted when you log out or close the browser.
Persistent cookies are automatically deleted after a specified period, which can vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time.
You can configure your browser settings according to your wishes and, for example, refuse to accept third-party cookies or all cookies. However, we would like to point out that you may then not be able to use all the functions of this website. In your browser settings you can specify that cookies require your consent before they are stored on your computer and become active. You can find detailed information about your browser settings on the websites of the providers or in these instructions for the most common browsers.
You can prevent the storage of cookies by setting your browser software accordingly; we would like to point out to you however that in this case you will if applicable not be able to use all functions of this website in full. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by Google by clicking on the following link
Download and install available browser plugin.
The legal basis for the use of Google Analytics is Article 6 Paragraph 1 Letter f) GDPR. Our legitimate interest lies in evaluating the use of our website. The data is stored for 38 months.
Facebook Custom Audiences
We use Custom Audiences from Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. If you have a user account on Facebook, our advertising can be displayed there in a targeted manner. For this purpose, the Facebook pixel establishes a direct connection between your page and the Facebook servers and your usage data from our website is transmitted to Facebook for analysis and marketing purposes. If you are a Facebook user, this data can be assigned to your Facebook account. Through tracking, your Facebook activities may be tracked across multiple pages. Your data may be processed by Facebook Ireland Limited on the servers of Facebook Inc. in the USA. Since the service and the data processing that takes place via this service are the sole responsibility of Facebook, we have no influence whatsoever on the possible processing of personal data. You can find more information on the collection and use of data by Facebook in Facebook’s data protection information at https://www.facebook.com/policy.php.
If you wish to object to the use of Facebook Website Custom Audiences, you can make the appropriate settings in your Facebook user account at:
The legal basis for the use of Custom Audiences is Article 6 Paragraph 1 Letter f) GDPR. Our legitimate interest lies in showing you target group-oriented advertising.
Use of Google Inc.’s remarketing or “Similar Audiences” function.
We use the remarketing or “similar target groups” function of Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”) on our website. This function serves the purpose of analyzing visitor behavior and visitor interests.
Your data may also be transmitted to the USA. There is an adequacy decision by the European Commission for data transfers to the USA.
The processing takes place on the basis of Art. 6 (1) lit. f GDPR from the legitimate interest of targeting visitors to the website with advertising by placing personalized, interest-based advertisements for visitors to the provider’s website when they visit other websites Visit on the Google Display Network.
You have the right to object to the processing of your personal data based on Art. 6 (1) f GDPR at any time for reasons that arise from your particular situation.
You can find more information about Google Remarketing and the associated data protection declaration at: https://www.google.com/privacy/ads/
Berlin, August 2022
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