Política de privacidade do MyHeritage

This Privacy Policy was last updated on October 11, 2018. If you have not reviewed it since that date, please do so now.

Overview

MyHeritage is an online service that allows members to create family sites and profiles in order to build and print their family trees, share family photos, keep in touch with family members, perform DNA testing, receive genetic analysis, participate in scientific research and research their family history with advanced research tools (the "Service"). The Service is owned and operated by MyHeritage Ltd. (hereafter "MyHeritage", 'we', 'our' or 'us'). 'You' or 'your' means an adult user, over the age of 13, of the Service (in some countries the minimum age is 14, see the "Underage Users" Section in the Terms and Conditions), and/or an adult user over the age of 18 of the DNA Services (see the "Eligibility" Sub-Section under the Section "DNA Services" in the Terms and Conditions). The MyHeritage website (the "Website") is part of a group of websites that we own and operate (the "MyHeritage Website Group") which also includes MyHeritage.* websites on other top-level domains, Geni.com, WorldVitalRecords.com and FamilyLink.com

In this document (this "Privacy Policy") we provide information on what personal information is collected and why, as well as how we use the personal information to provide you with a personalized, relevant, user-friendly experience on the Website. We explain how you can view this personal information, control the way it is shared, or delete it.

Much of the personal information on our Website is uploaded by users for their own personal and private purposes. We recognize the sensitivity and confidentiality of information that may be disclosed by users in registering, making purchases from our Website, performing their family history research, performing DNA testing and receiving genetic analysis, and we are firmly committed to protecting your privacy.

By using this Website and the Service you are accepting the practices described in this Privacy Policy and the processing (including collecting, using, disclosing, retaining or disposing) of your information under the terms of this Privacy Policy. This Privacy Policy should be read in conjunction with the Terms and Conditions.

If we decide to change our Privacy Policy, we will issue an updated version of this Privacy Policy with an updated date legend (and notify you via email or by other appropriate means) so that you will be aware of what information we collect, how we use it and under what circumstances we disclose it in accordance with applicable law. If you do not consent to the Privacy Policy or to any changes thereto and as a result you would like us not to use or hold your information in accordance with the revised terms, you may contact us (see contact information at the bottom of this Privacy Policy) so that we will delete your information and/or account.

Whenever this Privacy Policy is modified in substance, the label "updated" will be displayed prominently next to the "Privacy Policy" link in the footer of the Website pages. The "updated" label will be removed after 30 days or when you visit the updated Privacy Policy to read it, whichever comes sooner.

Use of the Website following any changes constitutes your acceptance of the revised Privacy Policy then in effect. If you do not agree to this Privacy Policy, please do not use the Website.

The Service

Our mission is to help everyone discover, preserve and share their family history. We accomplish this by using the resources available on our websites and also through collaborating with our extensive number of users around the world. This may involve the collecting, processing, storing and sharing of personal information. We want to ensure that this is done in a responsible, transparent and secure environment that fosters your trust and confidence.

The Website serves as a worldwide platform for family history, allowing its users to (1) build their family trees and benefit from the synergies of having many family trees from all over the world in one central location, such as the ability to find Smart Matches between the family trees, and to allow users to search other users' family trees, and historical records, to benefit their family history research; and to (2) use DNA related services, including but not limited to (i) submitting samples for DNA extraction and processing, (ii) uploading a digital version of genetic information exported from other DNA services, (iii) receiving and interacting with genetic analysis provided by the Website and (iv) downloading the raw DNA data (collectively, the "DNA Services"). Unless explicitly indicated otherwise, the Service includes the DNA Services for all purposes of this Privacy Policy.

MyHeritage family sites

Most of the personal information on the Website is organized in family sites, each serving a family or a community of users with a shared family history background or research goal. Every family site is managed by a site manager – the user who created it, and may have site members as participants. Family sites typically contain one or more family trees, plus family photos and additional family-oriented content posted by the site manager and the members of the family site.

Within a family site, the Website provides convenient visual tools for building a family tree and adding information to family tree profiles. The Website also provides output tools for producing family tree charts and posters and for showcasing a user's family history to family members via slideshows and online reports. When building a family tree, the user decides which relatives to add to the family tree, whether to add deceased relatives, living relatives or both, and which information to include about them. Adding living relatives to the family tree requires the user to obtain their prior consent. Before adding living relatives below legal age to the family tree, the user must obtain the consent of their parent or guardian.

The user decides to what degree information on the family tree and other information from the family site will be visible to and discoverable by other users, by setting the Privacy Preferences (described in a detailed section below). The user decides whether to build the family tree on the Website on his/her own, or to make it a collaborative effort by inviting family members to assist, using facilities available on the Website for inviting members. If other members are invited, they make similar choices on entering information into the family tree. All information is entered into the Website directly and is not collected implicitly. The Website prevents information on living people in family trees from being disclosed to strangers, to protect privacy, and such information if entered will not be visible outside the family site or discoverable by search engines such as Google. There is one scenario in which living people in family trees may be seen by other users of the Website, typically relatives of these living people – see section "What are Smart Matches™ and how do they affect your privacy?", which describes how to prevent that scenario if it is a concern.
Living people may also be found on the Website in public records (e.g. the 1940 United States Federal Census collection), and in these cases they are allowed by applicable laws. Living people who are well-known celebrities (e.g. presidents, movie stars) can be found on the Website inside the Geni.com collection.

The personal information that you and other users enter is stored in the Website only for the purpose of delivering the Service to you and the other users, i.e. displaying the family tree, printing the family tree, searching historical records, and other genealogy features.

DNA Services

The DNA Services allow you to order MyHeritage DNA testing kits, submit DNA samples to us, allow us to make the acceptable use of such samples and the DNA markers, nucleotides, mutations or haplogroups ("DNA Results") resulting therefrom or submitted by you to the Website and receive outputs of the genetic analysis of the DNA Results which include the DNA Matches and Ethnicity Estimates (together, the "DNA Reports"). All provisions herein apply both to DNA Results produced from MyHeritage DNA kits, and DNA Results uploaded to the Website following an export from another DNA testing service.

DNA Badges
A DNA badge will be displayed in your online family tree, in the person card of any individual for whom you are the DNA Manager. This is an indication that this person had their DNA tested, but it does not provide other people with access to the actual DNA Results. You can disable DNA badges through your privacy preferences.

What personal information does the Website collect from you or about you?

We only collect information we believe is necessary for our legitimate business interests, including to provide you with the Service. Here is a list of the type of personal information we request, collect or you provide:

i) Name, Contact Information and Payment Details:
When you sign up for the Service, we ask for your name, gender and email address, as well as birth year and country. The birth year is collected to ensure that you comply with the Terms and Conditions with regards to underage and minor users. Users who are underage (below age 13, and in some countries, below the age 14, and with respect to the DNA Services, below the age of 18) must not use the Website, and users who are minors (below age 18) must obtain the written consent of a parent or guardian before using the Website. See the Terms and Conditions in this regard. The country is collected so that we can comply with local laws and regulations in your country of residence.

In addition we will need to know your postal address, phone number and payment details to facilitate payment and fulfillment for any subscription or purchases you may choose to make through the Website.

ii) Your Family and Others:
You may also post additional personal information about yourself and others in the course of doing your family research on the Website, e.g., adding a photo to a family tree. Personal information entered in the course of building a family tree may include any of the following:
* Names
* Gender
* Relationships
* Dates and places of events (e.g., birth, death, marriage, divorce, immigration, etc.)
* Photos, documents, video files, audio files and other media
* Email addresses, addresses and contact information
and more.

iii) DNA samples, DNA Results and DNA Reports:
By submitting DNA samples to us and/or DNA Results to the Website, you grant us a royalty-free, world-wide license to use your DNA samples, the DNA Results and the resulting DNA Reports, and any DNA samples and/or DNA Results you submit for any person from whom you obtained legal authorization and the resulting DNA Reports, to the minimum extent necessary to allow us to provide the Service to you. The license you grant to us is not perpetual, and it is revocable as you are able at any time to delete your DNA Results and DNA Reports permanently from the Website and to have us destroy your DNA samples.

DNA related information is generated and stored on the Website when you use the DNA Services, whether through direct submission of a DNA sample to MyHeritage or by submitting to the Website, DNA Results generated by another DNA testing service.

The DNA information includes:

• DNA samples you submit to us;
  
• DNA Results resulting from the DNA samples;
  
• DNA Results submitted by you to the Website; and
  
• DNA Reports generated from the DNA Results

All DNA samples are stored at our testing lab and may be kept by us unless or until circumstances require us to destroy the DNA sample, which you can request at any time by contacting us using the contact details below, or it is no longer suitable for testing purposes. We may store the samples for additional genetic testing (i.e., we may be able to provide more detailed and accurate DNA Results, DNA Reports and other outputs by additional genetic testing in the future, subject to your explicit approval).

Minors: the DNA Services are intended for adults only. We rely upon parents or guardians 18 years of age or older to determine if the DNA Services are appropriate for use by individuals under the age of 18. When a minor uses the DNA Services, the parent or guardian of that minor will be held responsible for the minor’s actions and are deemed to have consented to the use of the minor’s information by us. By submitting a DNA sample of a minor, you represent that you are the minor’s parent or legal guardian. We do not knowingly seek or collect personal information from minors. If we become aware that we have unknowingly collected personal information from a minor, we will make commercially reasonable efforts to delete such information from our databases.

When you provide us with any personal information, that personal information may be transferred to and stored by us in our secure data centers which may provide a different level of protection for personal information than in your country of residence. By providing us with personal or genetic information, you specifically consent to the transfer and processing of such information and its storage in our data centers. We take all adequate security measures to ensure the privacy protection of the personal information provided by you. We place great importance on the security of all personally identifiable information associated with our members. We have implemented commercially reasonable technical, physical and administrative security measures in place to attempt to protect against the loss, misuse, unauthorized access, alteration or disclosure of users' personal information under our control. For example, our security and privacy practices are periodically reviewed and enhanced as necessary and only authorized personnel have access to personal information. We use secure server software to encrypt financial information you input before it is sent to us and we only work with labs and third parties who have met and commit to our security standards. While we cannot guarantee that loss, misuse, unauthorized access, alteration or disclosure of personal information will not occur; we use commercially reasonable efforts to prevent this. You acknowledge that you provide your personal information at your own risk and you acknowledge that in the event that you download your DNA Results: 1) such download will create a copy that is not protected by MyHeritage’s security and privacy settings; 2) such download and the storage of your DNA Results after you have downloaded it, shall all be made at your own risk; and 3) MyHeritage will not have any control over the downloaded DNA Results and shall not be liable to you or to any third party in connection with such download and/or storage.

If you choose to invite other family members or other users to view and edit your family tree, we will ask you for the individual's email address and name. You must first make certain that you have obtained their consent to pass on their details to MyHeritage. We will only use this information for the purpose of sending the individual his/her access details and will not use the information we collect as a result of this process for marketing purposes.

In addition you should also make sure that information or material you wish to place on the Website about anyone living is only posted with their prior knowledge and consent. If the person is under the legal age to enter into agreements (typically 18 years old), you represent that you have obtained the consent of the parent or guardian of the person under the legal age to enter into agreements. In all cases, you must make the implications of the consent clear to the person (or, if applicable, to the parent/guardian).

iv) Your Opinions and Comments:
If you participate in discussions on our message boards, or post messages on our blogs or Facebook accounts, we may capture that information.

v) Your Use of the Website:
While you use our Website, we may collect information based on your interaction with our Website or from the devices or computers you use to access the Website, including web log information, page views and IP addresses, all on an anonymized basis.

vi) Survey Answers:
The voluntary Surveys on MyHeritage (the "Surveys") collect, preserve and analyze self-reported information related to physical and other personal traits, demography, household, lifestyle, habits, preferences, hobbies and interests, opinions, family, occupation, health, psychological and cognitive traits and other similar information (collectively, the "Survey Research Information").

vii) Health Family Tree:
The Health Family Tree allows you to enter information concerning health conditions, physical traits and other personal traits about yourself and your immediate family members (collectively, the "Health Family Tree Information").

How do we use your personal information?

i) To provide the Service:
We primarily use your personal information to let you know about new features or other offers of interest from MyHeritage, or to address customer service needs and requests.

We also use your personal information to fulfill the purposes for which you have provided the personal information, such as displaying your family tree, calculating a relationship path between you and another relative, printing your family tree poster upon your request, processing your subscription; and with respect to the DNA Services - processing your DNA samples, conducting genetic analysis and providing you with the DNA Reports, and storing the DNA samples, DNA Results and DNA Reports. So that you get the most out of the Service, we will also use your personal information to serve you Smart Matches™ for your family tree, or to enable you and other members of the MyHeritage community to contact each other, to suggest relatives you may invite to your site as members, as well as to provide product and Website updates and newsletters. See section on Privacy Preferences below to learn how you can opt out or change your privacy preferences.

By providing us with personal information, you acknowledge the transfer of personal information to and in the United States and to the processing of personal information in the United States. You accept that the DNA samples will be stored in the United States as provided in the Terms and Conditions. MyHeritage will take appropriate steps to ensure that transfers of personal information are done in accordance with applicable law and carefully managed to protect your privacy rights and interests. Accordingly, transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, such as an intra-group transfer agreement. You have a right to contact us for more information about the safeguards we have put in place.

ii) To verify your identity:
To verify and carry out financial transactions relating to payments you make online.

iii) To communicate with you:
We may communicate with you for the purpose of informing you of changes or additions to MyHeritage or of any of our products and services or to seek feedback from you on the Service. Our communications with you will primarily be via email, but may be made via telephone, direct mail or another method of communication in select circumstances. You may also receive promotional offers from us. If you do not want to continue to receive such emails from us, you may opt out at any time by using the unsubscribe link listed in the email or by changing your Email Preferences. See section on Email Preferences below to learn how you can opt out or change your email preferences. If you wish to opt out of other methods of communication, please contact us by the contact information below.

iv) For internal business purposes:
In order to improve the Website and the Service or to develop new products and services, we may use your personal information for internal data analysis, studying how the Website is used, identifying usage trends and determining the effectiveness of promotional campaigns.

v) To perform research:
If you voluntarily agreed to the DNA Informed Consent Agreement (the "Informed Consent") we may use the Survey Research Information, the Health Family Tree Information, DNA Results, DNA Reports and other DNA information for the purposes of research as specified in the Informed Consent.

If you agreed to the Informed Consent and voluntarily participate in any of the Surveys, we may use the Survey Research Information for the purposes of conducting research studies to better understand, among other things, the relation between genotypes and phenotypes. Discoveries made as a result of the Surveys may be used in the study of genealogy, anthropology, population genetics, personalized medicine, population health issues, cultures, trends (for example, to identify health risks, preventive measures, treatments, or spread of certain diseases), and other related topics. Survey Research Information is aggregated from multiple individuals. Personal identifiers (such as names, birth dates and specific locations, etc.) of those participants are removed. In publishing outcomes of studies resulting from the Surveys, only aggregated Survey Research Information without personal identifiers will be published or made available to the public. Your identity and the identity of your family members will not be disclosed by us in any publication of the Surveys research results. The aggregated information gathered from you and other users through the Surveys may be used in our marketing and advertisements, and such ads, emails, or promotional offers may be presented to you or targeted to you.

If you agreed to the Informed Consent and provide Health Family Tree Information, we may use the Health Family Tree Information for the purpose of conducting research. Discoveries made as a result of the Health Family Tree Information may be used in the study of genealogy, anthropology, population genetics, personalized medicine, population health issues, cultures, trends (for example, to identify health risks, preventive measures, treatments, or spread of certain diseases), and other related topics. Health Family Tree Information is aggregated from multiple individuals. Personal identifiers (such as names, birth dates and specific locations, etc.) of those participants are removed. In publishing outcomes of studies resulting from the Health Family Tree Information, only aggregated Health Family Tree Information without personal identifiers will be published or made available to the public. Your identity and the identity of your family members will not be disclosed by us in any publication of the Health Family Tree Information research results.

LEGAL GROUNDS FOR THE PROCESSING OF PERSONAL INFORMATION

Under EU data protection law, all processing of personal information is justified by a "condition" for processing. In the majority of cases, any processing will be justified on the basis that:

• you have consented to the processing;
• the processing is necessary to perform a contract with you (e.g. processing your payments or creating your user account)
  
• the processing is necessary for us to comply with a relevant legal obligation; or
  
• the processing is in our legitimate commercial interests, subject to your interests and fundamental rights (e.g. analytics which we carry out of your use of the Website).


In addition, the processing of "special category data" is only permitted where a relevant exemption exists. Special category data includes genetic information, which we process as part of the DNA Services, and any information about your ethnic origin. In both cases, the special category data is processed on the basis of your explicit consent.

Where the basis of processing is your consent, you have the right to withdraw your consent, and therefore prevent that processing, at any time.

Will MyHeritage disclose any of my personal information to third parties?

In no case is the personal information provided by our users sold, licensed or otherwise shared by us with advertisers, sponsors, partners or other third parties. We will never sell or license DNA samples, DNA Results, DNA Reports or any other DNA information, to any third parties without your explicit informed consent, and we will never sell or license such information to insurance companies under any circumstances.

MyHeritage will not disclose any of your personal information except in very limited circumstances which are set out below.

i) In limited circumstances: (a) if required by law, regulatory authorities, legal process or to protect the rights or property of MyHeritage or other users (including outside your country of residence); (b) to enforce our Terms and Conditions; (c) to protect our rights, privacy, safety, confidentiality, reputation or property, and/or that of the MyHeritage Website Group, or others; (d) to prevent fraud or cybercrime; (e) to permit us to pursue available remedies or limit the damages that we may sustain; or (f) to investigate rare cases involving reported abuse of our Privacy Policy.

ii) In an acquisition of MyHeritage: in the event that MyHeritage, or substantially all of its assets or stock are acquired, transferred, disposed of (in whole or part and including in connection with any bankruptcy or similar proceedings), personal information will as a matter of course be one of the transferred assets.

iii) To third-party service providers: Under the protection of appropriate agreements, we use third parties to perform various tasks for us. For example, we use third party platforms to process payments from you or use a specialized DNA lab to extract, process and store your DNA samples. These third-parties are only given access to that information needed to perform their support functions, and are prohibited from using it for other purposes. With respect to processors outside the European Economic Area, we attempt to ensure adequate safeguards for your personal information, as required by applicable law.

iv) To your DNA Matches: If you use our DNA Services and DNA Matches are enabled, the DNA Reports will include a list of your potential relatives, based on DNA. Each one of the people who match your DNA will be able to see the amount of DNA they have in common with you and the predicted family relationship between you, and some of your personal information such as your display name, your country of residence, your ethnic estimate and other profile information, depending on your privacy settings.

May you refuse to provide personal information to MyHeritage?



Visitors may access some of our free services anonymously, such as the SuperSearch™ engine for historical records. Other services that we provide may be accessed by registering with a first name, last name, email address, gender, country and birth year, some of which are optional. To gain full access to the paid subscription-only features, appropriate billing information, and to purchase physical products such as family tree posters and family calendars, a shipping address is required. The amount of other personal information you decide to submit to MyHeritage is up to you but understand that your experience with the Website may be limited if you choose to provide no additional information. Most of the personal information submitted to the Service may be offered at your own discretion and is intended for personal and/or family use only. Naturally, withholding some personal information may compromise the usefulness of the Website for other family members.

How do you report, change or delete information about yourself or your family?

Deleting or amending your Public Profile, your Tree and your DNA Results and DNA Reports: Any information that you have uploaded into your tree or your profile and your DNA Results and DNA Reports is controlled by you and can be amended or deleted by you at any time. See information below on how to do this.

Deleting or amending information that others have posted about you or your family: If the information was posted in a family site where you are a member, you may delete it. See information below on how to do this. Otherwise, if you are not able to delete or amend such information posted by another member, then you should contact us using the contact information at the bottom of this document. We will then correspond with you to understand the specific information that you want to have deleted and will then proceed to delete it for you and resolve the matter quickly.

We will, if requested by you, destroy the DNA sample provided by you or your DNA sample which was provided to us by another person with your permission, at any time. To request destruction of your DNA sample, please contact us using the contact details indicated below.

In addition, you can, at any time, delete your DNA Results and DNA Reports from the Website by using the delete function from the "Manage DNA kits" page on the Website, or request MyHeritage Customer Support to do this for you.

For disputes or issues with other personal information on the Website about you: You may contact us using the contact information at the bottom of this Privacy Policy. If you are a registered member of the Website, and you contact us with a request pertaining to information that you entered into the Website, we ask that you communicate to us from the same email address that you used to register to the Website. Otherwise, we may need to verify your identity before considering your request.

Please note that where you or we delete content or your account, copies of that information may remain viewable elsewhere to the extent any such copy has been shared with others, was otherwise distributed pursuant to your privacy settings, or was copied or stored by other users.

Backup copies: Removed and deleted information may persist in backup copies for a limited time for our internal business purposes but it will not be available to you or other Users.

How may you modify or delete information on the Website?



Any member may modify his/her personal information, including password, by logging into the Website, visiting the member profile via Account > My profile, and editing it, to update the information therein. At any time, members may modify or delete information and content items such as news articles and photos which they personally have posted to their site.

At any time you may delete information that you have posted on the family site. As site manager you can also delete all information and content that other site members have posted on your family site. As a site member, you can delete information that the site manager or other site members have posted about you.

Your entire family site and all its contents may be deleted from the Account > Site settings > General > Administration link "Delete my site".

Deleting an entire family tree (but not the entire family site) may be done from Family Tree > Manage trees, click the "Delete" link next to tree you wish to delete.

Deleting any individual from your family tree (but not the entire tree) may be done via the online family tree viewer in your family site: click "Family tree" to visit the tree, find the person in the "Find a person..." box, then click Options > Delete this Person on the side panel.

You may delete a photo album by clicking "Photos" in the navigation of your family site. Click any album on the side panel, then click More actions > Delete album.

You may delete a photo (not an entire album) by clicking "Photos" in the navigation of your family site, find the photo in the album viewer, then click the wheel icon next to the photo and select Delete.

You may delete your member account from the Account > Account Settings link "Delete my account".

In addition, you can, at any time, delete your DNA Results and DNA Reports from the Website by using the delete function from the "Manage DNA kits" page on the Website, or request MyHeritage Customer Support to do this for you.

You may request us at any time to delete all Surveys you have completed. Such deletion requests shall always be honored by us promptly. We shall also delete your completed Surveys if your account on MyHeritage is deleted. Please note that due to the de-identification of certain Survey Research Information, any research or studies using anonymized or aggregate information that has already begun, studies that have been completed, and any study results or findings that have been published prior to your Survey deletion request or MyHeritage account deletion cannot be reversed, undone, or removed.

Health Family Tree Information may be changed and/or deleted by you at any time. We shall also delete your Health Family Tree Information if your account on MyHeritage is deleted. Please note that due to the de-identification of certain Health Family Tree Information, any research or studies using anonymized or aggregate information that has already begun, studies that have been completed, and any study results or findings that have been published prior to your Health Family Tree Information deletion cannot be reversed, undone, or removed.

In case you need extra assistance, you may email us at privacy@myheritage.com to request us to help delete any information that you wish to have deleted, and your request shall be carried out promptly by our staff unless it is examined and believed to be illegitimate.

IP Addresses

We need your IP address to deliver the Website and our Service to you and to help diagnose problems with our server. Your IP address is also used to gather broad demographic information such as geographic distribution of our members. When you visit the Service for the first time, we use your IP address to suggest the Service to you in the language deemed the most appropriate for the geographical region from which it originates. Server logs maintain IP addresses for a period of one month and are used to investigate suspected abuse of our Service.

CLICK STREAM DATA

As you browse the Internet, a trail of electronic information is left at each web site you visit. This information, which is sometimes called "clickstream" data, can be collected and stored by a web site's server. Clickstream data can tell us the type of computer and browsing software you use, the address of the web site from which you linked to the Website. We may use clickstream data to determine how much time visitors spend on each page of the Website and how they navigate through the Website. We will only use this information to improve or customize the Website.

Cookies and Non-Personal Information



Cookies

We make use of browser cookies and similar automated means of data collection technologies to enhance your experience of visiting the website, for example, to avoid displaying certain messages to you more than once, to save your log in details so you won’t need to re-enter them each time you wish to log in or to remember the display language you previously selected so you won't need to select it each time you visit the website. You can disable or delete cookies from your computer if you wish, but certain parts of our service may not work correctly or at all if you do so. For more information about our use of cookies and similar automated means of data collection, and how you can choose to disable or delete cookies, please see our Cookie Policy. Our Cookie Policy is considered a part of, and incorporated into, this Privacy Policy, and this Privacy Policy should be read in conjunction with our Cookie Policy.

Other non-personal information

When you visit our Website, we may automatically collect non-personal information about you, such as the website from which you have come to our Website, your computer type, screen resolution, Operating System version, mobile device details (if applicable) and Internet browser. We may also collect non-personal information such as demographic data, for example your geographic area. Non-personal information also includes personal information that has been aggregated in a manner such that the end-product does not personally identify you or any other user of the Website, for example, by using personal information to calculate the percentage of our users from a particular country or who are female. Because non-personal information does not personally identify you, we may use such non-personal information for any purpose. In addition, we reserve the right to share such non-personal information.

Who will be able to view your family site?



This is determined by your Privacy Preferences (see appropriate section below).
If your family site is set up on the Website as a private site, only those with a valid username and password will have access to your site. Initially, the family site manager (creator) is the only one with access to the site. The site manager may invite other members to the site via email, and only recipients of this invitation will be able to gain access to the site after becoming members in the Website. It is then the responsibility of the site members to help keep the site secure by offering password access only to appropriate relatives and friends - those they want to have access to the site. Each user is responsible to protect his or her username and password. See section "What are the implications of inviting other people to your family site?" below. By default, family sites are accessible to guests (i.e., the general public) but guests cannot view information about living people in your family tree.

Who will be able to find information in your family site?



Information about deceased individuals in your family tree, including photos, can be found by other people using the research facilities on the websites of the MyHeritage Website Group. These facilities help other people research their past and find relatives who are also in your family tree. If you do not want others to find information in your family tree, you can make your family trees and photo albums private and exclude them from the MyHeritage historical search engines. See section on "Privacy Preferences" below. Unless your family site is set to private, public search engines such as Google may find your site and make it accessible via search engines to guests (i.e., the general public), except that guests cannot view information about living people in your family tree.

Health Family Tree Information you added will only be visible to you and not to other family site members or any other users.

What are Smart Matches™ and how do they affect your privacy?



Smart Matches™ is a technology developed and owned by MyHeritage to find matches between family trees, by looking for individuals that they have in common, and bridging across differences in spelling, phonetics, facts and languages. Smart Matches™ are very useful in that they facilitate discoveries of unknown relatives and reuniting families whose ties have been disconnected over time.

Other MyHeritage users may receive notifications regarding Smart Matches™ between individuals in their family tree and individuals in your family tree. Smart Matches™ may also be found on living individuals in your tree. If you are concerned about the privacy of your family tree, to the extent that you do not wish to allow potential relatives to find and view parts of it, you can disable Smart Matches™ for your family tree(s). See "Privacy Preferences" below. By default, Smart Matches™ are enabled.

What are DNA Matches and how do they affect your privacy?



DNA Matches find relatives by locating users of the DNA Services who share segments of DNA inherited from a common ancestor.

If a DNA Match is found between you (or any other person of which you are the DNA manager), and another individual whose DNA Results are stored in our database, both you and such individual will be notified of the match (including the name of the match, the match quality, predicted relationship and family tree details) provided, that, both of you enabled DNA matching in your privacy settings.

DNA Matching may have significant personal implications because they may reveal unexpected family connections. If you use the DNA Services and are concerned about the implications of DNA Matching, you can disable DNA Matches for your profile and for any other profile of which you are the DNA manager. By default, DNA Matches are enabled. When DNA Matching is disabled, your DNA will not be matched with other people, no DNA Matches will be found and any DNA Matches found previously will be deleted.

Who will be able to view your DNA Reports?



Users can access, view and manage DNA Results and DNA Reports that are associated with their own profile. In case a user is the DNA manager of another individual, such user can access, view and manage also the DNA Results and DNA Reports of the other individual. A "DNA manager" is a user who uploaded DNA Results or submitted a DNA sample, either for himself or for any person from whom the site members obtained legal authorization. Only the DNA manager is allowed to re-assign DNA Results and DNA Reports from one profile to another.

What are the implications of inviting other people to your family site?



When you start a new family site on the Service, you are the only one who can add, edit and delete its information. You are also the only one who can view the details of living people in the family tree on the family site. You can determine via the Privacy Preferences (see below) whether other users would be able to find your family site, visit it and view limited information in it. Family sites are intended to be collaborative and you are allowed and encouraged to invite other people, especially your relatives, to become members in your family site. Becoming a member of a family site requires becoming a registered member of MyHeritage and accepting this Privacy Policy and the Terms and Conditions by the invitee. Members of your site are also allowed to add, edit and delete its information, but as site manager you can prevent them from modifying the family tree if you wish, or prevent them from posting content. This is done in the Account > Site settings > Privacy > Members page, and the default is that invited members can contribute to the family tree and post content such as photos.

Inviting other site members is useful if you are treating your family tree as a collaborative effort and wish to enlist some of your family members to help you complete it, and upload more photos of the family. In the Privacy Preferences page (see below) you can control whether the members that you invite can themselves invite more members or not.

Because family sites contain sensitive, private information and site members have full access to the private personal information in the family site, think carefully before you invite anyone and be sure to invite only people you know and trust. As site manager, you can revoke the membership of any member, even if previously approved, from the "Site members" page of your family site, by selecting "More > Remove from site" next to any member's name.

Family sites have several places for inviting family members, such the "Invite close family" widget in the front page of the family site, the page for inviting more family, and the facility to invite family members from an email address book. Inviting typically requires you to provide the email address of the user you wish to invite and his/her name. MyHeritage will then send an invitation email to the invitee (currently with hard-coded phrasing, in future versions it will be possible to edit the phrasing).

Members invited into your family site typically receive fewer emails from the Service, such as event reminders and family site activity newsletters only, and can control that when they accept the invitation and later through the Email Preferences page accessible from their MyHeritage profile page. So inviting family members typically does not expose them to marketing or advertising.

Invitation emails are sent by the Service on behalf of the inviter, from the email address of MyHeritage, but if the invitee replies to them the reply will go to the email address of the inviting user (to facilitate discussion regarding the invitation). Invitation emails clearly originate from MyHeritage and are not made to appear as if the inviter wrote them. Invitation emails have in their footer a link to avoid receiving such invitations in the future. If that link is not used, invitees may receive at most two automatic reminders from MyHeritage in a month's time. Invitation emails include a link to an "invitee wizard". In this wizard the invitee is required to read and accept the Privacy Policy and Terms and Conditions in order to be considered a member of the Service and receive any further emails from the Service. Invitees will be asked to provide their birth year, in order for the service to determine that they are not underage (see Terms and Conditions). Invitees who are minors may only use the Service if they obtain the written consent of their parent or guardian (see Terms and Conditions). The invitee wizard allows invitees to control initial email preferences.

If you have been invited as a site member and wish to see what kind of information has been entered about you, click Account > My profile to view your member profile, created for you when you were invited based on information provided by the inviter. Click "View in tree" to see information about you entered in the family tree. As a member of the family site, you may delete information from it, such as information about you. See Section "How do you report, change or delete information about yourself or your family?" above. Note that as a living person the information about you will not be accessible to anyone who is not a member of this family site, so the fact that you are inside a family site does not mean that your privacy has been compromised.

What are membership requests in family sites?



The opposite of inviting other people to be site members, is the ability of others to request to be members in your family site. You can determine whether or not this is possible in the Privacy Preferences (see below). Default: yes. People submitting a membership request are required to provide their full name, email address and reason for the request for you as the site manager to evaluate their request. When you reject a membership request, this is done silently and the requester is not notified. When you approve a membership request, a notification email is sent by the Service to the requester informing them that the request has been approved by you. Approved requesters become members of your family site as if you had invited them. You can revoke the membership of any member, including requesters you previously approved, from the "Site members" page of your family site, by selecting "More > Remove from site" next to any member's name. When rejecting a membership request you can optionally block that user and prevent them from requesting membership in your family site again.

SECURITY

MyHeritage has implemented administrative, physical and electronic measures designed to protect your information from unauthorized access. MyHeritage will comply with applicable laws in the event of any breach of the security, confidentiality, or integrity of your personal information and, where we consider appropriate or where required by applicable law, notify you via email, text or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations.

Where MyHeritage has given you (or where you have chosen) a password which enables you to access certain parts of the Website you are responsible for keeping this information confidential. MyHeritage asks you not to share your password with anyone.

MyHeritage takes steps to restrict access to your personal information to individuals who need access to it in order to process it on MyHeritage's behalf.

DATA RETENTION

We will retain your personal information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws.

In general, this means that we store your personal information for as long as is required to deliver our services, except where we have a lawful basis for saving it for an extended period of time (for instance, after your subscription expires, we may still have a legitimate interest in using your contact details for marketing purposes). We also retain the personal information we need for the execution of pending tasks and the personal information we need to realize our legal rights and our claims, as well as certain personal information that we must store for a legally mandatory period of time. When certain personal information is only saved due to a legally mandatory preservation term, the processing of it by us is limited, even where you do not specifically request this. If you agreed to the Informed Consent, we may retain the information provided thereunder for as long as we determine required for the research purposes disclosed therein.

Managing your privacy



You can control how you share personal information by changing your privacy settings in the following areas:


• Email Preferences: this allows you to control what marketing emails and other emails we send to you.
• Privacy Preferences: this allows you to control the information that others can see about you and your personal information. Ver os detalhes adicionais acerca dos Preferências de Privacidade.

Emails

MyHeritage may send you the following types of emails:

* Transactional emails. These are emails that occur following your specific action or request on the Service. For example, if you indicate on the Website that you forgot your password, an email will be sent to you with instructions on how to obtain a new password. If you make a payment, you will receive an email with a confirmation that your payment was received or the charge has failed. If you purchased a subscription, you will receive a head notice before it is about to expire, and so on. You cannot unsubscribe from transactional emails and by providing us with your email address you give us your consent to receive transactional emails as necessary.

* Family site emails. These are event reminder emails that alert you about upcoming birthdays and/or wedding anniversaries of your family members; and family site activity newsletters which summarize on a weekly basis the activity of your family members in a family site in which you are a member. By default these are enabled when you create a new family site or join it as a member and you can opt-out and unsubscribe from them. Users invited to a family site managed by another person, are taken to an invitee wizard which includes the option of unsubscribing from event reminders and family newsletters of this site before they are ever sent out.

* Notification emails. These are emails sent to family site managers. They are enabled by default and you can opt-out and unsubscribe from any or all of them. They include the following:

- Smart Matches™: notifications about new Smart Matches you received, and Smart Match confirmations by other users relevant to you
- Record Matches: notifications about new Record Matches you received
- Instant Discoveries™: notifications about new Instant Discoveries™ you received or applied
- DNA Matches: notifications about new DNA Matches found
- DNA Services Notifications: notifications about the status and shipping of MyHeritage DNA kit orders, status of the processing and extraction of the DNA samples, and the generation and availability of DNA Reports
- Invitations: emails initiated by other users who wish to invite you to their family site, and reminders of such invitations
- Messages: notifications about messages sent to you by other users on MyHeritage

* Announcement emails from MyHeritage. These are new feature announcements, promotions and offers from MyHeritage concerning the Service. They are enabled by default and you can opt-out and unsubscribe from any or all of them. Announcement emails are most commonly not sent to users invited to MyHeritage by other users, unless they are family site managers.

- Announcements: news from MyHeritage about new features, offers and discounts
- Information: information about genealogy in general and MyHeritage features in particular
- Genealogy: updates about new genealogy features

Email Preferences
All non-transactional emails sent to you by MyHeritage have a link at their footer that leads directly to the Email Preferences page in which you can conveniently turn off any particular email type you do not wish to receive any longer, or re-enable some emails that you have turned off in the past. Family site emails have a link at their footer to the site preferences page which allows you to unsubscribe from or re-subscribe to event reminder emails and family site activity newsletter emails.

For each family site in which you are a member, the Email Preferences page lets you control whether or not you will receive event reminders and family site activity newsletters.

Emails with 3rd party offers

MyHeritage typically refrains from sending commercial offers originating from partners, affiliates and third parties. To the extent that MyHeritage sends an offer, it is most likely about a service owned and operated by MyHeritage, or integrated into the Service or the MyHeritage Website Group.

Text Messages (SMS)
The Service offers the following free feature internationally: if you are a member or site manager of a family site, you can opt-in to receive free Text Messages (SMS) to your mobile phone, regarding event reminders in your family. The text messages are sent one day in advance ahead of events such as birthdays and wedding anniversaries of close family members only. This can be enabled or disabled via Account > My profile > Edit site preferences. Default: disabled. You can enable this at your initiative by ensuring that event reminders are sent, then check the box to receive them also by Text Message (SMS), and enter your mobile phone number with an international prefix.

MyHeritage will never share, license or sell your mobile phone number to any third party, or send you promotional Text Messages (SMS) to the mobile phone number you provided. The Text Messages (SMS) feature is available only to users who are 18 years of age or above and only users who are 18 years or older are eligible to use it. MyHeritage may discontinue this free feature at any time or cease providing it for free and transform it into an add-on feature of a paid subscription.

YOUR RIGHTS



You may revise your personal information by adjusting your Account settings as described herein. You also have the right to ask MyHeritage to amend any personal information it holds about you if it is inaccurate or misleading as to any matter of fact. MyHeritage may ask you provide it with one form of photographic identification so that MyHeritage can verify your identity. Any request to amend personal Information in MyHeritage's records should be in writing and addressed by email to privacy@MyHeritage.com.

RIGHTS OF EU USERS



If you are a registered MyHeritage member residing in the European Union (EU) , you have the following rights, which may be subject to certain exemptions: 1.1 You have the right to access information held about you. Your right of access can normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law, for instance where you request multiple copies of your information. 1.2 You have the right to object to processing which has our legitimate interests as its lawful basis (see "Legal Grounds for the Processing of Personal Information" section above). 1.3 You have the right to obtain a portable copy of Personal Information which is processed on the basis of your consent, or which is necessary for the performance of a contract between us (see "Legal Grounds for the Processing of Personal Information" section above). 1.4 You also have the right to request details of the basis on which your personal information is transferred outside of the European Economic Area. 1.5 MyHeritage may ask you provide it with one form of photographic identification so that it can verify your identity. Any request should be in writing and addressed to MyHeritage by email at privacy@MyHeritage.com or through customer support. MyHeritage will use reasonable efforts to supply personal information about you on its files. MyHeritage shall endeavour to respond as soon as practicably possible within the statutory period of 30 calendar days from receipt of the request.

GDPR



MyHeritage has taken rigorous steps to ensure compliance with all applicable privacy laws, including the general data protection regulation (GDPR).

CHILDREN



Our Services are not directed or targeted to children under the age of 13, and MyHeritage does not knowingly collect personally identifiable information from children under 13. If MyHeritage learns that a child under the age of 13 has provided personally identifiable information to the Website, it will use reasonable efforts to remove such information from its files. If you provide information about a child, you, as parent or legal guardian, consent to the processing and use of such information by us in accordance with this Privacy Policy.

Contacting us about Privacy



If you have any questions about this Privacy Policy, the practices of this Website, or your dealings with this Website, or wish to request access to and receive information about the personal information we maintain about you, have the information blocked or deleted, as appropriate, or oppose (in case of legitimate reasons) the processing carried out with respect to your personal information (note please that the right to access personal information may be limited in some circumstances), you can contact our Data Protection Officer via email at dpo@myheritage.com.