Last Revised: October 15, 2026
The Ultimate Human Wellness (“The Ultimate Human Wellness”, “we”, or “us”) are committed to protecting and respecting your privacy. This is our main privacy notice, which explains when, how and why we collect personal information about you. It also explains how we may share your information, how we secure it, and what rights and choices you have as an individual. The information in this privacy notice relates to our processing of your personal information when you purchase ‘The Ultimate Human Wellness Genetic Test Kit’, interact with our websites (“our websites”, or “the websites”), our pages across social media platforms, or otherwise interact with us. This notice covers processing subject to United Kingdom data protection law and, where applicable, the EU General Data Protection Regulation (“EU GDPR”) and related data protection law in the European Economic Area (“EEA”).
If you are located in the United Arab Emirates, our website for the Genetic Test Kit is dna.theultimatehumanwellness.ae. We process the personal data of individuals located in the UAE in accordance with UAE Federal Decree-Law No. 45 of 2021 Regarding the Protection of Personal Data (“UAE PDPL”). Sections of this notice that apply specifically to UAE residents are marked “UAE Residents” throughout.
If you are located in Australia, our website for the Genetic Test Kit is dna.theultimatehumanwellness.com.au. We handle the personal information of individuals in Australia in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”). Sections of this notice that apply specifically to Australian residents are marked “Australian Residents” throughout.
The Ultimate Human Wellness is committed to upholding the principles of data protection under applicable data protection law. In the United Kingdom, this includes the UK GDPR, the Data Protection Act 2018, the Data (Use and Access) Act 2025, and relevant guidance issued by the Information Commissioner’s Office (“ICO”). Where the EU GDPR applies, this includes Regulation (EU) 2016/679, applicable national data protection laws in EEA countries, and relevant guidance from competent supervisory authorities and the European Data Protection Board. We ensure that personal data is processed lawfully, fairly and transparently, and only for specified, explicit and legitimate purposes. We take care to collect and retain only the personal data that is necessary for our activities and to keep that data accurate and up to date. Our practices are designed to reflect the accountability principle and our ongoing commitment to protecting the rights and freedoms of individuals.
We are committed to ensuring the highest standards of privacy, by adequately protecting your personal information, and supporting your privacy rights. If you have any questions about this notice, or how we handle your personal data, don’t hesitate to get in touch with us. We’ll be more than happy to help.
The Ultimate Human Wellness LLC is a registered company with our registered address at 2669 S Bayshore Dr Unit 2101 Miami, FL, 33133-5489 United States. As required by Article 27 of the UK GDPR for relevant processing by controllers based outside the United Kingdom, we have appointed RGDP LLP as our UK Representative. RGDP LLP also provides our Data Protection Officer service for the UK, and TenIntelligence (dpo@tenintel.com) is our Data Protection Officer for the EU. Where the EU GDPR applies to our offering of products or services to individuals in the EEA, details of our EU Representative appointed under Article 27 of the EU GDPR are set out later in this notice.
If you have any concerns about how we collect, use, share or keep your personal data, you think there has been a breach of your personal data, you wish to make a complaint regarding the processing of your personal data, or you have a question or concern about anything in this notice, you may contact our Data Protection Officer for the UK using the details below:
RGDP LLP
Edinburgh, One Edinburgh Quay, EH3 9QG
info@rgdp.co.uk
We will use your personal data whenever you request or purchase our products and services, interact with us online, or to establish and / or manage a business relationship with you. We also need your personal data where you have obligations under a contract with us to provide us with the necessary personal data, and not providing this information may prevent our ability to maintain that contract with you.
We may collect your personal data directly from you, or we may receive it indirectly.
Under the UK GDPR and the EU GDPR, where applicable, we must have a valid lawful basis under Article 6 when we process your personal data. Where we process special category data, including genetic data and any health data, we must also identify a condition under Article 9. The Article 6 and Article 9 bases described below apply under both the UK GDPR and EU GDPR unless we state that a basis is specific to the UK.
See the breakdown of our lawful basis below:
We rely on this lawful basis when you make an enquiry via the website, social media, or otherwise, that is not in relation to an existing contract, or the establishment of a potential contract with us. For example, when you make a general enquiry about the products or services we offer.
If you are located in the UAE, we rely on the following lawful bases under the UAE PDPL when we process your data:
If you are located in Australia, we collect the following information when you buy and register your Genetic Test Kit:
We collect this information to register your kit, carry out your test, deliver your results, provide customer support and, if you agree, send you marketing. We collect your sensitive information only with your express consent, which you give when you register your kit. If you do not provide this information or your consent, we cannot provide the test. Because your results must be matched to you, it is not practicable to use the service anonymously or under a pseudonym.
If you buy your kit or supplements from Health Meister Pty Ltd, our authorised Australian retailer, Health Meister collects your order and payment details under its own privacy policy. Health Meister does not share those details with us and does not receive your registration details, sample information or test results.
Under applicable UK and EU data protection law, we will only use your personal data for the purposes for which we collected it unless we have a lawful basis to use it for another purpose and the new purpose is compatible with the original purpose, or another legal rule permits the further use. Where we use personal data for a new purpose, we will provide any additional privacy information required so that you understand how and why the data is being used.
Our website may contain links to other websites run by other organisations. This privacy notice applies only to our website, so we encourage you to read the privacy statements on any other websites you visit. The Ultimate Human Wellness is not responsible for the privacy information and practices of other websites, even if you access those using links from our website.
In addition, if you are linked to our website from a third-party site, we cannot be responsible for the privacy information and practices of the owners and operators of that third party site, and we recommend that you check the privacy information of that third party site also.
We will only share your personal data with third parties where it is necessary for the provision of the services that you have requested from us, where we have your consent to do so, or in the limited circumstances detailed below:
If you are located in the UAE, The Ultimate Human Wellness (TUHW) acts as the Data Controller for your information. We utilise trusted third-party Processors who process your DNA samples strictly according to our documented instructions and the security standards required by the UAE PDPL. This includes our UAE laboratory partner, Unilabs, which receives your sample and sends it, labelled only with a kit barcode and your gender, to its partner laboratory Gene by Gene in Houston, United States, for genetic analysis; and LifeDNA, who convert your analysed results and make them available to you through our platform. LifeDNA’s storage and processing of your data takes place within the United Arab Emirates; a limited, break-glass-only form of access from outside the UAE may occur in exceptional circumstances (for example, technical support). We also use Klaviyo to send you emails about your order, and Freshworks to manage your customer support requests; neither receives your genetic or health information. If you buy your kit through Be.Health, Be.Health handles your order and payment as a separate controller under its own privacy notice, and does not receive your test results. Further information about these or any other processor is available from our Data Protection Officer on request.
Your demographic and health information may also be shared with other DHA-authorised healthcare providers through the NABIDH Health Information Exchange.
We share your information only with the service providers who help us provide your test: LifeDNA, which operates our Australian platform and delivers your results; Gene by Gene, Ltd., our laboratory partner in Houston, United States, which analyses your sample; Klaviyo, which sends emails about your order and, if you have agreed, marketing emails; and Freshworks, which manages customer support requests. Klaviyo and Freshworks do not receive your genetic or health information or your test results. We may also disclose your information where required or authorised by Australian law.
The Ultimate Human Wellness is established in the United States and we use service providers and partners in the United Kingdom, the EEA and the United States. As a result, your personal data may be accessed, stored, analysed or otherwise processed in a country outside the United Kingdom or, for personal data subject to the EU GDPR, outside the EEA. This includes transfers or remote access involving our laboratory, technology, data analysis and other service providers where this is necessary to provide our services.
Where an international transfer is subject to the UK GDPR or EU GDPR transfer rules, we use a lawful transfer mechanism and appropriate safeguards. Depending on the destination and recipient, this may include an adequacy decision or adequacy regulation, participation by an eligible US recipient in the EU-US Data Privacy Framework and/or its UK Extension, the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another mechanism permitted by applicable law. Where required, we also assess the circumstances of the transfer and apply supplementary technical, contractual or organisational safeguards.
We do not make a restricted international transfer unless an applicable transfer mechanism, safeguard or lawful derogation is available. You may contact our Data Protection Officer if you would like further information about the safeguards that apply to a particular transfer of your personal data.
Our primary servers for UAE telehealth data are hosted within the United Arab Emirates on DESC-certified infrastructure (AWS region me-central-1). Your data is transferred outside the UAE only in the following cases:
Laboratory analysis: your sample is sent to Gene by Gene, Ltd. in Houston, United States, for genetic analysis, with your specific written consent given when you register your kit. It is labelled only with a kit barcode and your gender, and your genetic data is returned to and stored in the UAE.
Service providers: Klaviyo (emails about your order and, if you have agreed, marketing emails) and Freshworks (customer support) process your name, contact details and order information in the United States. They do not receive your genetic or health information or your test results. Our contracts with them require your data to be protected to the standard required by UAE law, in line with Articles 22 and 23 of the UAE PDPL.
Technical support: in exceptional circumstances, LifeDNA may access our UAE systems from outside the UAE to provide emergency technical support. This access is strictly limited and controlled under our contract with LifeDNA, and your data remains stored in the UAE.
A current list of the partners who receive your data, and the safeguard that applies to each, is available on request from our Data Protection Officer.
Our Australian platform is hosted in Australia (Amazon Web Services, Sydney region). We are likely to disclose your information to recipients in the United States: your sample and the registration details needed to process it are sent to Gene by Gene, Ltd. in Houston; LifeDNA, which is based in the United States, may access the platform from there to support it; and Klaviyo and Freshworks process your contact and order details in the United States. We take reasonable steps to ensure these recipients handle your information consistently with the APPs. We will ask for your consent to sending your sample and registration details to the United States when you register your kit.
We retain your personal data only for as long as we need to in order to manage your relationship with us, and to ensure compliance with legal and regulatory requirements. Where your data is no longer necessary for this relationship, we will ensure it is anonymised or disposed of appropriately. For example, following the analysis by our labs of your DNA sample, as part of ‘The Ultimate Human Wellness Genetic Test Kit’, your DNA sample will be securely disposed of.
We retain your UAE genetic and health data for 25 years, in accordance with UAE Federal Law No. 2 of 2019 (Health Data Law), Article 20. Your account and contact details are deleted two years after your account is closed.
We keep your genetic and health information for 7 years from the last time we provide a service to you, in line with Australian health records requirements, and then securely delete or de-identify it. Your account and contact details are deleted two years after your account is closed.
We use a variety of security measures to help prevent personal data from being accidentally or unlawfully accessed, shared or lost, or otherwise processed. When you provide us with your personal data, we take steps to make sure that data is kept secure and safe. We utilise Amazon Web Services for our cloud-storage purposes, providing client and server-side encryption both at rest and in transit, various logging and monitoring functionality to detect incidents and access attempts, and a number of access-management controls to ensure we protect against unauthorised access, and adhere to the principle of least privilege.
As mentioned earlier in this notice, where possible, we will pseudonymise your personal identifiers, sharing only a pseudonymised ID with our trusted partners, to reduce the risk involved during the provision of our services. We ensure that any third parties we involve in our processing follow our safety-first approach to handling your personal data.
We also ensure our staff and our customer service team receive suitable training on data protection, including how to adequately protect data during their day to day activities, recognising data subject rights requests, and carrying out best practices in order to prevent data breaches from occurring.
If a data breach involving your information is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme.
You have rights in relation to the personal data we hold about you. The rights available to you depend on the law that applies to the processing, including the UK GDPR and, where applicable, the EU GDPR. You can exercise your rights by contacting our Data Protection Officer for the UK or the EU, as applicable, using the details below. If the EU GDPR applies, you may also contact our EU Representative.
These rights are not always absolute. A legal exemption or the conditions attached to a particular right may limit when it applies. Where a right does not apply, we will explain the reason when responding to your request.
Right to be informed: You have the right to clear and transparent information about how we collect and use your personal data. This privacy notice is one way in which we provide that information.
Right of access: You have the right to ask whether we process your personal data and, where we do, to request access to that data and the information required by applicable data protection law. This is commonly known as a subject access request.
Right to rectification: You have the right to ask us to correct personal data that is inaccurate and to complete personal data that is incomplete, taking into account the purposes of the processing.
Right to erasure: You have the right to ask us to erase your personal data in certain circumstances, including where the data is no longer necessary for the purpose for which it was collected or where you validly withdraw consent and there is no other lawful basis for the processing.
Right to restriction of processing: You have the right to ask us to restrict the processing of your personal data in certain circumstances, for example while we verify the accuracy of data you have challenged or consider an objection you have made.
Right to data portability: Where the legal conditions are met, you have the right to receive personal data that you provided to us in a structured, commonly used and machine-readable format and to transmit that data to another controller. Where technically feasible, you may ask us to transmit it directly.
Right to object: You have the right to object to processing based on legitimate interests or certain public interest grounds where the legal conditions are met. You also have the right to object at any time to the use of your personal data for direct marketing, including related profiling. If you object to direct marketing, we will stop using your personal data for that purpose.
Right to withdraw consent: Where we rely on consent or explicit consent, you have the right to withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Where explicit consent is required for us to process genetic data in order to provide a requested service, withdrawing that consent may mean that we cannot continue the relevant processing or service.
Rights relating to automated decision-making and profiling: Where applicable, you have the right not to be subject to a decision based solely on automated processing, including profiling, where the decision produces legal effects concerning you or similarly significantly affects you, subject to the exceptions and safeguards provided by applicable law.
Right to complain to a supervisory authority: You have the right to complain to the ICO about processing subject to UK data protection law. Where the EU GDPR applies, you also have the right to lodge a complaint with a competent EEA supervisory authority, in particular in the country of your habitual residence, your place of work, or the place of the alleged infringement. Contact information is provided below.
If you are located in the UAE, you have the following rights, which you can exercise by contacting our Data Protection Officer:
The Data Protection Officer referenced elsewhere in this notice for UK GDPR purposes (RGDP LLP) is appointed for UK matters only and does not handle UAE PDPL requests. To exercise the rights above, UAE residents should contact TUHW’s UAE Data Protection Officer: TenIntelligence, dpo@tenintel.com.
You can ask for access to, and correction of, the personal information we hold about you, and you can download your raw genetic data through the platform. You can opt out of marketing at any time by using the unsubscribe link in our emails or by contacting us. To make a request, contact our Data Protection Officer for Australia, TenIntelligence, at dpo@tenintel.com. We will respond within 30 days.
If you have any questions regarding this privacy notice, you can contact us using the details below:
The Ultimate Human Wellness LLC
2669 S Bayshore Dr Unit 2101 Miami, FL, 33133-5489 United States
privacy@theultimatehumanwellness.com
If you have any concerns about how we collect, use, share or keep your personal data, you think there has been a breach of your personal data, you wish to make a complaint regarding the processing of your personal data, or you have a question or concern about anything in this notice, you may contact our Data Protection Officer for the UK using the details below:
RGDP LLP
Edinburgh, One Edinburgh Quay, EH3 9QG
info@rgdp.co.uk
RGDP LLP is also designated as our UK Representative, as required by Article 27 of the UK GDPR for relevant processing by controllers based outside the United Kingdom.
The Data Protection Officer named above (RGDP LLP) is appointed for UK GDPR matters only and does not handle requests under the UAE PDPL. If you are located in the UAE, please contact TUHW’s UAE Data Protection Officer instead:
TenIntelligence
dpo@tenintel.com
The Data Protection Officer named above (RGDP LLP) is appointed for UK GDPR matters only and does not handle requests under the Australian Privacy Act. If you are located in Australia, please contact TUHW’s Data Protection Officer for Australia instead:
TenIntelligence
dpo@tenintel.com
The Data Protection Officer named above (RGDP LLP) is appointed for UK GDPR matters only. If you are located in the EU or EEA, please contact TUHW’s Data Protection Officer for the EU instead:
TenIntelligence
dpo@tenintel.com
Where the EU GDPR applies to our processing in connection with offering goods or services to individuals in the EEA, we are required to appoint an EU Representative under Article 27 of the EU GDPR. We are in the process of making this appointment, and our EU Representative’s contact details will be added to this notice once it is complete. In the meantime, you can contact our Data Protection Officer for the EU using the details above.
If you have a concern about our use of your personal data, we ask that you contact us or our Data Protection Officer first so that we can try to resolve it. You also have the right to complain to the Information Commissioner’s Office about processing subject to UK data protection law.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113
Web: www.ico.org.uk
Where the EU GDPR applies, you have the right to lodge a complaint with a competent supervisory authority, in particular in the EEA country of your habitual residence, your place of work, or the place where you believe an infringement occurred. A list of EEA supervisory authorities and their contact details is available from the European Data Protection Board at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
If you are located in the UAE and have a concern that we cannot resolve, you have the right to lodge a complaint with the UAE Data Office, the regulatory authority responsible for enforcing the UAE PDPL.
If you have a concern about how we handle your information, please contact our Data Protection Officer for Australia, TenIntelligence, first at dpo@tenintel.com. We will acknowledge your complaint and respond within 30 days. If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or on 1300 363 992.
We regularly review and, where necessary, update the privacy information contained within this notice. This notice was last updated on 15 October 2026.
