Privacy Policy
1. Introduction
MolMart Ltd (“we,” “us,” or “our”) is committed to protecting the privacy and security of your
personal data. This Privacy Policy explains how we collect, use, share, and protect your
information when you use our genetic screening services, including SureMart, and our
associated patient-facing application.
This policy complies with the UK General Data Protection Regulation (UK GDPR), the Data
Protection Act 2018, and other relevant data protection laws.
2. Data Controller and Data Protection Officer
MolMart Ltd is the data controller responsible for your personal data.
Data Protection Officer Markella Mikkelsen (CEO & Founder)
Email mmikkelsen@molmart.co.uk
Address The Renold Building, 32a Altrincham St, Manchester M1 7JR, UK
Given that MolMart processes special category data (genetic and health data), Markella
Mikkelsen acts as Data Protection Officer in this capacity. If you have any questions or
concerns about how your data is handled, please contact us at the details above.
3. What Data We Collect
We collect and process the following categories of personal data:
a. Personal Identification Data
• Full name
• Date of birth
• Contact details (email address, postal address)
b. Health and Genetic Data (Special Category Data)
• Relevant family history
• Any previous genetic test results provided by you
• Genomic data generated through the SureMart carrier screening process
• Where applicable, donor genetic data used for donor–recipient matching
c. Transaction and Payment Data
Payment transactions are processed securely by Stripe, our third-party payment provider.
MolMart does not retain card details, billing addresses, or other financial credentials. Once a
transaction is complete, Stripe retains the relevant payment data in accordance with their
own privacy policy and applicable financial regulations. We retain only a record of the
transaction (date, amount, and service purchased) for accounting and legal compliance
purposes.
4. Purpose and Legal Basis for Processing
Under UK GDPR, we must have a lawful basis for processing your data. We process your
personal data as follows:
Purpose Legal Basis
Providing genetic screening services Performance of a contract (Article 6(1)(b))
Processing health and genetic data Explicit consent (Article 9(2)(a))
Communicating with you about your results Performance of a contract (Article 6(1)(b))
Donor–recipient genetic matching Explicit consent from both parties (Article 9(2)(a))
AI-assisted analysis and report generation
(MIRS algorithm)
Explicit consent (Article 9(2)(a)) and legitimate
interests (Article 6(1)(f))
Genetic counselling referral and support Explicit consent (Article 9(2)(a))
Complying with legal and regulatory
obligations
Legal obligation (Article 6(1)(c))
Improving our services using anonymised
data
Legitimate interests (Article 6(1)(f))
Your genetic and health data will only be processed with your explicit consent, which you
may withdraw at any time. Withdrawal of consent does not affect the lawfulness of
processing carried out prior to that withdrawal.
5. How We Use Your Data
We use your personal data to:
• Provide genetic carrier screening and deliver your results securely
• Perform donor–recipient genetic matching where you are using a sperm or egg donor
• Support you through our AI-enhanced patient application before and after testing
• Facilitate access to genetic counselling via our partner counsellors
• Conduct anonymised research and continuously improve our services
• Ensure compliance with healthcare regulations
• Respond to enquiries and provide customer support
6. Automated Processing and AI-Assisted Analysis
MolMart uses a proprietary bioinformatic pipeline and pathogenic scoring algorithm (MIRS —
MolMart Interpretation and Reporting System) to analyse your genomic data. This system
uses AI-augmented gene–disease matching to identify clinically relevant variant
combinations between partners or between a donor and recipient.
The output of this automated analysis directly informs the clinical report delivered to you and
your healthcare provider. This constitutes automated processing that may have a significant
effect on you within the meaning of Article 22 of the UK GDPR.
In accordance with your rights under UK GDPR, you have the right to:
• Request human review of any automated analysis or report
• Express your point of view regarding any automated finding
• Contest any decision based solely on automated processing
To exercise any of these rights, please contact us at mmikkelsen@molmart.co.uk. All clinical
reports are reviewed by a qualified molecular geneticist before delivery, providing a layer of
human oversight.
7. Data Sharing and Third Parties
We do not sell your data. We may share it with the following categories of recipients, all of
whom operate under Data Processing Agreements (DPAs) with MolMart:
Recipient Purpose
Accredited sequencing
laboratories
Processing of genetic samples and generation of raw genomic
data
Amber Gardiner, Evolve
Genetics
Genetic counselling services provided to patients
Clair Engelbrecht, CKE Genetics Genetic counselling services provided to patients
Stripe (payment processor) Secure processing of payment transactions; card data is not
retained by MolMart
Cloud storage and IT service
providers
Secure hosting and storage of data
Regulatory authorities Where required by law
8. International Data Transfers
MolMart processes and stores all patient data within the UK and European Economic Area
(EEA). We do not transfer your personal or genetic data to countries outside the UK or EEA
as part of our standard operations.
Where MolMart uses third-party accredited laboratories for customers based in the United
States, those arrangements are governed by separate agreements with those laboratories,
which hold relevant US accreditations (including CLIA and CAP). In all such cases,
appropriate contractual safeguards are in place, including Standard Contractual Clauses
(SCCs) or UK International Data Transfer Agreements (IDTAs) where applicable.
Stripe, our payment provider, may process transaction data in jurisdictions outside the UK or
EEA. Stripe’s data transfers comply with UK GDPR requirements. Please refer to Stripe’s
Privacy Policy for further information.
9. Data Retention
We retain your personal data for the following periods, in accordance with applicable UK
clinical and regulatory guidance:
Data Type Retention Period Basis
Family genetic records (test
results, clinical reports)
Minimum 30 years, or longer if
clinically relevant
NHS/UK clinical records
guidance for family genetic
records
Genomic data used for
research (anonymised)
Indefinitely, subject to strict
anonymisation and safeguards
UK GDPR Article 89 —
scientific/public interest
research
Transaction records (date,
amount, service)
7 years HMRC financial records
obligation
Payment data (card details,
billing address)
Not retained by MolMart — held by
Stripe only
Stripe Privacy Policy
App interaction and support
records
Duration of the customer relationship
plus 2 years
Legitimate interests
10. Donor–Recipient Genetic Matching
Where you are using a sperm or egg donor, SureMart offers a genetic matching service that
compares your genomic data against that of the donor to assess shared carrier variants that
may represent a reproductive risk.
This service involves the processing of genetic data from both the recipient and the donor.
Both parties must provide explicit, separate consent before any matching analysis is
performed. Donor data used for matching purposes is processed solely for that purpose and
is not used for any other analysis or stored beyond what is necessary to complete the
matching report.
If you are a donor whose data may be used in a matching service, you will be informed of
this use and your consent will be obtained in advance.
11. The SureMart Application
SureMart includes an AI-enhanced patient application that supports you before and after
testing. The app may collect and process the following:
• Your results and associated clinical information, to provide personalised guidance
• Responses to in-app questions or assessments
• Records of in-app interactions with our AI-supported genetic counselling content
Data collected through the app is subject to the same protections and retention policies
described in this Privacy Policy. The app does not make clinical decisions independently;
any outputs are supportive in nature and are not a substitute for advice from a qualified
genetic counsellor.
You may request deletion of your app data at any time by contacting us at
mmikkelsen@molmart.co.uk, subject to any retention obligations described in Section 9.
12. Cookie Policy
Our website (suremart.uk) and application use cookies and similar tracking technologies.
This section explains what we use and why.
What are cookies?
Cookies are small text files placed on your device when you visit a website. They allow the
site to recognise your device and remember information about your visit.
Cookies we use
Category Purpose Can be declined?
Strictly necessary Essential for the website and app to function
(e.g. maintaining your session, security tokens).
Cannot be disabled.
No
Functional Remember your preferences (e.g. language,
accessibility settings).
Yes
Analytics Help us understand how visitors use the site
(e.g. pages visited, time on site). Data is
anonymised where possible.
Yes
Marketing We do not currently use marketing or
advertising cookies.
N/A
Your cookie choices
When you first visit our website, you will be presented with a cookie consent notice. You may
accept all cookies, accept only strictly necessary cookies, or manage your preferences in
detail. You can update your cookie preferences at any time via the cookie settings link in the
footer of our website.
You may also control cookies through your browser settings. Note that disabling certain
cookies may affect the functionality of our website and app.
We comply with the UK Privacy and Electronic Communications Regulations (PECR) in our
use of cookies.
13. Your Rights Under UK GDPR
Under UK GDPR, you have the following rights:
Right Description
Right to Access Request a copy of your personal data held by us
Right to Rectification Request correction of inaccurate or incomplete data
Right Description
Right to Erasure Request deletion of your data, subject to legal and clinical
retention obligations
Right to Restrict Processing Request that we limit how we use your data
Right to Data Portability Receive your data in a portable, machine-readable format
Right to Object Object to processing based on legitimate interests
Right to Withdraw Consent Withdraw consent at any time without affecting prior lawful
processing
Right to Human Review Request human review of any automated analysis or AIgenerated
output
To exercise any of these rights, please contact mmikkelsen@molmart.co.uk. We will
respond within one calendar month. Where requests are complex or numerous, we may
extend this by a further two months, in which case we will notify you.
14. Security Measures
We take strict measures to protect your personal and genetic data, including:
• Encryption of sensitive data in transit and at rest
• Access controls to limit data access to authorised personnel only
• Secure storage of genetic samples and sequencing results
• Regular security reviews and risk assessments
• Data Processing Agreements with all third-party partners
15. Changes to This Privacy Policy
We may update this policy periodically to reflect changes in our services, legal obligations, or
data practices. The latest version will always be available on our website at suremart.uk.
Where changes are material, we will notify you directly.
16. Contact and Complaints
If you have any concerns about how we process your data, please contact:
Name Markella Mikkelsen, Data Protection Officer
Email mmikkelsen@molmart.co.uk
Address The Renold Building, 32a Altrincham St, Manchester M1 7JR, UK
You also have the right to lodge a complaint with the UK Information Commissioner’s Office
(ICO):
Website https://ico.org.uk/make-a-complaint/
Phone 0303 123 1113
