Privacy Notice

1. Who we are

The data controller for personal data processed through the Service is Andi Thomaj, a sole trader registered in Tiranë, Albania (register number M61725001N), trading as Ancestrify ("we", "us"). Full trader details are in our legal notice. You can contact us at info@ancestrify.io for any privacy-related question or to exercise the rights described below.

We are established outside the EU/EEA. Where the GDPR applies to our processing of your data, we are required to designate a representative in the Union under Article 27; we are in the process of appointing one and will name them here. Until then, please write to the address above, we answer every data-protection request directly, and being outside the EU does not reduce any of the rights described in this notice.

2. What data we collect

3. How we use your data and our legal basis

• To provide the Service (run your analysis, generate your report, keep your dashboard working), performance of our contract with you (Art. 6(1)(b) GDPR), and your explicit consent for the genetic data (Art. 9(2)(a) GDPR).
• To take payment and prevent fraud, performance of our contract and our and POK's legitimate interests (Art. 6(1)(b) and (f)).
• To keep the Service secure (rate-limiting, abuse detection, log review), our legitimate interests (Art. 6(1)(f)).
• To communicate with you about your account, purchases, and changes to the Service, performance of our contract (Art. 6(1)(b)) and, for non-essential communications, your consent (Art. 6(1)(a)).
• To comply with our legal obligations, including tax, accounting, and responses to lawful requests, Art. 6(1)(c).
• To show your entry on the public ancestry leaderboard, only if you choose to. No order is listed by default: once an Ancient Ancestry (qpAdm) or Ancestry Map (G25) analysis is complete you can join the leaderboard from your dashboard's "Edit details", picking a public nickname and country of origin, and your order's ancestry percentages then appear under that nickname (with your order's profile picture, when it has one). Your real name is never shown. Joining is your explicit consent (Art. 9(2)(a) GDPR), and you can opt any order out at any time from the same place, its entry and picture stop being served.

4. Who we share data with

We do not sell your personal data. We share data only with the following categories of recipients, under written contracts that require them to protect it:

• POK Payments (RPay Ltd), card payment processing as our payment provider on this website; card authorisation, settlement, and fraud prevention.
• Apple (Apple Distribution International Ltd, Ireland), the seller of in-app purchases made in the Ancestrify iOS app and the provider of Sign in with Apple. For a purchase Apple sends us a signed transaction record; if you choose Sign in with Apple on our login or sign-up page or in the iOS app, Apple tells us a stable account identifier, the email address you chose to share (which may be a private relay address Apple forwards) and, on first sign-in, your name, so we can create or sign you into your account. That is the only data exchanged, it flows from Apple to us and not the other way, and it is used on the basis of the contract you enter by signing in. Whichever of the two you sign in from, it is one account. Apple's sign-in script loads only on those two pages and never on the rest of the site. Deleting your account also revokes the Sign in with Apple link on Apple's side.
• Cloudflare, application hosting, edge delivery, DDoS protection, and privacy-first website analytics (Cloudflare Web Analytics). Those analytics set no cookies and store no identifier in your browser, so they cannot recognise you across visits and are not governed by the cookie choices below; they tell us only how many people viewed each page. Cloudflare also provides private file storage: a file you upload is received there, moved to our own servers and then erased from Cloudflare, and the videos made for your order are kept there for you to download.
• OpenFreeMap and NASA GIBS, map tiles and satellite imagery for interactive maps on dashboard pages. These and every other third-party source we rely on are listed, with their licences, on our credits page.
• Hetzner Online GmbH (Germany/Finland, EU), the servers that run our analysis pipeline and store your data, including your genotype file.
• Providers of specialised analysis tooling, computing services we use while an ancient-ancestry analysis is being prepared. They receive working data with the identity removed: an internal order number, the origins you declared, basic facts about the sample such as sex and testing company, and results computed during the analysis such as model fit statistics and population names. They never receive your name, email address, account or payment details, your file's name or your genotype file, which is never shared with them, so they cannot tell whose analysis it is. Every result is reviewed and approved by a person before you see it. Some of these providers operate outside the European Economic Area, see "International transfers" below.
• Resend, delivery of transactional and, where you have opted in, marketing email.
• BytePlus (ByteDance), video generation used to produce the illustrative artwork shown alongside ancestral populations. No customer data of any kind is sent to BytePlus; it is used only to create generic reference imagery.
• Google (Google Ireland Limited), website analytics through Google Analytics 4, only if you accept analytics cookies, and advertising measurement through Google Ads, only if you accept advertising-measurement cookies. Analytics receives the pages you view, a random browser identifier, your approximate location derived from your IP address, and basic device and browser information. Ads measurement may additionally receive a first-party ad-click identifier so a visit can be attributed to the correct campaign. We disable ad personalisation and do not use remarketing or customer-list audiences. Google may process this outside the EU, including in the United States, see "International transfers" above and how Google uses business data. No genetic data, uploads, results, or account details are sent to Google. Declining or withdrawing either optional category prevents the corresponding measurement from being activated or continuing. Separately, if you choose Sign in with Google on our login or sign-up page or in the iOS app, Google tells us your Google account identifier, your email address and your name so we can create or sign you into your account; that is the only data exchanged, it flows from Google to us and not the other way, and it is used on the basis of the contract you enter by signing in. The sign-in script loads only on those two pages and never on the rest of the site.
• An assistant you connect yourself (for example Claude, ChatGPT or Cursor), only if you connect one to your Ancestry Workbench and only while it stays connected. It is not our processor: you choose it, it acts for you under your own account with its provider, and that provider's terms and privacy policy apply to what it receives, including where it processes it. When you allow it, it can read what the Workbench shows you: your kits and finished reports as they are named there, your balance and statement, the populations in our reference panel, and the results of your models, rotations and distance scans. If you also let it run work, it can start and cancel that work, paid from your balance within the daily limit you set. It never receives your password, your email address, your payment card or your raw DNA file. We keep a record of each connection (the app's name and web address, when you connected it and last used it, its daily limit and what it spent) while it is connected and for 400 days after you disconnect it, and it is included in your data export. You can disconnect it at any time in the Workbench, which ends its access at once.
• Professional advisers (lawyers, accountants, auditors) where necessary, and regulators or courts where required by law.

5. International transfers

Some of our processors operate in countries outside the UK and the European Economic Area, including the United States. Where we transfer personal data outside those regions, we rely on appropriate safeguards, typically the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or adequacy decisions, and we apply additional measures where the law of the destination country makes them necessary.

6. How long we keep your data

We keep your account data for as long as your account is active and for a reasonable period afterwards to handle disputes and comply with legal obligations. We keep your genotype data only for as long as we need it to deliver and support your analysis; you can request earlier deletion at any time by emailing info@ancestrify.io. Payment and tax records are retained by us and our payment provider for the period required by applicable accounting and tax law (typically 6 to 10 years). A free G25 Admix request holds no documents: only your coordinate row, your name, your country and your region. They are kept for as long as your account holds the report, and are deleted with your account or on request to support, in which case the free report goes with them.

7. Your rights

Depending on where you live, you have rights over your personal data, including:

• access to your data and a copy of it;
• correction of inaccurate data;
• deletion of your data ("right to be forgotten");
• restriction of, or objection to, certain processing;
• portability of data you provided to us;
• withdrawal of consent at any time (without affecting processing carried out before withdrawal);
• the right to lodge a complaint with your local supervisory authority, in the EU/EEA, the data protection authority of the country where you live, work, or where you believe the issue arose; in the UK, the Information Commissioner's Office (ico.org.uk); and in Albania, the Commissioner for the Right to Information and Protection of Personal Data (idp.al).

To exercise any of these rights, email info@ancestrify.io. We will respond within the timeframe required by applicable law (typically one month).

8. Cookies

We use a small number of cookies that are strictly necessary to operate the site (authentication, security, load balancing) and, with your consent, optional analytics and advertising-measurement cookies. You can review and change your choices at any time via the Cookie preferences link in the footer.

On your first visit the browser also keeps a small first-party record of how you arrived (the page you landed on, the referring site and any campaign tags in the address) in local storage for up to 90 days. It is not a cookie, it is not shared with anyone, and it leaves your browser only if you create an account, where it is stored with your account so we can tell which channels bring customers.

• cc_cookie (strictly necessary, 6 months), remembers your cookie choices so we do not ask again.
• g_state (strictly necessary, set by Google only on our login and sign-up pages), remembers that you dismissed Google's sign-in prompt so it is not shown again straight away. It is not set unless you visit those pages.
• anc_theme (preference, 1 year), remembers the colour palette you chose under Appearance in Settings, so the app opens in your colours. It holds only the palette's name and is set only after you change the palette.
• _ga and _ga_FM9RJCNPQJ (analytics, 2 years), set by Google Analytics. They store a random identifier used to recognise repeat visits and to keep track of the current visit. This does not tell us your name, but it is not fully anonymous either.
• _gid (analytics, 24 hours), set by Google Analytics to distinguish visitors.
• _gcl_* (advertising measurement, up to 90 days), set by Google Ads to remember that a visit came from an advertisement and attribute later measured activity to the correct campaign. It is not used by us for personalised ads or remarketing.

Analytics and advertising-measurement cookies are only set if you accept their respective categories, and withdrawing consent deletes them.

9. Children

The Service is not intended for children. We do not knowingly collect data from anyone under 18. If you believe a child has provided us with data, please contact us and we will delete it.

10. Security

We use technical and organisational measures appropriate to the sensitivity of the data we hold, including encryption in transit, encrypted storage, access controls, short-lived signed session tokens, rotating refresh sessions, and regular review of our hosting and processor configurations. No system is perfectly secure; if we ever experience an incident affecting your data we will notify you and the relevant authorities as required by law.

11. Changes to this notice

We may update this notice from time to time. When we do, we update the "Last updated" date at the top and, where the changes are material, give you reasonable advance notice (for example, by email or in-app notice).

12. Contact

For privacy questions, requests, or complaints, email info@ancestrify.io or write to Ancestrify.