Draft — pending legal review. The final wording of this policy is being finalised with qualified counsel. The structure below reflects what the published policy will cover.
DRAFT — pending legal review. Not legal advice.
Biological Sample Collection & Processing Consent
This notice explains how your biological sample is collected, handled, processed and
disposed of when you use a VAMS BIOME microbiome service. It is written for you — the
person providing the sample — in plain English. Please read it before you collect your
sample. By collecting and returning your sample kit, you confirm that you have read and
understood this notice and consent to the collection and processing described below.
VAMS BIOME is a service of VAMS BioInnovation Private Limited ("VAMS", "we", "us"), an
India-incorporated private limited company with its registered office at
Plot No. 59, A-12-4-1, Near Matha Towers, K P Nagar, Benz Circle, Vijayawada, Andhra Pradesh 520008, India. This notice is governed by the laws of India, including the
Digital Personal Data Protection Act, 2023 (DPDP Act), and other Laws of India, including applicable laws of the State of Andhra Pradesh
requirements that apply.
Important — what VAMS is and is not. VAMS is a wellness and microbiome-education
service. VAMS is not a laboratory, an accredited or licensed laboratory, a healthcare
provider, a diagnostic provider, or a regulated medical-device manufacturer. Your sample is
analysed by qualified third-party laboratories on our behalf, as described below. Your VAMS
report is informational and wellness-oriented. It does not diagnose, rule out, treat, prevent
or predict any disease or medical condition, and it is not a substitute for advice from a
qualified healthcare professional.
What Your Sample Is
Depending on the service you purchased, your kit collects a small biological sample — for
example a swab or a small quantity of biological material from the relevant site of the body.
The purpose of collecting this sample is to characterise the microbial community (bacteria and
other micro-organisms) present in it, so that we can generate your microbiome report.
The primary object of analysis is microbial genetic material. Human cells and human DNA
may be incidentally present in any biological sample. How incidental human DNA is handled is
explained in the section "Incidental Human DNA" below.
How to Collect Your Sample (At Home)
Your kit is designed for you to collect your own sample at home. Please follow the printed
instructions supplied in your kit exactly — they take priority over this general summary if
anything differs. In general:
Read the full instructions first, and check the kit contents and any use-by / expiry
date before you begin. Do not use a kit that is damaged, open, or past its date.
Prepare as directed. Some services ask you to avoid certain activities, foods or products
for a period before collection. Follow any such timing guidance in your kit.
Collect from the correct site, using only the collection device provided, following the
step-by-step instructions and any diagrams.
Do not substitute your own containers, swabs or preservative fluids. Use only what is in
the kit.
Label and seal the sample exactly as instructed, using the pre-printed coded label
provided (see "Coded Identifiers" below). Do not write your name, contact details or other
directly identifying information on the sample tube.
Record the date and time of collection if the instructions ask you to.
If you are unsure at any step, contact us at legal@vamsbiome.com before returning the sample.
Hygiene & Safe Handling
Wash and dry your hands thoroughly before and after collection.
Keep the collection surfaces clean and avoid touching the tip of any swab or the inside
of any container, to reduce contamination.
Collect only your own sample. Each kit is intended for a single named individual and a
single collection. Do not pool or mix samples from more than one person.
Store the sealed sample as directed on the instructions until you return it (for example,
at room temperature or refrigerated, as specified), and return it within any stated window.
Do not eat, drink, or handle food while collecting, and keep kits away from children and
pets.
Dispose of single-use packaging hygienically. If you are unwell, or if collection would
be uncomfortable or unsafe for you, do not proceed — contact us or your healthcare
professional first.
Biological samples are handled as potentially biohazardous. Please seal and package the sample
in the provided outer packaging so that it is safe for return transit.
Return & Chain-of-Custody (General)
Once sealed and packaged, your sample is returned using the return method described in your kit
(for example, via Approved third-party courier and logistics providers selected according to serviceability, biological-sample handling requirements and applicable transport rules. The carrier for a particular order will be communicated at dispatch. within Initially available only in serviceable regions of India. International and Australian availability must not be represented as active until local operations, logistics and legal requirements are confirmed. Eligible locations will be shown during checkout., subject to any Unopened and unused collection kits may be eligible for a return request within 7 calendar days after delivery, subject to prior authorisation. For health, hygiene and sample-integrity reasons, opened, activated, registered, used, contaminated or returned biological-sample kits cannot ordinarily be accepted. Defective, damaged, incorrect or incomplete kits will be replaced or refunded in accordance with applicable consumer law.). We maintain a general chain-of-custody process designed to track your sample from
receipt to processing and disposal, including:
Coded receipt. On arrival, the laboratory records the sample against its coded identifier
(see below), not against your name.
Logging of key steps. Receipt, accessioning, processing and disposal are logged so the
status of a coded sample can be traced through the workflow.
Access controls. Physical samples and their associated data are handled by authorised
personnel under appropriate security and confidentiality controls.
The specifics of custody, transport and logging are operational and may change over time; this
section describes the intent at a general level rather than a fixed procedure.
Coded Identifiers
To protect your privacy, your sample and the resulting laboratory data are handled under a
coded identifier (a barcode / reference number), not under your name. Directly identifying
information about you (such as your name and contact details) is stored separately by VAMS and
is linked to the coded identifier only where necessary to deliver your service and report.
This means the qualified laboratory that processes your sample generally works with a coded
sample rather than your identity. Access to the information that links a code back to a specific
person is restricted to authorised personnel and used only as needed to provide the service, to
meet legal obligations, or as otherwise permitted under our Privacy Notice.
Who Processes Your Sample
Your sample is processed by qualified third-party laboratories engaged by VAMS to perform
the analysis on our behalf. The processing location and the laboratory's accreditation or
licensing status are:
Processing location: Samples may be processed by qualified third-party laboratories in India or another location disclosed to the customer before sample submission or processing. The specific processing laboratory and country will be identified in the order documentation or test report where applicable.
Accreditation / licensing status: VAMS BioInnovation Private Limited is not itself represented as an accredited clinical laboratory. Laboratory accreditation, quality certification and permitted testing scope vary by processing partner and will be disclosed for the applicable service. No accreditation should be inferred unless expressly stated and independently verifiable.
VAMS itself is not a laboratory and is not an accredited or licensed laboratory. We select
laboratory partners on the basis of their competence and applicable quality standards, and we
put in place appropriate data-processing terms with them. The set of laboratories and
supporting sub-processors we use may change over time; a current list can be provided on request
(see https://www.vamsbiome.com/legal/subprocessors) and any applicable regulators are noted at Ministry of Corporate Affairs; Ministry of Electronics and Information Technology; Data Protection Board of India; Department of Consumer Affairs and Central Consumer Protection Authority; and, depending on the product or claim, CDSCO, FSSAI, relevant State authorities and other competent regulators..
Incidental Human DNA
Our analysis targets microbial genetic material. However, any biological sample can contain
incidental human cells and human DNA. Our approach is to minimise, filter and destroy
incidental human DNA:
Minimise. Collection methods and laboratory processing are oriented toward recovering
microbial material, which limits the human genetic content that is meaningfully analysed.
Filter. During data processing, sequence data identified as human is computationally
filtered out and excluded from the microbiome analysis. We do not use your sample to generate
a human genetic (genomic) profile of you, and we do not perform human genetic testing as part
of this service.
Destroy. Human-derived sequence reads that are filtered out are not retained as part of
your microbiome dataset, and any residual physical sample is destroyed after processing as
described below.
We do not sell your sample or your genetic data, and we do not use incidental human DNA for
purposes beyond the technical steps needed to deliver your microbiome report, unless you give a
separate, specific, optional consent (see "Optional Consent for Research Use").
What Happens to Your Sample
At a high level:
Receipt and accessioning. The laboratory receives and records your coded sample.
Preparation and analysis. The sample is prepared and analysed to characterise its
microbial community.
Data generation. The analysis produces microbiome data linked to your coded identifier.
Report generation. VAMS uses that data to generate your informational, wellness-oriented
microbiome report.
Residual-sample handling. After processing, any residual physical sample is retained only
for the limited period described below, then destroyed.
Handling of the data derived from your sample (including how long it is kept, your rights,
and how you can withdraw consent) is described in our Privacy Notice and summarised under
"Your Rights" below; data is retained for Retention depends on the record type and purpose. Generally: order, invoice and statutory business records for up to 8 years; identifiable microbiome test data and reports for up to 3 years after report delivery or account closure; raw sequencing files for up to 12 months after report delivery; support records for up to 3 years; and consent records for as long as necessary to demonstrate compliance. Data may be retained longer where required by law, litigation hold or explicit research consent, and may be deleted or anonymised earlier when no longer necessary..
Residual-Sample Retention & Destruction
After your sample has been processed, any residual physical sample is retained only for a
limited period — Unless a different period is disclosed and consented to, residual biological samples will normally be destroyed within 30 days after the final report is issued. Samples may be retained longer only for necessary repeat testing, quality investigation, legal requirements or separately consented research. — to allow, for example, re-testing or
quality-control checks where necessary. At the end of that period, the residual physical sample
is destroyed in accordance with applicable biological-waste and safety requirements.
VAMS does not retain your residual physical sample in a long-term biobank, and does not transfer
your residual sample to research collaborators, unless you give a separate, specific, optional
consent for such use (see below). If you withdraw your consent, we will stop further processing
and arrange for destruction of any residual sample that has not already been destroyed, except
where we are required to retain limited records to meet a legal obligation.
Optional Consent for Research Use
Any use of your sample or the resulting data for research — including longitudinal
profiling, algorithm or product development, commercial research, biobank retention, or sharing
with research collaborators — is entirely optional and separate from the service you
purchased.
You can purchase and receive your microbiome service and report without agreeing to any
research use.
Consent to research use is requested separately and is granular: you can agree to one
optional purpose without agreeing to others. It is never bundled with, or presumed from, your
purchase or from this collection consent.
If you do give a research consent, it will describe that specific use, and you can withdraw
it at any time. Withdrawal will not affect processing already carried out before withdrawal,
and does not affect the delivery of your core service.
Declining research use has no effect on your ability to use the service or receive your
report.
Your Rights
Under the DPDP Act and applicable law, and subject to lawful limits, you may:
Access the personal data we hold about you and information about how it is processed;
Correct or update inaccurate or incomplete personal data;
Erase personal data where it is no longer required for a lawful purpose;
Withdraw consent at any time (including any optional research consent), as easily as it
was given, without affecting the lawfulness of processing before withdrawal;
Nominate another individual to exercise your rights in the event of death or incapacity;
Raise a grievance with us through our grievance-redressal process; and
Complain to the Data Protection Board of India if your grievance is not resolved.
To exercise any of these rights, contact privacy@vamsbiome.com. General service
queries can be sent to legal@vamsbiome.com.
Limits of This Notice
Nothing in this notice limits any liability that cannot lawfully be excluded — including
liability for fraud or wilful misconduct, our obligations to safeguard your personal data, and
your statutory remedies as a consumer. This notice does not remove your access to Consumer
Commissions, statutory grievance mechanisms, or competent regulators. It does not affect other
terms that apply to your purchase, including our Terms of Service and Privacy Notice, which you
should read alongside this notice.
Version and Change History
Document name: Biological Sample Collection & Processing Consent
Version: 1.0
Effective date: 10 July 2026
Change history: v1.0 (10 July 2026) — Initial publication.