Genomic Life Privacy Policy

Last Updated: July 2024

This Privacy Policy (this “Policy”) outlines how Genomic Life (“We”, “Us”, “Our”) may use and disclose personal, medical, and other information pertaining to our users (“Members”, “You”, “Your”). Genomic Life is committed to protecting Your privacy and the information We handle, both physically and electronically.

While Genomic Life was originally established as a non-medical service provider that didn't issue medical referrals or prescriptions, our scope of services has evolved. Although we still do not provide direct medical treatment or clinical services, we now engage in business processes that involve the handling of information potentially covered by the Health Insurance Portability and Accountability Act (HIPAA). As such, our role within the health information management ecosystem has shifted, and we have transitioned from merely aligning with HIPAA's spirit and intention to complying with certain HIPAA requirements. In recognition of our adherence to robust security and privacy standards, we maintain our certifications under the HITRUST and NIST CSF which provides evidence of compliance for HIPAA security rule controls and HIPAA breach notification rules.

This Policy applies to users of Our services, websites (such as www.GenomicLife.com), and any mobile applications, platforms, and any other features or tools that We offer or may develop (collectively, Our “Services”). Please note that other sites You may visit, including third-party sites linked from any of Our websites, may have their own privacy policies and We are not responsible for the content or practices of those websites.

We may provide additional notices at the time when We collect or process Your personal information. For example, We may provide additional disclosures or seek consent prior to Your use of certain of Our Services. This policy is meant to supplement, but not limit, the information in those notices.

We may amend this Policy at any time by posting updates to this page. If there are material changes, We may place a prominent notice on the website and/or contact You via email or through Our platforms. If Your membership is provided by a third-party entity, such as Your employer, they may have requested specific variations from this Policy. For further information on any such variations, we recommend reaching out to Your employer.

Personal Information Collected

The types of data We collect from You may vary depending on your interactions with Genomic Life. This information can be obtained through different means, including direct input from You, data provided by your employer or third parties like healthcare providers, or through Your use of Our websites using cookies and other tracking technologies.

Contact and Account information

Your name, phone number, email address, postal address, username, shipping address, phone number, communication preferences, and information on which Services You have shown interest in.

Self-Declared Physical, Demographic, and Behavioral information

Date of birth, gender, gender identity, and race/ethnicity, personal and family medical history, physical features (e.g., eye color), behavioral information (e.g., exercise habits).

Health Information

Information related to Your past, present, or future health conditions. With your consent we may request your care provider teams provide medical records, laboratory reports, or clinical action plans to inform genomic services.

Genetic Information

Collected via genetic testing kits offered as part of Our Services.

Inferences

We may infer other personal characteristics from the personal information You provide us.

Purchase (i.e., Billing) Information

Information on Your purchases and other transactions with Us, including billing and shipping information, which may be managed by third parties.

Internet or other electronic network activity information

Information provided from Your use of websites, applications, or other such services, such as Your internet protocol (IP) address, devices, browsing behavior, and usage patterns.

We may combine the personal information You provide with other information about You that We gather from other sources.

Uses of Personal Information

We only collect and process Your personal information for Our legitimate business purposes and as permitted by applicable laws, which may vary depending on where You live and where We operate.

Our purposes of processing personal information may include:

• Delivering the Services You have requested or meeting Our contractual commitments to You: This may include sharing Your personal information with specialists, nurses, physicians, healthcare institutions, and other individuals and entities involved in delivering healthcare services to You. It may also involve disclosing personal information to the employers through whom we invoice and receive payment for the services provided to You.
• Communication: For example, to send You service-related announcements and education.
• Engagement: To conduct engagement campaigns and targeted education or awareness campaigns.
• Complying with regulatory requirements and other applicable laws: For example, to meet records retention obligations.
• Maintenance or improvement of the Services and Our websites and operations: For example, maintaining, improving, and protecting Our websites, including their functionality and any personalized features and new product development and services. As otherwise permitted: Any other legal permissible purposes relevant to Your relationship with Us. We may also de-identify Your personal information so it can no longer be used to identify you. In such circumstances, the information may no longer be considered personal information and would not be covered by this Policy.

We aim to retain Your personal information for no longer than as needed for the specific purpose(s) for which it is collected. However, We may be required by law to retain certain personal information for a longer period. We may also need to retain personal information for record-keeping, accounting, or insurance purposes, or to establish, defend against or respond to legal claims.

Sharing of Personal Information

We do not sell, share, rent, or trade personal information other than as disclosed within this Policy or with Your consent. We may provide personal information to other parties in the following circumstances:

• To Our service providers and other third parties that work on Our behalf to provide the Services or conduct business functions;
• For provision of the Services, to include to specialists, nurses, doctors, healthcare facilities, and other persons and entities involved in providing You healthcare services;
• With genomic testing laboratories in order to facilitate Your genomic lab tests, clinical action plans, and billing;
• When You choose to participate in research studies or programs, we may share Your personal information with research institutions or organizations;
• With Your consent, We may request or share genetic information and analysis results with healthcare providers, such as doctors or medical practitioners, to assist in diagnosis or treatment;
• When you choose to integrate Your Genomic Life account and associated information with third-party applications, platforms, or wellness services;
• With partners that provide genetic or genomic products personalized or tailored to You;
• For billing involved in the process by which We bill and collect payment;
• With digital agencies and data providers to conduct awareness, engagement, and educational campaigns or targeted communications.
• Pursuant to a corporate merger, consolidation, restructuring, the sale of the outstanding stock, assets, or other corporate change, including during any due diligence process; and
• In the following cases:
• • where such disclosure is necessary for compliance with a legal obligation to which We are subject, including public health requirements or a subpoena, court order or search warrant (in which case We will take reasonable steps to protect that personal information and limit disclosure to what is required);
• • to enforce our Terms of Service or other contracts with you, including investigation of potential violations thereof;
• • respond to claims regarding violations of third-party rights;
• • protect the rights, property or personal safety of Our employees, agents and affiliates, Our users and/or the public; and/or
• • as is reasonably necessary for fraud protection, spam/malware prevention.

Security Measures to Protect Your Personal Information

We have implemented reasonable and industry-standard organizational, technical, and administrative safeguards to protect personal information. We update such measures as appropriate to protect Our information security systems. However, there is no perfect security, and even with those measures, We cannot guarantee that unauthorized access, use, alteration or disclosure of Your personal information will not occur.

Children

Our Services are not intended or designed for children or minors under the age of 18. We do not have any actual knowledge that individuals under the age of 18 use the Services without parental consent. If You believe that We might have inadvertently collected personal information about a child or minor under the age of 18, please contact Us so that We may take appropriate action.

Applicable Laws

We do not believe the California Consumer Privacy Act (CCPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), or Virginia Consumer Data Protection Act (VCDPA) currently apply to Us. As We evolve, We intend to adopt CCPA, CPA, CTDPA, and VCDPA requirements when and as applicable to Us and we may incorporate any additional privacy regulations herein at Our discretion.

Your Rights

As a user of Our Services, You may have certain rights and choices regarding the personal information We collect and how it’s used. These rights may vary depending on Your place of residency and applicable state and federal privacy laws. We may deny certain requests under specific circumstances, and in such circumstances, We will advise You of any such denial and provide its reasons. You may contact Us at the contact information provided below with questions about these Your rights.

1.) Access and Correction: You have the right to access the personal information that We hold about you. You can request corrections, amendments, or deletions to Your information if it is inaccurate or incomplete.

2.) Consent and Withdrawal: Where We process Your information based on Your consent, You have the right to revoke such consent at any time.

3.) Data Portability: You may have the right to receive Your personal information in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another controller without hindrance.

4.) Objection to Processing: You may have the right to object to the processing of Your personal information for certain purposes.

5.) Restriction of Processing: You may have the right to request that We restrict the processing of Your personal information under certain circumstances, such as if You contest the accuracy of the data.

6.) Filing Complaints: You may have the right to file a complaint with the appropriate supervisory authority if You believe Our processing of Your personal information violates applicable law.

7.) Deletion: You may have the right to ask for the deletion of Your personal information from Our records. Please note, Your rights may be limited under specific circumstances, such as when We need to retain data to comply with Our legal obligations or protect the rights of others.

See the “Contact Us” section below about how to request to exercise Your rights. Your request will be forwarded to an appropriate member of Our team. Depending on the nature of the request, You may be required to provide additional information (including to verify Your identity). In accordance with the applicable laws, We will use reasonable efforts to comply with Your request in a timely manner. Additionally, if You have concerns with how We handle Your request, You may have the right to request an appeal of Our determination. If You would like to request such an appeal, please include information about Your prior request so that We can review Our prior decision.

We will not discriminate against You for exercising Your rights under this Policy. Please note that if you decide to exercise certain right under this Policy, such as to revoke Your consent to Our collection, use, disclosure, or retention of personal information, We may not be able to provide Services to you.

Cookies and Tracking Technologies

Our current and future websites, applications and platforms may use cookies and other tracking technologies. Cookies are small data files that are placed on Your device by websites You visit. These and other tracking technologies, such as pixels, web beacons, and tags are used widely to make websites work more efficiently, including to enhance user experience, as well as to provide information about website visitors to website owners.

Most web browsers allow some control of cookies through browser settings. Please keep in mind that if You set Your browser to reject cookies, Your user experience when visiting websites may be affected. Our websites do not currently respond to “Do Not Track” browser settings.

In certain cases, We may provide a separate cookie notice or consent regarding Our use of cookies and tracking technologies.

For more information about cookies, including how to manage and delete them, please visit www.allaboutcookies.org.

Mobile and SMS Communications

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Notice of Privacy Practices

Genomic Life also maintains a Notice of Privacy Practices (NOPP) that specifically covers how health information about You may be used and disclosed, as well as how you can access such information. A copy of the NOPP can be found online at GenomicLife.com under our Governance & Policies section.

Contact Us

If You have any questions about this Policy or the personal information We collect or process about You, or to exercise any of Your rights to Your personal information, please contact Us at:

Navigation@GenomicLife.com

If You wish to reach Us via mail, Our postal address is:

3344 N Torrey Pines Ct. Suite 100, La Jolla, California 92037