Consumer Health Data Privacy Policy

Effective date: September 17, 2025

Last modified: September 17, 2025

This Consumer Health Data Privacy Policy ("Policy") describes the practices of EvaGenomics ("Company" or "We") for collecting and using any data that is linked or reasonably linkable to a specific individual and that identifies that individual's past, present, or future physical or mental health status that Company collects or controls the collection of ("consumer health data"). This Policy applies to the websites, mobile applications, and related services (collectively, the “Services”) offered by Company.

Please read this Policy carefully to understand our policies and practices regarding your consumer health data and how we will treat it. If you do not agree with our policies and practices, you should not use the Services. Other privacy policies may apply for your personal information that is not consumer health data. To view our general privacy policy describing how we treat other personal information, visit https://www.evagenomics.com/privacy-policy . When we make material changes to this policy, we place a banner on this webpage to notify you of this update.

  1. Consumer Health Data We May Collect About You

We collect and use different types of consumer health data from and about you, including:

●      Information about any of the following:

●      individual health conditions, treatment, diseases, or diagnoses;

●      family health history;

●      diagnostic testing, treatment, or medication;

●      social, psychological, behavioral, or medical interventions;

●      bodily functions, vital signs, symptoms, or measurements of physical or mental health status;

●      Biometric data, meaning data that is generated from the measurement or technological processing of an individual's physiological, biological, or behavioral characteristics and that identifies a consumer, whether individually or in combination with other data. Biometric data includes, but is not limited to:

●      imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template can be extracted; or

●      keystroke patterns or rhythms and gait patterns or rhythms that contain identifying information.

●      Genetic data, meaning any data, regardless of its format, that concerns a consumer's genetic characteristics. Genetic data includes, but is not limited to:

●      raw sequence data that results from the sequencing of a consumer's complete extracted deoxyribonucleic acid (DNA) or a portion of the extracted DNA;

●      genotypic and phenotypic information that results from analyzing the raw sequence data; and

●      self-reported health data that a consumer submits and that is analyzed in connection with consumer's raw sequence data.

●      Data identifying a consumer seeking health care services. Health care services means any service provided to a person to assess, measure, improve, or learn about a person's mental or physical health, including but not limited to:

●      individual health conditions, status, diseases, or diagnoses;

●      social, psychological, behavioral, and medical interventions;

●      health-related surgeries or procedures;

●      use or purchase of medication;

●      bodily functions, vital signs, symptoms, or measurements of the information described in this subsection;

●      diagnoses or diagnostic testing, treatment, or medication;

●      reproductive health care services; or

●      gender-affirming care services.

●      Precise location information that reasonably indicates a consumer's attempt to receive or acquire health services or supplies.

●      Any inferences of the above categories derived, extrapolated, or inferred from non-health information.

We use these categories of consumer health data for the following purposes:

●      Fulfilling the purposes for which you provided the data or that were described when it was collected, including analyzing your particular set of health-related symptoms and/or analyzing the genetic information derived from the saliva sample you submit.

●      Performing the services or providing the goods that you request from us and responding to your questions or requests for information.

●     Updating your personalized genetic profile from time to time to provide you with the most current information.

●      Re-analyzing your genetic profile based on additional symptoms you provide, if you purchase these additional services.

●      Notifying you about changes to our websites, mobile applications, products, or Services.

●      Facilitating services and operations performance, security, and integrity, including:

●      undertaking activities to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted consumer health data or that otherwise threaten to compromise the performance, security, or integrity of our business; and

●      performance analytics, identity verification and authorization, site and application optimization, and quality control.

●      Recordkeeping and auditing.

●      Complying with our legal obligations and risk management, audit, investigations and reporting, and other legal and compliance reasons.

●      Administering customer accounts and preferences.

●      Conducting internal research on health and genetic information.

●      Measuring or understanding the effectiveness of non-personalized advertising and delivering non-personalized advertising served as part of your current interaction with you.

2. Consumer Health Data Sources

We collect consumer health data from the following sources:

●      You, including when you request certain health-related services, answer health-related questionnaires, and upload your health information to the Services.

●      Your device when you visit or interact with our sites, applications, or services, including through cookies, web beacons, and similar technologies that automatically send us information when you browse, use, visit, or otherwise interact with our sites, applications, or services.

3. Consumer Health Data Disclosures

We may disclose any of the consumer health data categories listed above to processors, service providers, and contractors that help us provide products and services to you, including our laboratory partners. We instruct these processors, service providers, and contractors, to only use consumer health data as permitted by our contracts with them and consistent with applicable law.

We may also disclose consumer health data as permitted by applicable law, including:

●      With your consent.

●      To prevent, detect, protect from, or respond to security incidents, identity theft, fraud, harassment, or malicious or deceptive activities.

●      To a third party acquiring our assets if Company sells its business or otherwise is part of a merger, acquisition, bankruptcy, or other transaction involving a third party taking control of our assets or business.

●      To investigate, report, or take legal action to protect our rights, property, and safety and the rights, property, and safety of others.

Note that we do not sell your consumer health data, and that third parties may not your collect consumer health data over time and across different Internet websites or online services when you use our Services.

4. Purposes of Collecting, Using, and Sharing Your Consumer Health Data

We collect, use, disclose, store, and otherwise process your consumer health data for the following purposes:

●      To generate an assessment of your health profile and potential risk factors, based on your particular symptoms, health conditions and diagnoses, and genetic information.

●      To allow you to create, maintain, customize, and secure your account with us.

●      To conduct internal and/or external research, including genetic research, when you consent to this processing.

●      To send promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences.

●      To fulfill any other use that we describe when you provide the information.

Please note that we remove personal identifiers from your genetic and health information and no longer link this information with your profile when we use it for internal research purposes. Even when we remove personal identifiers, certain categories of genetic information may still be linkable to or associated with specific individuals, given the nature of this data. When this is the case, the provisions of this privacy policy apply to such data.

5. Your Privacy Rights

You have specific rights with respect to your consumer health data. You have the right to:

●      Know: You may request confirmation that we collect, share, or sell your consumer health data.

●      Access: You may request access to your consumer health data that we have collected or control, including:

●      a list of all third parties and affiliates that we have shared or sold your consumer health data to; and

●      the email addresses or other online method to contact those third parties and affiliates.

●      Opt Out: You may withdraw your consent for our collection and sharing of your consumer health data.

●      Delete: You may request that we delete your consumer health data.

●      Appeal: You may appeal our decision to grant or not grant your request to know, access, opt out, or delete by contacting us at any of the addresses below.

To exercise any of your rights, please contact us at any of the addresses below. 

6. Contact Information

Email:                info@evagenomics.com

Address:         206 E HURON ST, SUITE 314, ANN ARBOR, MI 48104    

Phone:            +1 734-596-3921