PRIVACY POLICY

Effective Date: September 17, 2025

Last Updated: September 17, 2025

This Privacy Policy describes how EvaGenomics LLC and its affiliates ("Company," "we," or "us") collect and process personal information in relation to your use of our services and website: evagenomics.com. If you do not agree to this Privacy Policy, your choice is to not utilize our services or websites or provide personal information in connection with them. By utilizing our services and websites, you agree to this Privacy Policy and expressly consent to the processing of personal information according to this Privacy Policy. For more information about how we process your consumer health personal data, please view our Consumer Health Privacy Policy.

  1. Personal Information We Collect.

    A. Information You Choose to Give Us

  • Contact information collected through our website, including your name, address, city, state, zip code, email address, and telephone number.

  • Health information, including symptoms, health conditions, diagnoses, and treatment information when you submit the symptom checker assessment online.

  • Demographic information, including gender, age, race, and ethnic origin, when you submit the symptom checker assessment online.

  • Genetic information, including genomic information and your full DNA sequence, when you provide a saliva sample for genomic assessment.

  • Payment information to complete purchase transactions.

B. Information Automatically Collected by Using Our Website

  • Your device data and how you interact with our website, including IP address, browser type, and unique device identifier.

  • Usage information, including the pages or content you view and searches on our website.

  • Cookies and similar technology. Please review the cookie technology section below for more information.

C. Categories of Sensitive Personal Information

  • Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account

  • Racial or ethnic origin

  • Genetic data

  • Health information

  • Medical history, medical treatment, or mental or physical health conditions or diagnoses

2. How We Use Information We Collect.

We may process this information to:

  • Fulfill or meet the reason you provided the information. For example, if you provide your health-related personal information in our symptom checker assessment, we will use this information to generate the results of this assessment. We may also save your information for these purposes. 

  • Provide, offer, support, personalize, or develop our website and services.

  • Process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • Provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • Help maintain the safety, security, and integrity of our website, services, databases and other technology assets.

  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

  • Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

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

  • Personalize, measure, and improve our recruitment efforts.

  • Fulfill any other use that we describe when you provide the information.

Please note that we may anonymize or reasonably deidentify your personal information, including your genomic and/or health-related information, so that it can no longer be reasonably associated with or used to identify you in some circumstances. We may retain and use such anonymized, non-personal information for any legitimate business purpose without further notice to you or obtaining your consent, unless required by law. 

We may also use your personal information, including your health and genetic information, for internal research purposes. While we attempt to deidentify your personal information prior to processing this information for research purposes, anonymized genetic information may still be linked to specific individuals in some circumstances, given the nature of this data. When this is the case, the provisions of this privacy policy apply to such processing.

3. Disclosing, Sharing, and Selling Information. 

A. Disclosing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose personal information as stated below:

  • with laboratories, which analyze samples you may provide, as well as the information derived from these samples.

  • with third-party researchers when you expressly consent to this disclosure.

  • with data analytics, software/IT, cybersecurity, cloud service, consultants, financial, legal, and other similar providers that support our business.

  • with banks and credit card processors to the extent necessary for Company to deliver the services. 

  • when we believe sharing is necessary to protect our rights, preserve safety, investigate fraud or other wrongdoing.

  • when required by law, which includes complying with any court order, law, or legal process, including responding to a government or regulatory request.

  • in connection with the sale, transfer or financing of Company’s business or its assets, including a bankruptcy proceeding or to our affiliates.  

  • to enforce or apply our agreements, including for billing or collection purposes.

  • for any other purpose we disclose to you when you provide the information.

B. Sharing Personal Information for Personalized Advertising

In this Privacy Policy, "sharing" means disclosing a consumer's personal information to third parties for cross-context behavioral advertising or targeted advertising. "Cross-context behavioral advertising" refers to the targeting of advertising to a consumer based on the consumer's personal information obtained from the consumer’s activity across websites and applications, other than those with which the consumer intentionally interacts.  In the preceding twelve months, Company has "shared" the following categories of personal information with its third-party marketing partners for the purposes of personalized advertising: contact information, your unique device data, and website usage information.

C. Selling Personal Information 

In the preceding twelve months, Company has not sold personal information. We also do not knowingly sell the personal information pertaining to minors under the age of 16.

4. Information Security and Retention. 

We use reasonable administrative, technical, and physical security measures to protect the personal information we retain and to help ensure that it is used in accordance with this Privacy Policy.  

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless longer retention is required by law or for auditing purposes. To determine the appropriate retention period for personal information, we consider applicable laws, the volume and nature of the personal information, its purpose, and the potential risk of harm from its unauthorized use or disclosure.

5. Cookies and Tracking Technologies.

Company uses cookies and pixels as automatic data collection mechanisms that collect information, including in some instances personal information, from users of its Website and Services.  Third parties also place these tools on our Website to collect and process information about our users for various purposes, including for security, for analytics, and to facilitate targeted advertising.  These tools include: Google reCAPTCHA, Google Analytics, and Google Tag Manager.  Please carefully review the linked information associated with each tool, which is also set forth below. By visiting our Website, or otherwise using our Services, you consent to Company’s use of cookies and pixels as detailed in this Policy.  

A. Cookies

A cookie is a small text file that we store on your browser or the hard drive of your computer.  They are used to make websites function and to collect information to facilitate more secure, efficient, and customized user experiences.  Cookie use is standard for most websites. Company uses four types of cookies in connection with our Services:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Services. These essential cookies are always enabled because our Services won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our Website.   

  • Analytics cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our Services work, for example, by ensuring that users are finding what they are looking for easily.

  • Preferences cookies. These are used to recognize you when you return to our Services. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Marketing cookies. These tools record your use of our Services, the pages you have visited and the links you have followed. We will use this information to make our Services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites.

    B. Pixels

Pixels – sometimes also called "pixel tags," "clear gifs," or "web beacons" – are very small graphic images that help EvaGenomics to analyze users' behavior in connection with our Services and to measure the effectiveness of our Services and related advertising.  EvaGenomics uses pixel tags on our Website to collect information about users' use of our Services, such as which Website pages you view, which features or links you use, or other such actions you take relative to our Services.  Types of information that pixels may gather includes the IP address of the device you use to access the Services, date and time information, immediate browsing history, and technical information about your device such as the browser type and operating system.  Pixels can also allow us, or third parties, to place cookies on your device.

C. Third-Party Technologies Used

Third parties use cookies in connection with our Services. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services.  Select third-party technologies include, but are not limited to, the following:

  • Google reCAPTCHA v3: We use “Google reCAPTCHA v3” (hereinafter “reCAPTCHA”), provided by Google, Inc. ("Google"), on our Website.  The purpose of reCAPTCHA is to keep our website as secure as possible by checking whether data that enters our system – for example, through a web form – is provided by a human individual as opposed to spamming software or other robot.  To make this determination for this purpose, reCAPTCHA collects and reviews various aspects of the Website user's activity.  This assessment automatically begins when our user enters the Website.  For the purpose of confirming human activity, reCAPTCHA assesses various information that it collects – including, without limitation, IP address, browser information cursor activity, and time spent on the Website.  reCAPTCHA will also place an additional cookie in your browser upon its assessment of your activity and take a snapshot of your browser window.  Data collected during the analysis is forwarded to Google. Please note that the reCAPTCHA collection, assessment, and other processing runs completely in the background.  While reCAPTCHA processing is noted for our users both here, Website visitors are not informed that an analysis is taking place when it occurs.  As opposed to former CAPTCHA versions, which required website visitors to identify images, solve puzzles, or check a box, reCAPTCHA assesses and scores user input for human origin without any such affirmative behavior from the user.  Our goal in using the reCAPTCHA tool on the Website is to protect the Services, and users of the Services, from bots, spam, and other such unapproved and potentially malicious activity.  If you want to prevent any data about you and your behavior to be transmitted to Google, you must log out of Google and delete all Google cookies before visiting our Website or using the reCAPTCHA software.  Please visit the following page to obtain more information about reCAPTCHA: https://developers.google.com/recaptcha/.  Additional information on Google reCAPTCHA be found at https://www.google.com/recaptcha/intro/android.html, and Google's privacy policy can be found at https://www.google.com/intl/de/policies/privacy/.

  • Google Analytics: Our Website uses Google Analytics, provided by Google. This web analytics program collects and generates information, through cookie placement, about your use of the Website.  Google will use this information to evaluate your use of our Website, to compile reports on Website activity and to provide us with other services related to Website activity and internet usage.  The IP address provided to us by Google Analytics will not be merged with other data that Google provides to us.  If you would like to prevent Google Analytics from collecting your data, you can prevent this collection by utilizing the opt-out tool that Google makes available at the following site: http://tools.google.com/dlpage/gaoptout. If you use this tool, an opt-out cookie will be placed to prevent Google Analytics from collecting your information.  Google's Terms of Use and privacy policy can be found on this page: https://policies.google.com. 

  • Google Tage Manager: Our Website uses Google Tag Manager, provided by Google. Google Tag Manager is a tag management system that allows us to quickly and easily update measurement codes and related code fragments collectively known as tags on our Website. Tag Manager itself does not collect personal information, but it enables the deployment and management of various tracking and analytics tags from third-party services. When you visit our Website, Google Tag Manager may load and execute various tags that we have configured, which may include analytics, advertising, and other tracking technologies. These tags may collect information about your browsing behavior, device information, IP address, and other data as specified by the individual services deployed through Tag Manager. The specific data collected depends on which tags are active and their individual privacy settings. Google Tag Manager uses cookies to function properly and to enable the tags it manages. If you want to prevent Google Tag Manager from functioning on your device, you can disable JavaScript in your browser, though this may affect the functionality of our Website. For more information about Google Tag Manager, please visit: https://marketingplatform.google.com/about/tag-manager/. Google's privacy policy can be found here: https://policies.google.com/privacy.

    D. “Do Not Track” Signals

We do not currently honor “do not track” signals from a web site browser. Please refer to your computer browser help instructions for more information on cookies and other related technologies and how to manage their use.

6. Other Important Information.

A. Linked Websites

Our websites may contain links to other websites. We assume no responsibility for the content, privacy policies, or practices of any third-party websites.  You expressly relieve Company from any and all liability arising from your use of any third-party website, or from the content of any third-party website. 

B. Children's Privacy

Our website does not target or knowingly collect any information from individuals under age 18.

C. Changes to our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notification that the Privacy Policy has been updated on our website home pages. If we make material changes to how we treat the personal information we collect, we will notify you through a prominent notice on our website home pages, in addition to any other means necessary to fulfill our legal requirements. The date the Privacy Policy was last revised is identified at the top of the page. 

7. Contact Information.

For questions regarding this Privacy Policy, you may contact us at any of the following addresses:

Email: info@evagenomics.com

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

Phone: +1 734-596-3921