GENOMIC LIFE PRIVACY POLICY

Last Updated: June 2026

This Privacy Policy (this "Policy") describes how Genomic Life, Inc. ("we", "us", "our") collects, uses, discloses, and otherwise processes personal information pertaining to individuals who interact with us through our websites and other online and offline services ("Services").

This Privacy Policy does not apply where we process personal information on behalf of another business customer as a service provider, processor, business associate, or subcontractor business associate. In those circumstances, we process the information under our agreement with the business customer, including any applicable data processing agreement or business associate agreement. For example, where you access our Services through an Employer-Offered Benefit Membership (a membership made available to you by your employer), your employer may provide us with certain information (such as your name and eligibility status) to enable your access. Your employer's privacy notice governs that information passed to Genomic Life, not this Privacy Policy. This includes protected health information we process on behalf of a HIPAA covered entity, which is governed by HIPAA, the applicable business associate agreement, and the covered entity's notice of privacy practices.

If you provide us with personal information about another individual, such as if you invite or recommend someone for a Direct Membership (a membership that is available for purchase directly from Genomic Life), you must obtain their consent (or have the legal authority without consent) to share their personal information with us.

We may provide additional notices at the time when we collect or process personal information. For example, we may provide additional disclosures or seek consent in connection with certain features of our Services. Those notices supplement, and do not limit, this Privacy Policy.

We may update this Privacy Policy from time to time to reflect changes in our privacy practices. When we make changes, we will post the updated Privacy Policy on our website and update the "Last Updated" date at the top of this page. If we make material changes, we will also notify you directly and obtain your consent where required by law. We encourage you to review this Privacy Policy periodically.

Sources of Personal Information

We may collect personal information from the following categories of sources:

• Directly from you. We may collect personal information you provide through forms, purchases, account registration, customer service interactions, surveys, and other direct interactions with our Services.

• Automatically when you use our Services. We may collect personal information through observation of your actions on our websites through cookies, pixels, and similar technologies that record your browsing and interaction activity.

• From third-party sources. We may receive personal information from third parties, such as healthcare providers and care teams involved in your care or services; employers, plan sponsors, benefit administrators, or other organizations that make the Services available to you; other members or individuals who invite you to our Services; business partners and affiliates; and publicly available sources. Where required, we obtain your consent before receiving personal information from these sources.

• From Service Providers and Contractors. We may receive personal information from entities acting on our behalf that collect or generate personal information in the course of providing services to us.

Personal Information We Collect

We may collect the following categories of personal information:

• Identifiers, such as first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.

• Personal Records, such as signatures, physical characteristics or description, insurance policy number, employment or employment history, credit card number, debit card number, or other financial information.

• Protected Classification Characteristics, such as age, marital status, sex, and veteran or military status.

• Commercial Information, such as records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.

• Internet or Other Similar Network Activity, such as browsing history, search history, and information regarding your interaction with our websites, applications, or advertisements.

• Geolocation Data, we may collect approximate geolocation data, such as location inferred from IP addresses, billing addresses, or city and state information.

• Inferences Drawn from Other Personal Information. We may draw inferences from the information we collect to create a profile reflecting characteristics such as preferences, trends, predispositions, behavior, attitudes, and healthcare literacy.

• Sensitive Personal Information. If you sign up for an Employer-Offered Benefit Membership or a Direct Membership, we may also collect the following categories of sensitive personal information, such as:

  • Racial or ethnic origin

  • Genetic data

  • Health information

  • Mental or physical health condition or diagnosis

Where required by applicable law, we obtain consent before processing sensitive personal information, including before using sensitive personal information for any purpose that requires consent under applicable law.

How We Use Personal Information

We may use personal information for the following purposes:

• Providing and Improving Our Services, including to provide, personalize, and improve our products and Services, including to troubleshoot issues, perform data analysis, testing, and system maintenance, and to support our internal operations.

• Processing Transactions, including to process transactions and send related information, including purchase confirmations, invoices, and billing notices.

• Communications, including to send technical notices, updates, security alerts, support, and administrative messages. We may also send promotional communications, such as information about new Services, offers, promotions, rewards, contests, and upcoming events. You may opt out of promotional communications at any time by following the instructions in the communication or contacting us using the contact information in the Contact Us section below.

• Customer Support, including to respond to inquiries, comments, and requests, and to provide customer support, including through AI-supported tools.

• Research and Analytics, including to conduct research and analytics, including to monitor and analyze trends, usage, and activities in connection with our Services and to develop new products, Services, and features.

• Safety and Security, including to detect, investigate, and prevent security incidents, fraudulent transactions, and other illegal activities, and to protect the rights and property of our company and others.

• Personalization, including to understand individual preferences and to enhance and personalize experiences, including by delivering content and recommendations tailored to your interests.

• Advertising and Marketing, including to send marketing communications, such as information about our products, services, offers, promotions, newsletters, events, or other information that may be of interest. We may also use limited information about interactions with our websites and online Services, such as identifiers, device information, browsing activity, and related inferences, to measure the effectiveness of our outreach and advertising campaigns and understand engagement with our Services. You may opt out of promotional communications at any time by following the unsubscribe instructions in our messages or by contacting us as described below.

• Corporate Transactions, including to facilitate corporate transactions, such as mergers, acquisitions, financing, bankruptcy, dissolution, or the transfer, divestiture, or sale of all or a portion of our business or assets.

• Legal Compliance, including to comply with legal obligations, respond to legal processes, and cooperate with regulatory authorities.

• With Your Consent. We may use your personal information for other purposes with your consent or at your direction.

We may de-identify or aggregate personal information so that it can no longer reasonably be used to identify you. We may use, create, and disclose de-identified or aggregated information for any purpose permitted by applicable law, including research, analytics, and improving our Services. Where required by applicable law, we will maintain and use de-identified data only in de-identified form and will not attempt to re-identify it except as permitted by applicable law.

How We Disclose Personal Information

We may disclose personal information to third parties in the following circumstances, subject to applicable law, applicable contractual restrictions, and any consent or authorization required for the disclosure:

• Service Providers and Contractors. We may disclose personal information to companies that perform Services on our behalf, including cloud service providers, payment processors, customer relationship management providers, fulfillment partners, data analytics vendors, security vendors, and identity verification services. These parties process personal information only as directed by us and are subject to contractual obligations to maintain its confidentiality and security.

• Healthcare Providers, Laboratories, Pharmacies, and Other Care Participants. If you participate in an Employer-Offered Benefit Membership or a Direct Membership, we may disclose personal information to independent healthcare providers, genetic or genomic testing providers, and other care-related third parties as reasonably necessary to provide, coordinate, support, or facilitate the Services you request or receive.

• Plan Sponsors and Employers. If you participate in an Employer-Offered Benefit Membership, we may disclose limited personal information to your employer, plan sponsor, benefit administrator, or other sponsoring organization, separately from our role as a service provider or processor to that organization, as necessary to administer the program, process billing or payment, support program operations, report on program participation or utilization, or fulfill our contractual obligations.

• Advertising and Analytics Partners. We may disclose limited online interaction data, such as identifiers, device information, browsing activity, and related inferences, to data analytics companies and similar partners to measure campaign performance and understand engagement with our Services. This does not include genomic information, information about physical or mental health condition or diagnosis, or related information we collect from individuals who participate in an Employer-Offered Benefit Membership or a Direct Membership, which we do not use for advertising.

• Financial Services and Payment Processing. When you provide payment data, we may disclose payment and transactional information to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, and other related financial services.

• Government Agencies. We may disclose personal information to government agencies when required by law, in response to valid legal process, or to protect public safety.

• Corporate Transaction Parties. We may disclose personal information to potential acquirers, merger partners, or other parties in connection with a corporate transaction such as a merger, acquisition, financing, bankruptcy, dissolution, or sale of assets.

• With Your Consent. We may disclose personal information to other third parties with your consent or at your direction.

We do not share mobile numbers or text messaging opt-in data with affiliates or third parties for their own marketing or promotional purposes.

We do not sell, or license for monetary consideration any genomic information, information about physical or mental health condition or diagnosis, or related information we collect from individuals who participate in an Employer-Offered Benefit Membership or a Direct Membership.

Cookies and Tracking Technologies

We and our third-party partners may use cookies, pixel tags, web beacons, local storage objects, software development kits (SDKs), session replay tools, and similar technologies to collect information when you interact with our websites, applications, and online Services. These technologies help us operate our Services, understand how you use them, personalize your experience, and deliver relevant advertising.

Technologies We Use. The technologies we use serve a variety of purposes:

• Essential operations. Certain cookies and similar technologies are necessary for you to use features of our Services, such as accessing secure areas, processing transactions, and maintaining security. Without these technologies, certain services you request cannot be provided.

• Performance and analytics. We may use cookies and similar technologies to collect information about how visitors use our Services, including which pages are visited most often, how long visitors spend on a page, and whether visitors receive error messages. We may use this information to improve our Services, understand usage trends, and measure the effectiveness of our features.

• Functionality and personalization. Cookies and similar technologies allow our Services to remember choices you make, such as your language preference, region, or display settings, and provide enhanced, personalized features.

• Advertising and measurement. We may use cookies and similar technologies to measure the effectiveness of our outreach and engagement campaigns, understand engagement with our websites and online Services, and support marketing and analytics activities. These technologies may collect identifiers, device information, browsing activity, and related inferences about your interactions with our websites and online Services, which may reveal information about your interests in or use of particular Services.

Your Choices. You have choices regarding cookies and similar technologies. Please note that these choices are typically specific to the device or browser you are using, which means that if you access our Services from multiple devices or browsers, you may need to make your choices on each one separately.

• Browser settings. Most web browsers allow you to delete or reject cookies through your browser settings. If you choose to delete or reject cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. Certain features of our Services may not be available or fully functional if you disable cookies.

• Industry opt-out tools. You may opt out of targeted advertising from participating companies through the Digital Advertising Alliance (DAA) at optout.aboutads.info or the Network Advertising Initiative (NAI) at optout.networkadvertising.org. Please note that opting out through these tools does not prevent you from seeing advertising, it means the ads you see may be less relevant to your interests.

• Email web beacons. Most email clients allow you to prevent the automatic downloading of images, which prevents web beacons from automatically connecting to the web servers that host them.

Do Not Track. Some web browsers offer a "do not track" setting. We do not currently respond to web browser "do not track" signals.

Retention of Personal Information

We do not retain personal information for longer than is reasonably necessary for the purposes for which it was collected and processed, as disclosed in this policy, unless retention is otherwise required or permitted by law.

In determining how long to retain personal information, we consider the nature and sensitivity of the information, the purposes for processing, legal or regulatory requirements, operational needs, contract terms, and statute of limitations periods. When we no longer need your personal information, we will delete it or store it in an aggregated and de-identified format.

Security Measures to Protect Your Personal Information

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee the absolute security of your personal information.

Children

Our Services are for those 18 years or older, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information as quickly as possible. If you believe we may have collected information from a child under 18, please contact us using the information Contact Us section below.

Third-Party Links

Our Services may contain links to websites, applications, or Services operated by third parties. If you follow a link to any third-party service, please note that the third party's privacy policy, not ours, applies to any personal information you provide to them. We are not responsible for the privacy practices of any third party.

Contact Us

If you have any questions about this Privacy Policy or the personal information we collect or process about you, please contact us at: Navigation@genomiclife.com.

If you wish to reach us via mail, our postal address is:

4365 Executive Drive, Ste 715, San Diego, California 92121

U.S. State Privacy Law Supplement

Depending on where you reside and our processing activities, applicable law may provide you with certain rights regarding your personal information. This section describes those rights, how to exercise them, and additional disclosures required by law.

Some of the disclosures described above may constitute a "sale" or "sharing" of personal information as those terms are defined under applicable state privacy laws.

Your Privacy Rights

Under applicable law, you may have the following rights with respect to your personal information:

• Access and portability. You may confirm whether we process your personal information and request access to it, including the categories collected, the sources, the purposes of processing, the categories of third parties to whom it has been disclosed, and the specific pieces of personal information collected. You may also obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

• Delete. You may request that we delete the personal information we have collected about you, including personal information you have provided to us and personal information we have obtained about you from other sources. 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.

• Correct. You may request that we correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

• Opt out of Sale, Sharing, or Targeted Advertising. Website visitor information disclosed through certain third-party tracking technologies may be considered a "sale" or sharing to third parties for targeted advertising under applicable law. You may opt out of the processing of your personal information for such purposes, to the extent we engage in such processing. We do not sell or share for targeted advertising purposes genomic information, information about physical or mental health condition or diagnosis, or related information we collect from individuals who participate in an Employer-Offered Benefit Membership or a Direct Membership.

• Opt out of Profiling. You may opt out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, to the extent we engage in such processing.

Exercising Your Rights

We will not discriminate against you for exercising your privacy rights.

• Submitting Requests. You may submit a request to exercise your privacy rights by email to Navigation@genomiclife.com. Please include your full name, state of residence, and a description of the right(s) you wish to exercise.

You are not required to create a new account to exercise your rights, but we may require you to use an existing account for verification purposes.

Verification. When you submit a request to exercise your privacy rights, we may verify your identity before processing the request. Our verification process may involve matching information you provide against information we already maintain or requiring you to log in to your existing account. We will not require you to provide personal information beyond what is reasonably necessary to verify your identity.

Authorized Agents. You may designate an authorized agent to submit a request on your behalf. If you use an authorized agent, we may require you to provide the authorized agent with written permission and verify your identity directly with us. You may also designate an authorized agent through the use of technology, including a browser setting, browser extension, or global device setting, that indicates your intent to opt out of the sale of personal data or targeted advertising.

Appeal. If we decline to take action on your request, you may appeal our decision. We will provide instructions for how to submit an appeal with our response.

Additional State-Specific Disclosures

# California Residents

California "Shine the Light." California residents may request information about whether we have disclosed personal information subject to California Civil Code Section 1798.83 to third parties for their direct marketing purposes. To submit such a request, contact us at Navigation@genomiclife.com. We do not currently disclose information to third parties for their own direct marketing purposes.

# Connecticut Residents

Large Language Model Training. We do not collect, use, or sell personal information for the purpose of training large language models.

# Nevada Residents

Opt Out of Sales. Nevada residents may submit a verified request directing us not to sell your covered information for monetary consideration as defined under Nevada law by contacting us at Navigation@genomiclife.com. However, we do not sell covered information for monetary consideration.