Privacy Policy

    Effective June, 2025

    Introduction

    This Privacy Policy (“Privacy Policy”) describes how Unite Genomics, Inc., a Delaware corporation, and its affiliates (“Unite Genomics,” “we,” “us,” or “our”), collect, use, and disclose “personal information” in connection with our Website and Services (each as defined below). We collect information from the people who visit our website (collectively, “you,” “your”) with a homepage located at www.unitegenomics.com (the “Website”) or use our services related to the analysis of health and genomic data, including to create a user account (“Account”) with us (each, a “User”), and contact our Users’ health care providers and others to authorize the disclosure of their health information to researchers and others, and to view, change, and manage those authorizations and access requests (together the “Services”).

    Please read this Privacy Policy carefully to understand how we collect, process, share, or otherwise handle information that you and others provide us through our Website or our Services, as well as how you can control and manage the information Unite Genomics maintains about you through your Account (“Account Information”). This Privacy Policy is subject to Unite Genomics’ Terms of Use. The current version of the Terms of Use is available at www.unitegenomics.com/terms-of-use.

    Personal Information Collected

    "Personal information" is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual or household, which may include without limitation information about your physical or mental health or condition. "Personal information" we obtain includes information that Users provide to us; information that is provided to us by health care providers, researchers, and others who Users authorize to share information with us; and technical information collected by us and by third parties about Users’ and visitors’ use of our Website and Services.

    Information You Provide to Us

    We collect information about you that you provide to us, for example, by sending us a message or by contacting us directly. We also collect information from Users upon registering for an Account. To register for an Account, you must provide your name and email address and create a password. You may also choose to provide additional contact information, such as your address and phone number.

    We collect personal information from Users through their use of the Unite Genomics Patient Portal (“Patient Portal”). Through the Patient Portal, Users may submit their gender, age and birth date, weight, height, treatment and diagnosis information, health and well-being related information, and may complete a number of surveys that provide baseline, activity, lifestyle, health care, family history, nutrition habits, exposure to environmental risk factors, and related information to us. In addition, you may decide to share with us personal information from devices such as blood pressure monitors, glucose meters, and fitness tracker devices. We also collect cheek swab samples from Users that have received and returned our DNA kits, and process genomic information derived from those samples if that User’s genome is sequenced as part of a research study.

    Information Collected From Third Parties

    We collect personal information about Users when they authorize third parties to provide it to us. Through each User’s Account, a User may authorize health care providers, researchers, and others to share personal information about the User with us. This information typically includes measurements and assertions (lab data, device measurements, clinical assessment tool scores, etc.), diagnoses, conditions, problems, procedures, family history, detected issues (drug-drug interactions, duplicate therapies, etc.), imaging results (x-ray, CT, MRI, etc.), medications and administrations, questionnaire responses (social history, patient intake forms, research questionnaires and case report forms, etc.), records of samples taken, diagnostic reports, and allergies, and other information of this kind. We hold, use, and disclose this personal information subject to this Privacy Policy. In addition, we collect personal information from certain service providers we have engaged to provide services to us, which may include customer support services.

    Managing Provider Connections and Authorizations

    When you connect your account to a healthcare provider through Unite Genomics, you authorize us to retrieve your health records from that provider. You can revoke this authorization at any time by deleting the provider connection within your Unite Genomics account. When you do so, we will stop retrieving new information from that provider, and any previously retrieved data from that provider will be deleted from your account.

    If, for a connected provider in your account, you prefer to retain previously retrieved records in your account but wish to revoke your authorization for Unite Genomics to access or update your health data from that provider, you will need to do so through that provider’s patient portal or by contacting their health records office directly. Unite Genomics cannot revoke our own access to your records on your behalf. Revoking authorization through your provider will stop future data retrieval, but any previously retrieved information will remain in your account unless you choose to delete it.

    Technical Information Collected From Use of the Website and Services

    We and third parties automatically receive and store technical information whenever you interact with the Website, including information about your use of our Website such as the features of the Website that you use and how you use them, your Internet domain and IP address, type of browser and operating system, referring and exit pages, date and time of visit, and clickstream information. We automatically collect this information on your Website activity on our server logs. We may combine any information that we collect, including technical information, with the personal information that you choose to provide to us.

    We may also work with third parties that collect data about your use of the Site and other websites or apps over time for non-advertising purposes. Among these third parties, we may use Google to improve the performance of the Site and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit https://www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

    We do not permit third-party analytics providers to collect or access identifiable health data, and we limit their use to generalized traffic and usage metrics. If analytics are ever used on pages containing sensitive health information, they are gated by user consent or implemented with protections to ensure no health data is transmitted.

    We may use this information, alone or in combination with other personal information such as your email address, to provide personalized features and functionality, including for example to provide reminders and information about opportunities to share your information for research. We may also use this data to help us understand how you and other Users use parts of the Website and/or our Services so that we can improve them. We may disclose aggregated statistical information to third parties about how the Website and/or our Services are used.

    Cookies

    We use cookies and similar technologies to assist in collecting information about usage of the Website and to help us remember you and your preferences when you revisit the Website.

    Uses of Information

    We may use information we collect to:

    • Use automated systems to review your health data and identify potential gaps in care, based on publicly available clinical guidelines. When these systems detect potential opportunities for you to improve your care, we may send you informational messages encouraging you to speak with your healthcare provider. These messages are informational only and not medical advice. If you do not wish to receive care gap notifications or automated messages based on analysis of your health data, you may opt out at any time by contacting us at privacy@unitegenomics.com. Please note that opting out of these messages will not affect your participation in any research studies or other communications you have agreed to receive.

    • Deliver, administer and improve our Website and Services, including by providing certain of the personal information you provide (in some cases with certain identifying characteristics removed) to life sciences research organizations;

    • Communicate with you, answer your questions, and fulfill your requests;

    • Send you information and materials via mail and e-mail about offers, products, news, and/or research studies we think could interest you;

    • Provide customer service;

    • Improve and personalize your experience using the Website;

    • Better understand your needs;

    • Deliver announcements and updates about our Website and Services;

    • Contact you about any of the above as well as any changes to or notifications regarding your Account;

    • Comply with the law and to maintain the security of our Website or Services;

    • As otherwise disclosed at the time of collection or use; and/or

    • With your consent.

    Health Breach Notification

    If we experience a security breach involving your personal health data, and the breach meets applicable federal definitions, we will notify you as required by the Federal Trade Commission's Health Breach Notification Rule, including direct notification and public reporting if required.

    Information Sharing

    We may disclose your information in the following circumstances:

    • As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding.

    • Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required by law, or to protect our rights or the rights of third parties.

    • To comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our Terms of Use or other agreements, or where we deem necessary to protect our rights, property or safety or the rights, property or safety of our Users or others.

    • With service providers, including independent companies or other third parties and individuals to help us provide, facilitate or improve our Website and Services (such as customer service, support, or data hosting).

    • With your consent or as otherwise disclosed at the time of data collection or sharing.

    We may disclose aggregate, anonymous or statistical information without restriction.

    Sharing of Information

    When you create your Account, your settings will by default allow your de-identified information to be made available to researchers and/or organizations who partner with us. You may change this setting at any time through your account settings at portal.unitegenomics.com/account-settings. By making this data available, we hope to enable you to contribute to research advances and accelerate innovations in health care.

    We take measures designed to ensure that you will not be directly identifiable based on the de-identified information you may choose to make available. However, it may be possible for others to identify you if you have made your information available publicly in other ways; for example, if you post pictures or information to social media that describes you or your health condition, it may be possible for someone to correlate that with information in a Unite Genomics data set. De-identified information will be stored and made available without any of your personal Account Information.

    In addition, you may be asked when you create your Account, and from time to time after, to participate in, and/or to permit your information to be used in, academic, clinical, commercial or other research studies, either by Unite Genomics or by entities performing research. You are under no obligation to participate in any such research or permit your information to be used. If you do agree, you may be asked to authorize us and/or your health care provider or another party to provide information they have about you, including information that identifies you and relates to your past, present, or future physical or mental health or condition, or to provide a unique identifier that will allow the researcher or institution to link other personal information to the information that Unite Genomics maintains about you. Only you can agree to this linkage with other information or databases. We will not link the information in your Account for academic, clinical, commercial or other research studies without your authorization. If you agree to participate in a research study, the person or organization conducting the study may require you to sign a written consent to participate, which may include terms and conditions that are different from those of this Privacy Policy.

    In some cases, we may tokenize data from our platform and our research or commercial partners may use tokenized data we share with them to analyze patterns of care across the United States and understand how health trends relate to specific healthcare providers or organizations. While no personal identifiers are shared, these analyses may inform education activities targeted at providers who see patients with certain health characteristics. We do not share information that allows partners to identify individual patients.

    In limited cases, we may request your explicit, written consent or authorization to share your identifiable information with a specific third party that has partnered with us. This third party will be named in the request for your consent or authorization. Sharing of your identifiable information with the named third party will only occur for the listed purposes you approve via the consent or authorization. We will not share identifiable data with any partner without your express authorization.

    Opting Out of Sharing Your Information

    You may at any time request that Unite Genomics cease sharing your information with researchers and partners (e.g., academic institutions, life sciences companies, or public health collaborators). You may do this through the Patient Portal at portal.unitegenomics.com/account-settings. However, please note that any opt out is forward-looking, and will not remove previously shared information from the records of the parties to whom we have disclosed that information in accordance with this Privacy Policy or an authorization you have given to us.

    Exporting, Deleting, or Changing Your Information

    You can change the contact information you provided when you registered through your Patient Portal profile page at portal.unitegenomics.com/account-settings.

    Data Retention

    We retain your personal information for as long as your account is active or as needed to provide you with Services. If you terminate your account and request deletion, we will remove your personal information from our active systems. We may retain limited records for compliance, legal, or audit purposes in accordance with applicable law.

    Terminating Your Account

    You can terminate your Account at any time by emailing us at privacy@unitegenomics.com. Upon termination, we will delete your Account Information and other personal information. However, terminating your Account and deleting your personal information will not remove it from the records of the parties to whom we have disclosed that information in accordance with this Privacy Policy or an authorization you have given to us.

    Email Communications

    You can choose to stop receiving marketing or informational emails from us by clicking the “unsubscribe” link at the bottom of any such email. Please note, however, that you will continue to receive communications related to our transaction(s) and relationship with you.

    Practices of Third Parties

    Our Privacy Policy applies solely to how Unite Genomics and its affiliates collect and disclose your information. We do not control, and therefore are not responsible for, the privacy and security practices of third parties.

    Changes to Privacy Policy

    We may change this Privacy Policy at any time. We encourage you to revisit this Policy regularly to stay informed about how we collect, use, and share your information.

    State Privacy Rights

    Some states provide their residents with specific rights regarding their personal information, including the right to access, delete, or correct their information, or to opt out of certain data uses. While these laws may not currently apply to Unite Genomics, we aim to honor reasonable requests. Please contact privacy@unitegenomics.com to make such a request.

    Questions, Comments, and Suggestions about Privacy

    We welcome your questions and feedback about privacy. Please contact us at 510-408-6842 or via e-mail at privacy@unitegenomics.com.

    If you require this Privacy Policy in an alternative format due to a disability or accessibility needs, please contact us at privacy@unitegenomics.com.

    Terms of Use

    Effective June, 2025

    Unite Genomics, Inc., a Delaware corporation, and its affiliates (“Unite Genomics,” or “we” or “our”) operates this website at www.unitegenomics.com (“Website”) to provide online access to information about Unite Genomics and the services we provide (“Services”). Your access and use of this Website and our Services are subject to the following terms and conditions (“Terms of Use” or “Agreement”). Your use of the Website and/or our Services constitutes your acceptance of our Terms of Use and your agreement to comply with and be legally bound by them. Please read these Terms of Use in their entirety.

    This Terms of Use Agreement forms a legally binding agreement between you and Unite Genomics, and you should read it carefully. By downloading, accessing or using the Website or using the Services, you represent that you are at least eighteen (18) years old or the legal age of majority, whichever is greater, and you are agreeing to these Terms of Use.

    THIS AGREEMENT CONTAINS AN ARBITRATION AGREEMENT AND CLASS ACTION WAIVER THAT WAIVE YOUR RIGHT TO A COURT HEARING OR JURY TRIAL OR TO PARTICIPATE IN A CLASS ACTION. ARBITRATION IS MANDATORY AND IS THE EXCLUSIVE REMEDY FOR ANY AND ALL DISPUTES UNLESS SPECIFIED BELOW OR IF YOU OPT-OUT.

    Use of Website and Services

    You may not use any part of the Website or our Services for any purpose that is unlawful or that is prohibited by our Terms of Use. You may not use the Website or our Services in any manner that: (a) is false or misleading, such as using the Credentials of another person; (b) is defamatory, derogatory, degrading or harassing of another; (c) invades another’s privacy or improperly includes, copies, transmits, or authorizes the disclosure of another’s confidential, sensitive or personal information; (d) may restrict or inhibit another’s use or enjoyment of the Website or our Services; (e) could interfere with or disable, overburden, damage, or impair the Website or our Services; (f) monitor or copy any material on the Website for any unauthorized purpose; (g) violates or infringes another’s rights; (h) you do not have the right and authority to share and grant the necessary rights and licenses for; (i) violates any applicable laws or regulations; or (j) limits or harms the functionality of Unite Genomics’ or any other person’s computer systems.

    Your Account

    To use our Services, you must create an account (“Account”) and keep the information in your Account (“Account Information”) accurate, complete, and up-to-date. You may create an Account at portal.unitegenomics.com/create-account and view your Account Information and make any necessary changes at any time at portal.unitegenomics.com/account-settings. In order to create your Account, you may be required to provide certain registration, identification, authentication details and other information. Your Account Information includes a user name, password, and certain other information used as a part of our security procedures (“Credentials”). You must keep your Credentials confidential and not disclose your Credentials to others. Your Account is personal to you. By creating your Account, you accept responsibility for all activities that occur under your Credentials. You must notify Unite Genomics immediately of any unauthorized access to, use or disclosure of your user name, password, or other Credentials, or of any security violation or breach of our Website’s security of which you become aware.

    We have the right to disable any Account, user name, password, or other Credentials at any time that we determine, in our sole discretion, that you have violated any provision of our Terms of Use or that the security of the Website or Services requires us to do so.

    Automated Features and Health Data Use

    Unite Genomics may use automated systems to analyze your health data and identify potential gaps in care based on publicly available clinical guidelines. These systems may trigger messages that provide information or reminders intended to help you discuss your care with your provider. These messages are informational only and do not constitute medical advice or clinical diagnosis.

    Privacy Policy

    By using the Website, you are agreeing to Unite Genomics’ Privacy Policy, which is incorporated herein by reference.

    Except for information that you submit through the use of the Unite Genomics Patient Portal (“Patient Portal”) and your Credentials, you should not send any confidential or proprietary information to Unite Genomics. Any information you submit other than through the Patient Portal, including but not limited to questions, comments, or suggestions, shall be deemed to be non-confidential and shall become the property of Unite Genomics. By providing that non-confidential information to us, you grant Unite Genomics an unrestricted, irrevocable license to use, reproduce, display, perform, modify, transmit, and distribute that non-confidential information. Unite Genomics shall be free to use any ideas, concepts, know-how or techniques contained in that non-confidential information for any purpose whatsoever, including but not limited to developing, manufacturing, and marketing products incorporating that non-confidential information. You further represent that by providing non-confidential information to us, you have the rights to grant the license described above.

    Your Account Information, and the information we receive from you through the Patient Portal, and any other information created or collected by Unite Genomics through this Website or any of our Services, will be subject to our Privacy Policy.

    Data Retention

    We retain your information for as long as your account is active or as needed to provide you with Services. If you terminate your account and request deletion, we will remove your personal information from our active systems. We may retain limited records for compliance, legal, or audit purposes in accordance with applicable law.

    Limitation of Use

    You may not use the Website or Services to make medical decisions or as a substitute for consultation with a qualified healthcare provider. Messages or content from Unite Genomics are informational and should not be considered medical advice or a replacement for professional medical consultation.

    Copyright and Other Rights

    Unite Genomics or its suppliers of Content own all copyrights to Content on the Website and all other intellectual property rights related to the Website and our Services. You may copy Content on the Website solely for your own, non-commercial use in connection with your use of Unite Genomics’ Services. No other copying of Content is permitted. You agree that any copies of the Content shall retain all copyright and other proprietary notices in the same form and manner as the original.

    Trademarks

    The trademarks, logos, service marks, brand identities, title, characters, trade names, graphics, designs, and other properties (collectively the “Trademarks”) displayed on the Website are protected intellectual properties that are registered and unregistered trademarks of Unite Genomics, its affiliates and others. Nothing that appears on the Website should be construed as granting, by implication, or otherwise, any license or right to use any Trademark displayed on the Website without the express, written permission of Unite Genomics or the party that may own that Trademark. Your misuse of the Trademarks is strictly prohibited.

    Electronic Communications

    By using the Website or sending email to us, you agree and consent to receive communications from us electronically, including by email or by posting notices on this Website. You acknowledge that your electronic submission constitutes your agreement and intent to be bound by the terms of this Agreement. Pursuant to any applicable statutes, regulations, rules, ordinances or other laws, including without limitation the United States Electronic Signatures in Global and National Commerce Act, P.L. 106-229 (the “E-Sign Act”) or other similar statutes, YOU HEREBY AGREE TO THE USE OF ELECTRONIC SIGNATURES, CONTRACTS, ORDERS AND OTHER RECORDS AND TO ELECTRONIC DELIVERY OF NOTICES, POLICIES AND RECORDS OF TRANSACTIONS INITIATED OR COMPLETED THROUGH THE WEBSITE OR SERVICES OFFERED BY UNITE GENOMICS. Further, you hereby waive any rights or requirements under any statutes, regulations, rules, ordinances or other laws in any jurisdiction which require an original signature or delivery or retention of non-electronic records, or to payments or the granting of credits by other than electronic means.

    Disclaimer of Warranties

    WE MAKE NO REPRESENTATIONS OR WARRANTIES OF ANY KIND THAT EXTEND BEYOND THE DESCRIPTION ON THE FACE OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, UNITE GENOMICS MAKES NO IMPLIED WARRANTIES, REPRESENTATIONS OR ENDORSEMENTS WHATSOEVER WITH RESPECT TO THE WEBSITE, THE SERVICES, OR THE CONTENT. UNITE GENOMICS DOES NOT WARRANT THAT THE FUNCTIONS PERFORMED BY THE WEBSITE WILL BE UNINTERRUPTED, TIMELY, SECURE OR ERROR-FREE, OR THAT DEFECTS IN THE WEBSITE WILL BE CORRECTED. UNITE GENOMICS DOES NOT WARRANT THE ACCURACY OR COMPLETENESS OF THE CONTENT, OR THAT ANY ERRORS IN THE CONTENT WILL BE CORRECTED. THE WEBSITE, THE SERVICES, AND THE CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. NOTWITHSTANDING ANYTHING TO THE CONTRARY HEREIN, THIS DISCLAIMER OF WARRANTIES DOES NOT APPLY IN NEW JERSEY.

    Limitation of Liability

    IN NO EVENT WILL UNITE GENOMICS BE LIABLE FOR ANY DIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY OR OTHER INDIRECT DAMAGES ARISING OUT OF (I) THE USE OF OR INABILITY TO USE THE WEBSITE, THE SERVICES, OR THE CONTENT, (II) ANY TRANSACTION CONDUCTED THROUGH OR FACILITATED BY THE WEBSITE; (III) ANY CLAIM ATTRIBUTABLE TO ERRORS, OMISSIONS, OR OTHER INACCURACIES IN THE WEBSITE, THE SERVICES AND/OR THE CONTENT, (IV) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA, OR (V) ANY OTHER MATTER RELATING TO THE WEBSITE, THE SERVICES, OR THE CONTENT, EVEN IF UNITE GENOMICS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IF YOU ARE DISSATISFIED WITH THE WEBSITE, THE SERVICES, THE CONTENT, OR WITH THE TERMS OF USE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO TERMINATE YOUR ACCOUNT AND DISCONTINUE USING THE WEBSITE AND THE SERVICES.

    SOME STATES, INCLUDING NEW JERSEY, DO NOT ALLOW THE EXCLUSION OR LIMITATION OF LIABILITY FOR CONSEQUENTIAL OR INCIDENTAL DAMAGES, AND SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY IN THOSE STATES.

    Digital Millennium Copyright Act

    Unite Genomics complies with U.S. copyright law and to responding to claims of copyright infringement. We will promptly process and investigate notices of alleged infringement and will take appropriate actions under the Digital Millennium Copyright Act, Title 17, United States Code, Section 512(c) (“DMCA”).

    If you believe that any materials on the Website have been used or copied in a way that infringes your copyright or other intellectual property rights, you may request that Unite Genomics remove those materials by providing us with the following information:

    • An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright or other intellectual property interest;
    • A description of the copyrighted work or other intellectual property that you claim has been infringed;
    • A description of where the material that you claim is infringing is located on the website (including the specific URL of each item in dispute, which should help us to locate the relevant content);
    • Your address, telephone number, and email address;
    • A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; and
    • A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright or intellectual property owner or are authorized to act on the copyright or intellectual property owner’s behalf.

    Designated Agent

    Notice of claims of copyright or other intellectual property infringement can be delivered as follows, by email, fax or standard mail:

    Taner Dagdelen

    3 East Third Avenue, Suite 200 - #105

    San Mateo, CA 94401

    Phone: (510) 408-6842

    Email: dmca@unitegenomics.com

    Notice for California Users

    Under California Civil Code Section 1789.3, users of the Website from California are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210. Unite Genomics may be contacted in writing at 3 East Third Avenue, Suite 200 - #105, San Mateo, CA 94401 or by telephone at (510) 408-6842.