Information That We Collect.

“Personal Information” is information that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with you or your household,
either alone or in combination with other information. We generally collect or receive information
through the Services from you in the following ways:

1. Information You Voluntarily Choose to Provide.
   a. Registration and Order Information: information provided when registering as Phenomics client
   and/or ordering our Services (e.g. name, date of birth, email address, postal address, telephone
   number, healthcare insurance information, payment
   information, etc.).
   b. Clinical Information: information regarding patient’s medication profile (e.g. prescription, over-the-counter, recreational, etc.) and genotype (e.g. specific location of nucleotides in your genome) generated by processing your plasma, serum, and/or buccal sample by Phenomics, our contractors, agents, or assignees; or otherwise contributed to Phenomics.
   c. Self-Reported Information: information provided when ordering our Services about patient’s disease conditions, personal traits (e.g. height, weight, age, ethnicity, etc.), family history, sociological factors and other information entered into surveys, physical or electronic forms, or features while signed in to your Phenomics account.
   d. User Content: all information, data, text, photographs, graphics, video, messages, or other materials, excluding Clinical Information and Self-Reported Information, produced by you and sent, whether publicly or privately, to Phenomics or using a Phenomics Site or Service.

2. Information Collected Automatically When You Use Our Services.
   We collect some information automatically when you use our Services. If a combination
   of information that we collect does identify you or your patient as an individual, we will treat
   the combined information as personal information.

We collect information automatically through technologies such as web browsers, cookies, log files, and web beacons. We use the information for purposes such as modifying or improving features, addressing technical issues, preventing fraud or misuse of our Services, and conducting data analytics. The type of information that we automatically collect may vary, but generally includes:

• a. Technical information about your computer, device, hardware, or software you use to access the Internet or our Services, such as IP address or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications);
• b. Usage information and statistics about your interaction with our websites and applications, which may include the URLs of our websites that you have visited, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, the application you used, how long you used the application and when, and other usage statistics;
• c. Information that facilitates a safer and more personalized experience, such as user identification provided in connection with your application use, saved preferences, and device identifiers or usage information for authentication and fraud prevention purposes;
• d. The real-time location of your device, if you agree to use your device settings.

We also may derive your general location from device information such as IP address. Our partner companies may access your information, such as your lab results. That data collection is subject to our partners’ privacy policies and the terms, conditions, and authorizations you complete and provide to us or our partners in order to use our Services.

Third-Party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Site, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information
they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use and Share Your Information.

As a general matter, we use your information to provide any Services or information you request,
including:

• To provide results of certain laboratory tests and genetic tests;
• To communicate with you, respond to your requests, or provide you with updates and information;
• To better understand our users, their interests, and their preferences;
• To personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;
• To develop, deliver, and improve our products, services, and other offerings;
• To connect you with our partners who provide aspects of our Services;
• To manage and customize advertisements or promotional offers;
• To comply with law enforcement and regulatory obligations;
• For security purposes;
• For internal purposes such as auditing, data analysis, and research with de-identified information.
• We will share information with service providers, consultants, contractors, agents, and third-party vendors that perform services on our behalf and under our instructions. These services providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share certain limited information, such as device identifiers, with advertisers and other marketing partners for purposes of gauging the effectiveness of advertising and other marketing strategies.
• We may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iii) if necessary to protect the vital interests of another individual (such as to prevent death, bodily harm, or serious damage to property). We may also provide your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

We will not give, sell, rent, loan, or otherwise disclose any identifiable Personal Information to any third party, unless permitted or otherwise authorized to do so.

Your Choices.

We provide you with choices about whether to provide us with personal information and whether it is shared. For example, you can choose not to give us the personal information we request, as described in the “Information You Voluntarily Choose to Provide” section of this policy. However, in some cases, if you decide not to provide the personal information we request, we will not be able to provide the application, service, or information you requested.

Other examples of your choices include:

• You can browse our website without registering or directly submitting any personal information to us. We may collect some limited information automatically, as described above.
• You can opt-out of receiving certain promotional or marketing communications from us at any time, by using the contacting us at support@phenomicshealth.com.
• You may change your browser settings or take other steps to block, manage, or delete cookies. Not all our Services currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause our websites and applications not to work as intended and some features may not be available.
• Phenomics will retain your Personal Information necessary to comply with legal requirements, including the federal Clinical Laboratory Improvement Amendments of 1988 (CLIA). Phenomics will also retain limited information related to your account and data deletion request, including, but not limited to, your email address, account deletion request identifier, and record of legal agreements for a limited period required by contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes.
• You may also exercise and amend your choices by sending an email to us as detailed in the “How to Contact Us” section below.

Security.

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, the alteration, access, disclosure, or use and other unlawful forms of processing. In some cases, your information is accessible when you log into a feature we offer and in those cases you need to keep your user credentials and password confidential and secure so that your information is protected.

Links to Other Websites and Services.

We are not responsible for the practices employed by websites or services linked to or from the Services, including the information or content contained therein. Please remember that when you use a link to go from our Website to another website, our Privacy Policy does not apply, and we do not have control over those third-party websites or services. Your browsing and interaction on any third-party website or service are subject to that third party’s rules and privacy policies.

Access and Correction.

We provide you with the ability to request access to and correction of your or your patient’s personal information. You can update your account information any time through our website. If you would like to request access to or a correction of your personal information, please submit your request by sending an email to the address specified in the “How to Contact Us” section below. Please include your name, email address, and postal address in your request, and describe specifically the information that you would like to access or correct so that we may respond appropriately and promptly.

Updates to Our Privacy Policy.

This policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this policy when this policy was last updated. Please review this policy every time you access or use our Services to make sure that you have reviewed the most recent version.

If You Live in California.

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write to us (see Contact Information below).

How to Contact Us.
If you have any questions or comments about this policy, if you need to report a problem, or if you would like to exercise one of your rights under this policy, please contact us at support@phenomicshealth.com or using the information below. Please include your name, contact information, and the nature of your request so that we can respond appropriately and promptly to
your communication.

Phenomics Health Inc.
46701 Commerce Center Drive Plymouth, MI 48170