Effective Date: November 18, 2025Entity: Personomics LLC ("Personomics," "we," "us," or "our")Services: The Personomics platform, websites, member portals, apps, coaching programs, integrative lab services, and related services (collectively, the "Service").

Contact: [email protected]

This Privacy Policy explains how Personomics, LLC ("Personomics," "we," "us," or "our") collects, uses, shares, and protects your personal information when you:

Visit our website at personomics.io or any site that links to this Privacy Policy (the "Site")

Use our mobile or tablet applications (the "Apps")

Access our assessments, courses, memberships, coaching programs, integrative health lab services, and related online services (collectively, the "Services")

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not consent to the terms of this Privacy Policy, permission to use the Services is denied and you must cease using the Services immediately.

Note on HIPAA: Where applicable, your health information is also protected under our HIPAA Notice of Privacy Practices, available at personomics.io/hipaa-consent. In the event of any conflict between this Privacy Policy and our HIPAA Notice, the HIPAA Notice governs with respect to Protected Health Information (PHI).

1. Scope

This Privacy Policy applies to personal information we collect:

Directly from you through the Services

Automatically when you use or interact with the Services

From certain third parties (e.g., payment processors, scheduling tools, lab partners, marketing platforms)

This Privacy Policy does not apply to third-party websites, apps, or services that may be linked to or integrated with our Services. Please review the privacy policies of those third parties separately.

If you are a resident of a jurisdiction with specific privacy or consumer health data laws, additional terms may apply. Please see our Consumer Health Data Privacy Policy at personomics.io/consumer-health-data-privacy for more information.

Geographic Restrictions: Lab services offered through Personomics are subject to geographic restrictions. Lab testing is not available to residents of New York State (permanently prohibited by state law) or Washington State (currently suspended). Internationally, lab services are available only to residents of Australia, Canada, New Zealand, and the United Kingdom. These restrictions are determined by our lab partner EquiLife and applicable law.

2. Information We Collect

We may collect the following categories of information, depending on how you use the Services:

2.1 Information You Provide Directly

Account & Contact Information

Name, email address, phone number

Mailing address and country/region

Order & Transaction Information

Billing address and shipping address

Limited order details (products or services purchased, purchase amount, order date)

Payment-related information (processed via our third-party payment processors; we do not store full credit card numbers)

Coaching & Program Information (When You Voluntarily Provide It)

Information you choose to provide in questionnaires, intake forms, or communications related to coaching or assessments (e.g., health goals, lifestyle patterns, symptom history, preferences)

Scheduling preferences and notes related to your sessions or program participation

Communications

Messages and emails you send to us (e.g., support requests, feedback, testimonials)

Responses to surveys, polls, or promotions

Marketing Preferences

Your choices regarding email subscriptions, SMS opt-ins, and other communication preferences

2.2 Health & Wellness Data

Because Personomics provides health coaching and facilitates integrative lab testing, we may collect the following categories of health and wellness information, which may constitute Protected Health Information (PHI) under HIPAA or Consumer Health Data under applicable state laws:

Lab results and biomarker data: Results from integrative health lab tests facilitated through Personomics and our lab partner EquiLife, which may include information about hormone balance, metabolic health, inflammation markers, nutrient levels, and other biomarkers

Specimen and sample information: Information related to your biological sample collection and processing (e.g., sample type, collection date, registered kit information)

Health history and intake information: Health background, current symptoms, medications, supplements, and other health-related information you voluntarily provide during onboarding or coaching sessions

Wellness and lifestyle data: Information about your activity levels, sleep, stress, diet, and other lifestyle factors you choose to share with your coach or through our platform

Health goals and program notes: Notes and records created by your Personomics health coach in connection with your coaching program

This information is handled with the highest level of care and in accordance with our HIPAA Notice of Privacy Practices (personomics.io/hipaa-consent) and, where applicable, our Consumer Health Data Privacy Policy (personomics.io/consumer-health-data-privacy).

2.3 Information We Collect Automatically

When you access or use the Services, we may automatically collect certain information about your device and usage, such as:

IP address

Browser type and version

Device type, operating system, and unique device identifiers

Referring URLs and exit pages

Pages viewed, links clicked, and other actions taken on the Site

Dates and times of access

We may use cookies, web beacons, pixels, and similar technologies to collect this information (see Section 5 – Cookies & Similar Technologies).

2.4 Information from Third Parties

We may receive personal information from third parties, including:

Lab partners: EquiLife and their accredited third-party laboratory providers (e.g., kit registration, sample status, test results)

Payment processors: Confirmation of payment status and transaction details

Scheduling platforms: Appointment time, name, and email

Email and marketing platforms: Engagement metrics, unsubscribe data

Analytics providers: Aggregate visitor statistics

Affiliate or advertising partners: Information about how you arrived at our Site

2.5 Information from Connected Devices & Third-Party Health Apps

With your explicit permission, we may receive information from third-party accounts, services, or devices you choose to connect to our Services, such as:

Wearable devices (e.g., smartwatches, fitness trackers)

Health and fitness tracking apps (e.g., Apple Health, Google Fit, Oura)

Other connected health platforms

The use of your data by any connected third-party service is governed by that service's own privacy policy. We recommend reviewing those policies before connecting any third-party accounts.

3. How We Use Your Information

We may use your personal information for the following purposes:

3.1 To Provide and Maintain the Services

Processing and fulfilling orders, including lab kit orders

Managing your account and login

Providing access to coaching programs, assessments, and lab services

Coordinating lab ordering, specimen processing, and results delivery with EquiLife and their lab partners

Scheduling and managing coaching appointments

Responding to your inquiries, requests, and support tickets

3.2 To Improve and Personalize the Services

Analyzing usage patterns to understand how the Services are used

Improving content, coaching programs, user experience, and features

Personalizing content, health recommendations, and offers based on your profile and program

3.3 To Communicate with You

Sending transactional emails (e.g., order confirmations, account notices, lab kit status, appointment reminders)

Sending program-related communications and resources

Delivering newsletters, updates, or marketing communications (where permitted by law and your preferences)

Sending SMS/text messages, if you have opted in

You may opt out of marketing communications at any time (see Section 9 – Your Choices & Rights). Transactional or service-related messages may still be sent even if you opt out of marketing.

3.4 For Research and Development

We may use de-identified and aggregated data — from which all personally identifying information has been removed — for the following purposes:

Improving our coaching programs and health education content

Analyzing health and wellness trends across our member population

Developing new features, programs, or services

Where permitted by applicable law, facilitating or contributing to peer-reviewed health research

We will never use your individually identifiable health information for research purposes without your explicit written consent.

3.5 AI-Powered Tools & Features

We may use AI-powered tools to support the delivery of our Services, including but not limited to:

AI-assisted coaching support or recommendations within our platform

AI-enabled customer support or helpdesk tools that analyze your communications to help us respond more efficiently

Automated health insight generation based on your lab results and program data

Any AI tools we use are subject to our data processing agreements and are prohibited from using your personal information for purposes beyond supporting the delivery of our Services. Your health and wellness data is never used to train third-party AI models without your explicit consent.

3.6 To Support Safety, Security & Legal Compliance

Detecting, preventing, and responding to fraud, abuse, or security incidents

Enforcing our Terms of Service and other policies

Complying with applicable legal obligations, including HIPAA, and responding to lawful requests from authorities

3.7 With Your Consent

In some cases, we may ask for your explicit consent to use your information for a specific purpose. If you provide consent, you can withdraw it at any time by contacting us (see Section 13 – Contact Us).

4. Legal Bases for Processing (EU/UK/EEA Residents)

If you are located in the European Economic Area (EEA), the United Kingdom (UK), or a similar jurisdiction, we will process your personal information only where we have a lawful basis to do so, such as:

Contract performance (e.g., to provide the Services you requested)

Legitimate interests (e.g., improving Services, preventing fraud, sending certain helpful non-marketing communications, where not overridden by your rights)

Consent (e.g., certain marketing communications or cookies)

Legal obligations (e.g., record-keeping for tax, compliance, or HIPAA purposes)

You have specific rights under GDPR/UK GDPR (see Section 9.3).

5. Cookies & Similar Technologies

We and our service providers may use cookies, pixels, and similar technologies to:

Recognize your browser or device

Remember your preferences

Analyze traffic and usage

Measure the effectiveness of content and marketing

You may control cookies through your browser settings and, where available, through cookie banners or preference tools on the Site. Disabling certain cookies may affect functionality or performance of the Services.

6. How We Share Your Information

We do not sell your personal information.

We may share your information in the following ways:

6.1 Lab Partners

We share relevant personal and health information with our lab partner EquiLife and their accredited third-party laboratory providers for the purpose of processing your lab orders, analyzing your samples, and delivering your results. This sharing is necessary to provide the lab services you have requested and is governed by our HIPAA Notice of Privacy Practices and applicable Business Associate Agreements.

6.2 Service Providers

We may share your information with trusted third-party vendors who perform services on our behalf, such as:

Payment processing

Order fulfillment and shipping

Email, SMS, and marketing automation

Scheduling and calendar management

Website hosting and security

Data analytics and performance monitoring

Customer support platforms and AI-enabled helpdesk tools

These service providers are authorized to use your personal information only as necessary to provide services to us and are required to protect your information.

6.3 Coaches and Program Facilitators

If you enroll in a coaching or program experience that involves a Personomics coach or designated facilitator, we may share relevant information you voluntarily provide (such as your name, contact information, health intake data, and lab results) with that coach or facilitator to assist with the delivery of the service. Coaches and facilitators are required to follow our policies and applicable laws in handling your information.

6.4 Business Transfers

If Personomics undergoes a business transaction such as a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will take reasonable steps to ensure the recipient uses your information in a manner consistent with this Privacy Policy.

6.5 Legal & Safety Requirements

We may disclose your information if we believe in good faith that such disclosure is reasonably necessary to:

Comply with a law, regulation, or legal request

Protect the rights, property, or safety of Personomics, our users, or the public

Enforce our Terms of Service or other agreements

Detect, prevent, or address fraud, security issues, or technical problems

7. Consumer Health Data

Personomics collects and processes information that may constitute "consumer health data" as defined under applicable U.S. state laws, including but not limited to Washington's My Health, My Data Act, the Colorado Privacy Act, and the Connecticut Data Privacy Act.

Note on Geographic Restrictions: As stated in Section 1, lab services are currently not available to residents of New York State (permanently) or Washington State (temporarily suspended). If you are a Washington State resident, please note that while you may access coaching services, lab services are currently unavailable to you.

For full details on how we handle consumer health data and your rights under applicable state laws, please see our Consumer Health Data Privacy Policy at personomics.io/consumer-health-data-privacy.

8. Data Retention

We retain personal information for as long as reasonably necessary to:

Provide the Services

Fulfill the purposes described in this Privacy Policy

Comply with legal, tax, HIPAA, and accounting obligations

Resolve disputes and enforce our agreements

Health and wellness data, including lab results and coaching records, may be retained for a longer period where required by applicable law or professional standards. When we no longer need your information, we will either delete it, anonymize it, or securely store it until deletion is possible.

9. Your Choices & Rights

9.1 Email & SMS Communications

Email: You can unsubscribe from marketing emails at any time by clicking the "unsubscribe" link at the bottom of our emails or by contacting us directly at [email protected].

SMS/Text Messages: You can opt out of marketing texts by replying STOP to any message or following instructions in the message. Even if you opt out of marketing SMS, we may still send transactional or service-related messages (e.g., appointment reminders, lab kit status updates) where necessary.

9.2 Cookie Preferences

You can typically adjust your browser settings to refuse or delete cookies. You may also see a cookie banner on our Site that allows you to manage certain preferences. Note that disabling cookies may impact the usability of some features.

9.3 Rights for EU/UK/EEA Residents

If you are located in the EEA or UK, you may have the following rights (subject to certain exceptions and limitations):

Right of access – Request a copy of the personal data we hold about you

Right to rectification – Request correction of inaccurate or incomplete data

Right to erasure – Request deletion of your data in certain circumstances

Right to restrict processing – Request that we limit how we use your data

Right to data portability – Request a copy of your data in a structured, machine-readable format

Right to object – Object to certain processing, including direct marketing

Right to withdraw consent – Withdraw consent where processing is based on your consent

To exercise these rights, contact us at [email protected]. We may need to verify your identity before responding.

9.4 Rights for U.S. State Residents (e.g., CA, CO, VA, CT)

If you are a resident of certain U.S. states with privacy laws, you may have additional rights, such as:

The right to know what categories of personal information we collect and disclose

The right to access or request deletion of certain personal information

The right to opt out of certain types of data sharing or targeted advertising

The right to correct inaccurate personal information

The right to non-discrimination for exercising your privacy rights

We will honor valid requests in accordance with applicable law. To submit a request, please contact us at [email protected]. We may ask you to verify your identity before fulfilling your request.

9.5 Rights Regarding Health Information

For rights specifically related to your Protected Health Information (PHI) — including lab results, coaching records, and health intake data — please refer to our HIPAA Notice of Privacy Practices at personomics.io/hipaa-consent, which describes your full rights under HIPAA including rights to access, amendment, accounting of disclosures, and restrictions.

10. Data Security

We use reasonable technical and organizational measures to protect personal information against loss, misuse, unauthorized access, disclosure, alteration, and destruction. These measures include encryption, secure data centers, access controls, and regular security reviews.

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security and you use the Services at your own risk.

If we become aware of a data breach that affects your personal information or PHI, we will take steps required by applicable law — including HIPAA breach notification requirements — which may include notifying you and/or regulators within the timeframes required by law. See our HIPAA Notice of Privacy Practices for full breach notification details.

11. Children's Privacy

The Services are not offered to children under 16 years of age, and our policy is to bar the collection of personal information from children under 16 without appropriate parental or guardian consent.

If we discover that we have collected personal information from a child under 16 without appropriate consent, we will take reasonable steps to delete such information. If you believe a child under 16 has provided us personal information, please contact us at [email protected].

12. International Data Transfers

Personomics is based in the United States. If you access the Services from outside the U.S., your information may be transferred to, stored, and processed in the United States or other countries where our service providers are located.

By using the Services, you acknowledge that your information may be subject to different data protection rules than in your country of residence. Where required, we will implement appropriate safeguards (such as standard contractual clauses) to protect your information when it is transferred internationally.

Reminder: International lab services are available only to residents of Australia, Canada, New Zealand, and the United Kingdom. See Section 1 for full geographic restrictions.

13. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or your personal information, you can contact us at:

Email: [email protected]

Website: personomics.io/privacypolicy

If you are in the EEA/UK, you may also have the right to lodge a complaint with your local data protection authority.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Effective Date" at the top of this page and, where required, provide additional notice (such as via email or a notice on the Site).

Your continued use of the Services after any changes become effective signifies your acceptance of the updated Privacy Policy.

Personomics LLC • [email protected] • personomics.io