This Privacy Policy (“Policy”) describes how Omega Genetics, Inc. (“Omega,” “we,” “us,” or “our”) collects, uses, shares, and safeguards information about you when you access or use our websites, mobile applications, digital platforms, or related services (collectively, the “Services”).

We are a health-technology company focused on providing longevity and wellness plans powered by genetics, laboratory results, biomarkers, and lifestyle questionnaires. Omega does not conduct medical tests itself; instead, we partner with independent, licensed laboratories and telehealth providers.

We are committed to handling your data responsibly, transparently, and in compliance with U.S., EU/UK, and California privacy laws.

1. Scope of this Policy

This Policy applies to:

• Visitors to our websites;
• Users of our mobile applications and digital tools;
• Individuals who register for accounts, join our waitlist, request investor access, or partner with us;
• Customers whose employers, brokers, or unions provide access to Omega’s Services as a benefit.

This Policy does not apply to third-party websites, apps, or services that link to or integrate with Omega.

2. Information We Collect

We collect several categories of information:

a) Personal Identifiers

• Name, email address, phone number, mailing address.
• Account credentials (username and password).

b) Health and Wellness Data (Provided by You)

• Responses to questionnaires on diet, exercise, sleep, lifestyle, and stress.
• Self-reported health goals and wellness preferences.
• Optional disclosures of past medical history (if voluntarily provided).

c) Laboratory and Genetic Data (Authorized by You)

• Laboratory results, biomarker values, and related metadata.
• Genetic testing results, uploaded files, or authorized reports.
• Test identifiers linked to your results.
• Data shared by telehealth providers (with your direction).

c-bis) Genetic Data — Additional Protections

• Separate express consent. Collection and use of genetic data requires your explicit, written consent, separate from general Terms of Service acceptance.
• No sharing with insurers or employers. Your genetic data will never be disclosed to insurance companies, employers, or government entities for eligibility, underwriting, or employment purposes.
• State-specific retention. Genetic data is retained for up to 36 months after account closure, consistent with applicable state genetic-privacy laws, unless you request earlier deletion.
• Right to sample destruction. You may request destruction of any biological sample and deletion of associated data at any time by contacting Email: contact@omegagenetics.ai.
• Applicable laws. We comply with the Genetic Information Nondiscrimination Act (GINA) and applicable state statutes, including the Florida Protecting DNA Privacy Act, Montana GIPA, California GIPA, and Washington genetic-privacy provisions.

⚠️ Note: Omega itself does not perform testing. All testing and clinical services are delivered by independent, licensed laboratories and telehealth providers.

d) Device and Usage Data

• IP address, device type, browser type, operating system, referral URLs.
• Usage activity: clicks, pages visited, session time, navigation patterns.
• Cookies, pixels, and similar tracking technologies.

d-bis)  'Genetic Data' covering:

• Separate express consent,
• Explicit ban on sharing with insurers/employer,
• State-specific retention periods,
• Right to request sample destruction,
• GINA and state-statute references.

e) Partner Data

• Information received from laboratories, telehealth groups, benefit brokers, or other business partners as necessary to provide Services.

3. How We Use Information

We use collected information to:

• Deliver Services. Provide personalized longevity scores, dashboards, and wellness plans.
• Account Administration. Manage user accounts, authenticate access, and provide support.
• Product Development. Improve algorithms, conduct research, and develop new features.
• Communication. Send updates, transactional notices, newsletters, and promotional offers (with consent).
• Compliance. Meet legal obligations, enforce contracts, and detect/prevent misuse.
• Analytics. Perform aggregated and de-identified analysis for scientific and commercial insights.

4. How We Share Information

We may share information only as follows:

• Service Providers. Vendors providing hosting, analytics, email/SMS, payment processing, and customer support.
• Testing and Telehealth Partners. Independent labs and clinicians, when you authorize services.
• Employers, Brokers, and Unions. Only aggregated/de-identified reports unless you explicitly consent to identifiable sharing.
• Legal Authorities. To comply with applicable law, regulation, subpoena, or protect rights and safety.
• Business Transactions. In connection with mergers, acquisitions, financing, or sales of assets, subject to confidentiality.

We do not sell personal data as defined by the California Consumer Privacy Act (CCPA/CPRA).

5. U.S. Users and HIPAA Adjacency

• Omega is not a “covered entity” under the Health Insurance Portability and Accountability Act (HIPAA).
• However, we voluntarily apply safeguards comparable to HIPAA standards.
• If you use labs or telehealth providers through Omega, those providers may be HIPAA-covered entities, and their privacy practices are governed by their Notice of Privacy Practices.

6. EU/UK Users (GDPR/UK GDPR)

If you reside in the European Economic Area (EEA) or the United Kingdom, Omega processes personal data under the following legal bases:

• Contractual necessity. To deliver the Services.
• Consent. For sensitive health/genetic data and marketing communications.
• Legitimate interests. For product improvement, analytics, and fraud prevention.
• Legal obligations. To comply with laws and regulations.
• You have the right to access, rectify, erase, restrict, or port your data, as well as the right to object to processing and withdraw consent at any time.

7. California Residents (CCPA/CPRA)

If you reside in California, you have the following rights:

• Right to know. What personal information we collect and how it’s used.
• Right to delete. Request deletion of personal information (with exceptions).
• Right to opt out. Object to “sale” or “sharing” of personal information (Omega does not sell personal data).
• Right to correct. Request correction of inaccurate personal information.
• Right to non-discrimination. You will not be penalized for exercising your rights.

Requests may be submitted to
contact@omegagenetics.ai.

8. Data Retention

• Personal identifiers: retained while active and up to 24 months after closure.
• Genetic data: up to 36 months after closure unless earlier deletion requested.
• Biomarker data: up to 60 months after closure for longitudinal tracking, subject to deletion request.
• Aggregated/de-identified (HIPAA Safe Harbor): may be retained indefinitely.

9. Data Security

We implement robust safeguards including:

• Encryption in transit (TLS) and at rest (AES-256).
• Role-based access controls.
• Secure hosting environments and regular audits.

⚠️ However, no method of storage or transmission is 100% secure.

9-bis Security Incident Notification

In the event of a security incident affecting your personal information, we will notify you and applicable regulators without undue delay and in accordance with state and federal data-breach laws, including New York's SHIELD Act.

10. International Transfers

If you access from outside the U.S., your data may be processed in the U.S. or other jurisdictions. Where legally required, we implement Standard Contractual Clauses (SCCs) or equivalent safeguards.

11. Children’s Privacy

The Services are not directed to individuals under 18. We do not knowingly collect children’s data.

12. Policy Changes

We may update this Policy periodically. Updates will be posted with a new “Effective Date.” Material changes will be communicated via email or in-app notification.

13. Contact Us

Omega Genetics, Inc.
41 Madison Avenue, 31st Floor
New York, NY 10010
Email: contact@omegagenetics.ai