By using our Services, you acknowledge that you have reviewed and agree to all of the policies and procedures described in the Privacy Statement.

Key Definitions

Aggregate Information: Information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.Anonymized Information: Information where identifying data such as your name, contact information, and other identifying data has been stripped, so that you cannot reasonably be identified as an individual.Individual-level Information: Information about an individual’s genotypes or other traits/characteristics, but which is not necessarily tied to Registration Information.Personal Information: Information that can be used to identify you.The following types of Personal Information are collected and stored by Prenetics:

Registration Information: Information you provide about yourself when registering for our Services (e.g. name, email, and address).

Genetic Information: Information regarding your genotype generated through the processing of your saliva by Prenetics, its successors, or assignees.

Self-Reported Information: Personal traits, ethnicity, health-related information, and other information entered about yourself into surveys, forms, or features while signed in to your Prenetics account.

Sensitive Information: Health Information, Genetic Information, Personal Information and certain Self Reported Information.

User Content: All data, information, software, photographs, graphics, messages, or other materials –

other than Genetic Information and Self-Reported Information – generated by users of Prenetics’ Services and transmitted to or through Prenetics.

Web Behavior Information: Information on how you use websites or mobile applications provided by Prenetics (e.g. browser type, domains, page views).

Service or Services: Prenetics’ products, software, services, and websites (including but not limited to text, graphics, images, and other material and information) as

accessed from time to time by the user, regardless if the use is in connection with an account or not.

Principles

Prenetics collects and handles information to: (i) comply with laws and regulations we are subject to, (ii) as we reasonably believe is permitted by laws and regulations, (iii) provide, analyze, and improve our Services, and (iv) to protect the security and safety of our company, employees, customers.The security and confidentiality of your personal information is a commitment we make to you. We never make any compromises which would put your information at risk. Our security measures in place protect against the loss, misuse or alteration of information under our control. We use procedural, physical, technical and electronic security methods designed to safeguard and to prevent people who aren’t authorized from getting access to this information.Your personal genetic information will never be disclosed, sold, or rented to a third party, even if the third party had provided the test to you.

What information we collect

Information you provide directly to us:Registration Information: When you register for or use our Services, we collect personal information, such as your name, date of birth, shipping address, and contact information such as your email and phone number.Self-Reported Information: You can optionally provide us with additional information regarding your traits such as height, weight, gender, ethnicity, and other health related information through applications, features, forms, etc.User Content: Some of our Services allow you to create and post or upload content, such as data, text, photographs, messages, or other materials that you create or provide to us through either a public or private transmission (“User Content”).Third-party services (e.g., social media): If you use a third-party site, such as Facebook, in connection with our Services, we may also collect other information (e.g. your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third-party site. We do not control third-party sites’ information practices; please review their privacy policies and your settings on those sites in detail.

Customer service: When you contact our Customer Care center or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Service, Privacy Statement or applicable laws or regulations; and analyze and improve our Services.

Information related to our genetic testing services:

Genetic Information: Genetic Information refers to features of your DNA that distinguish you from other people (e.g. the As, Ts, Cs, and Gs at particular locations in your DNA) and is generated when we process and analyze your saliva sample. Genetic Information includes the result information reported to you, by us and may be used for other purposes, as outlined in Section 4 below.

Information collected through tracking technology (e.g. from cookies and similar technologies)

Web Behavior Information: We use cookies and similar technologies to help us recognize you, customize and improve your experience, provide security, analyze usage of our Services, gather demographic information, to offer our products and services to you, to monitor the success of marketing programs, and to serve targeted advertising on our site and on other sites around the Internet. We do not use your sensitive information, such as Genetic Information and Self-Reported Information, for targeted advertising. We may receive reports based on the use of these technologies on an individual as well as aggregated basis. Users can control the use of cookies at the individual browser level. When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile applications (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.

How we use and share information

Prenetics will only use and share your personal information with third parties in the ways that are described in this privacy statement.

Using information to provide, analyze and improve our Services

We use the information described above in Section 3 to provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with other commitments in this Privacy Statement to: open your account, communicate with you, and implement your requests; host our websites, run our mobile applications, authenticate your visits, provide personalized content, and track your usage of our Services; conduct analytics to improve and enhance our Services; offer new products or services to you, including through emails, promotions or contests; implement online marketing campaigns and targeted advertising, including by utilizing third party ads (subject to your cookie settings and preferences), and to measure the effectiveness of our marketing and targeted advertising; conduct surveys or polls, and obtain testimonials; process and deliver your genetic testing results; perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities.You may be able to opt-in, opt-out or otherwise adjust your preferences of having your information used for certain of these activities. Please see below to learn more.We may share Aggregate Information with third parties, which is any information that has been stripped of your Registration Information (e.g. your name and contact information) and aggregated with information of others so that you cannot reasonably be identified as an individual. This Aggregate Information is different from “Individual-level” Information.

Prenetics will never share individual level information to any third-party, even if the third party had provided the test to you. Only you have the control and the consent to allow the sharing of your individual level information. Aggregate information such as “x% of our users share a genetic trait” may be shared, however, this information cannot identify individuals.

Disclosures required by law

Under certain circumstances your information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. Prenetics will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that Prenetics may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Prenetics Terms of Service and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Prenetics, its employees, its users, its clients, and the public.

Account closure

If you wish to stop participating in our Services or no longer wish to have your personal information be used, you may close your account by sending a request to Customer Care ([email protected]). All Genetic Information within your account (or profile) will be removed within thirty (30) days of receipt of your request. Backup copies may be retained for a limited time pursuant to our data protection policies. We may also retain limited Registration Information such as your name, contact, and transaction data, to provide you services, and for accounting, audit and compliance purposes.

Important Information

Security measures

Prenetics takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, Prenetics uses procedural, physical, technical and electronic security methods designed to safeguard your Personal Information. In particular, all connections to and from our websites and mobile applications are encrypted.Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third party and should immediately notify Prenetics of any unauthorized use of your password. Prenetics cannot secure Personal Information that you release on your own or that you request us to release.

Business transactions

If Prenetics goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of assets, and your information is amongst the assets transferred, your information would remain subject to the promises made in any pre-existing Privacy Statement.

Children’s privacy

Prenetics is committed to protecting the privacy of children as well as adults. Neither Prenetics nor any of its Services are designed for or directed toward children under the age of eighteen (18). A parent or guardian, however, may collect a DNA sample from, create an account for, and provide information related to, his or her child. The parent or guardian assumes full responsibility for ensuring that the information that he/she provides to Prenetics about his or her child is kept secure and that the information submitted is accurate.

Contact Information

Please direct all questions related to our privacy policy to: [email protected].

Any other information related to your genetic test or other matters may be obtained by contacting [email protected].