These "privacy summary" provide an overview of some key components of our data privacy and handling practices.

1. My1Lab provides information from several external sources, and allows user to review information anonymously.

2. We collect information when you register an account, self-report information through surveys, forms, features or applications, use our Services, upload your own content to our Services, use social media connections and features, refer your contacts to us, share information through various interactions with us and our partners, and via cookies and similar tracking technologies.

3. We use information in general (i) to provide, analyze and improve our Services, (ii) as we reasonably believe is permitted by laws and regulations, including for marketing and advertising purposes, (iii) to protect the security and safety of our company, employees, and customers as we reasonably believe is permitted by laws and regulations, (iv) to comply with laws and regulations we are subject to, and (v) when you consent, for research purposes, the results of which could be used to develop therapeutics.

CONSENT TO THE USE OF SENSITIVE INFORMATION

By agreeing to our Privacy Statement and Terms of Service, you consent to sensitive information, such as information about your health, Genetic Information, and Self-Reported Information such as racial and ethnic origin and sexual orientation (where you provide it) being used by us to:

1. analyze and provide you with our Services;
2. analyze and provide you with information about your ancestry;
3. determine whether you would be suitable to take part in surveys, polls or questionnaires that we are conducting; and
4. monitor and improve existing products or services that we offer or to develop new products and services

We will not use your sensitive information without your consent unless: (i) the information has been anonymized or aggregated so that you cannot reasonably be identified as an individual; or (ii) a legal obligation requires us to use it in some way e.g. a court order requires us to disclose the information.

CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION

1. By agreeing to our Privacy Statement and Terms of Service, you consent to the storing and processing of your personal information, including sensitive information, in the USA and countries outside of the country with our genomics partners such as laboratories. We use a range of measures to safeguard information but these countries may have laws that are different from those of your country of residence. You also consent to your personal information, including sensitive information, being transferred in the event of a business transition such as a partnership, merger, acquisition by another company, or other transaction or proceeding. In such a case, your information would be used as set out in any pre-existing Privacy Statement.


2. We will not sell, lease, or rent your individual-level information (i.e., information about a single individual's genotypes, diseases or other traits/characteristics) to any third-party or to a third-party for research purposes without your explicit consent.


3. We give you the ability to share information with other individuals through features like DNA Relatives. You will always need to take a positive action to share your information, for example, DNA Relatives is subject to an opt-in requirement before we share your information with potential relative matches.


4. You may independently decide to disclose your information to friends and/or family members, doctors, health care professionals, or other individuals outside our Services, including through third-party services such as social networks and third-party apps that connect to our website and mobile apps through our application programming interface ("API"); always review the privacy policies of third-party apps and services before sharing your information.


5. We may share anonymized and aggregate information with third-parties; anonymized and aggregate information is any information that has been stripped of your name and contact information and aggregated with information of others or anonymized so that you cannot reasonably be identified as an individual.


6. We will use your information and share it with third-parties for scientific research purposes only if you sign a Consent Document. Note that we will disclose your individual-level information only if we obtain additional explicit consent from you.


7. If you have any questions about our privacy practices, please email us at info@My1Lab.com or send a letter to the address provided at contact us page.

Full Privacy Statement

This privacy statement applies to all websites owned and operated by Phoenix Solutions, LLC as My1Lab.com ("My1Lab"), including www.My1Lab.com. Our Privacy Statement is designed to help you better understand how we collect, use, store, process, and transfer your information when operating our website, mobile apps, products, software and other services (collectively "Service" or "Services").

Contents

• Key Definitions
• Principles
• Type of information we collect
• How we use and share information
• Your choices
• Important Information
• Contact information

1. Key Definitions

1. 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.

2. Anonymized Information:
information that has been stripped of your Registration Information (e.g., your name and contact information) and other identifying data such that you cannot reasonably be identified as an individual.

3. Individual-level Information:
information about a single individual's genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.

4. Personal Information:
information that can be used to identify you, either alone or in combination with other information. My1Lab collects and stores the following types of Personal Information:

a. Registration Information:
information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, user ID and password, and payment information).
b. Genetic Information:
information regarding your genotype (e.g. the As, Ts, Cs, and Gs at particular locations in your genome), generated through processing of your saliva by My1Lab or by its partners, contractors, consultants, successors, or assignees; or otherwise processed by and/or contributed to My1Lab.
c. Self-Reported Information:
all information about yourself, including your disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your My1Lab account.
d. Sensitive Information:
information about your health, Genetic Information, and certain Self-Reported Information such as racial and ethnic origin and sexual orientation.
e. User Content:
all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials - other than Genetic Information and Self-Reported Information-generated by users of My1Lab Services and transmitted, whether publicly or privately, to or through My1Lab.
f. Web Behavior Information:
information on how you use the My1Labwebsite (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology.

5. Service or Services:
My1Lab’s products, software, services, and website (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.

2. Principles

The following are our core privacy principles:

1. We collect and handle information (i) to provide, analyze and improve our Services, (ii) as we reasonably believe is permitted by laws and regulations, including for marketing and advertising purposes, (iii) to protect the security and safety of our company, employees, customers, as we reasonably believe is permitted by laws and regulations, (iv) to comply with laws and regulations we are subject to, and (v) when you consent, for research purposes, the results of which could be used to develop therapeutics.

2. We will not sell, lease, or rent your individual-level information (i.e., information about a single individual's genotypes, diseases or other traits/characteristics) to any third-party or to a third-party for research purposes without your consent.

3. We understand and respect the sensitive nature of the information you may provide to us, including information about your genetic characteristics, disease conditions, racial and ethnic origin, etc. To that end, we strive to be transparent in our collection, use and disclosure of this information and to ask for your explicit consent to share such sensitive information with third-parties. Please see below to learn more about our sharing and consent practices.

4. We are committed to providing a secure and safe environment for our Services.

3. Type of information we collect

a. Information you provide directly to us

i.Registration Information.
When you register an account with us or purchase our Services, we collect personal information, such as your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information such as your email and phone number and license number.

ii.Self-Reported Information.
You have the option to provide us with additional information about yourself through surveys, forms, features or applications. For example, you may provide us with information about your personal traits (e.g., eye color, height), ethnicity, disease conditions (e.g. Type 2 Diabetes), other health-related information (e.g. pulse rate, cholesterol levels, visual acuity), and family history information (e.g. information similar to the foregoing about your family members). Where you are disclosing information about a family member, you should make sure that you have permission from the family member to do so.

iii.User Content.
Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission ("User Content"). For example, User Content includes any post or message you place on My1Lab's community forums.

iv.Blogs.
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request that we remove or anonymize your personal information from our blog or community forum, contact us at info@my1lab.com.

v.Social Media Features and Widgets.
Our website includes Social Media Features, such as the Facebook Like or Share button and Widgets, and the LinkedIn Open ID application ("Features"). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly.

vi.Third-party services (e.g., social media).
If you use a third-party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person's name and contact information, 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 site's information practices, so please review their privacy policies and your settings on those sites carefully.

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

b. Information related to our genetic testing services
.Saliva sample and bio-banking. To use our genetic testing services, you must purchase, or receive as a gift, a My1Labpartners testing kit, register an online account, and ship your saliva sample to our partner or third-party laboratory. Once received, your saliva sample will be identified by its unique barcode, along with your gender and your date of birth. The barcode label identifies you. Your saliva samples and DNA are destroyed after the laboratory completes its work, unless the laboratory's legal and regulatory requirements require it to maintain physical samples, or you have consented for research study.

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

Web Behavior Information. We and our third-party partners use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to help us recognize our user population, customize and improve your experience, provide security, analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service), gather demographic information about our user base, 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 and our third-party partners 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 by these companies on an individual as well as aggregated basis. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you, such as your user profile ID or order number. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.

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 application (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.

Google Analytics. Google Analytics is used to perform many of the tasks listed above. We use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions). We have enabled the following Google Analytics Advertising features: Remarketing, Google Display Network Impression Reporting,

d. Other Types of Information.
We are always working to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our privacy statement, as needed.

4. How we use and share information

My1Labwill use and share your personal information with third-parties only in the ways that are described in this privacy statement.

a. Using information to provide, analyze and improve our Services
We use the information described above in Section 3 to operate, 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:

i.open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);

ii. host our website, run our mobile application(s), authenticate your visits, provide custom, personalized content and information, and track your usage of our Services;

iii. conduct analytics to improve and enhance our Services;

iv. offer new products or services to you, including through emails, promotions or contests;

v. 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;

vi. conduct surveys or polls, and obtain testimonials;

vii. process and deliver your genetic testing results;

viii. 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 use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.

b. Using information with your consent
You have the choice to participate in My1Lab Research by providing your consent. "My1Lab Research" refers to research aimed at publication in peer-reviewed journals and other research funded by the federal government (such as the National Institutes of Health - NIH) participated, coordinated, contributed, or conducted by My1Lab. My1LabResearch may be sponsored by, conducted on behalf of, or in collaboration with third-parties, such as non-profit foundations, academic institutions or pharmaceutical companies.

Consent process for research.
Your Genetic and Self-Reported Information may be used for My1LabResearch only if you have consented to this use by completing a Consent Document. If you have completed a Consent Document:

1.My1Labmay use individual-level Genetic Information and Self-Reported Information internally at My1Labfor Research purposes. In addition, we may allow select third-party research contractors to access your individual level Genetic and/or Self-Reported Information onsite at My1Lab’s offices for the purpose of conducting scientific research, provided that all such research contractors will be supervised by our access rules and guidelines.

2.When your Genetic Information and/or Self-Reported Information is being used for research purposes, it will not be linked to your Registration Information.

i.Withdrawing your Consent.
You may withdraw your consent to participate in Research at any time by changing your consent status within your My1LabAccount Settings. If you experience difficulties changing your consent status, contact us at info@my1lab.com.

ii.What happens if you do NOT consent to My1Lab Research?
If you do not complete a Consent Document or any additional consent agreement with My1Lab, your information will not be used for Research.

c. Information we share with third-parties
. General service providers. We share the information described above in Section 3 with our service providers, as necessary to provide their services to us. Service providers are third-parties (other companies or individuals) that help us to provide, analyze and improve our Services. For example, we work with third-party laboratories and contractors to process and analyze your saliva sample for purposes of generating your Genetic Information.

i. "Targeted advertising" service providers. We permit third-party advertising networks and providers to collect Web Behavior Information on our Service to help us to deliver targeted online advertisements ("ads") to you. They use cookies and similar technologies (such as JavaScript, beacons, device identifiers, location data, and clear gifs) to compile information about your browser's or device's visits and usage patterns on our Services and on other websites over time, which helps to better personalize ads to match your interests, and to measure the effectiveness of ad campaigns.

ii. Aggregate information. 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 ("Aggregate Information"). This Aggregate Information is different from "individual-level" information. Individual-level Genetic Information or Self-Reported Information consists of data about a single individual's genotypes, diseases or other traits/characteristics information.

d. 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, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. My1Labwill 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 My1Labmay owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the My1LabTerms 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 My1Lab, its employees, its users, its clients, and the public.

5. Your choices

a. Access to your account
If your Registration Information changes, you may access, correct or update most of it from your Account Settings page. You may also modify and delete certain of your information, or update your consent status and biobanking options. You may be able to correct or reset Self-Reported Information entered into a survey, form, or feature from your account on the surveys. Please note that you may not be able to delete User Content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third-parties, though we can work with you to prohibit your data from being shared with third-parties in the future. We will respond to your request to access within 30 days.

b. Information you choose to share with others
My1Labgives you the ability to share information with other individuals who have My1Labaccounts through (i) our community forums, (ii) relative finding features (e.g., "DNA Relatives"), and (iii) other sharing features (such information is "User Content"). Please refer to your settings. You may be required to opt-in to some of this sharing, but some features require an opt-out.

6. Important Information

a. Security measures
My1Labtakes 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, My1Labuses a range of physical, technical, and administrative measures to safeguard your Personal Information. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.

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 My1Labof any unauthorized use of your password. My1Labcannot secure Personal Information that you release on your own or that you request us to release.

Your information collected through the Service may be stored and processed in the United States or any other country in which My1Labor its subsidiaries, affiliates or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.

b. Business transactions
In the event that My1Labgoes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.

c. Children's privacy
My1Labis committed to protecting the privacy of children as well as adults. Neither My1Labnor any of its Services are designed for, intended to attract, or directed toward children under the age of 13. A parent or guardian, however, may collect a saliva 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 My1Lababout his or her child is kept secure and that the information submitted is accurate.

d. Changes to this Privacy Statement
Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our customers' account login pages for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes prior to the change becoming effective.

7. Contact Information

If you have questions about this Privacy Statement, please email My1Lab's Privacy Administrator at info@my1lab.com, or send a letter to:

Privacy Administrator
My1Lab
12306 Cypress Spring Rd,
Clarksburg, MD - 20871

*This Privacy Statement was last updated on September 10, 2017.