Profile Health, Inc.
Effective Date: September 9, 2026

Privacy Highlights

The full policy follows. This summary is not a substitute for it, but these are the points that matter most.

We never sell your genetic data, and we never give it to anyone outside Profile Health.

No licensing, no research partners, no pharmaceutical companies, no data brokers, no insurers, no employers, no advertisers. The only outside parties who touch it are the sequencing laboratory and our infrastructure vendors, under contract, for us.

Research and AI training are opt‑in and separate.

Accepting our Terms of Service does not permit either. A separate consent does, and you can decline it and still get your full results.

You can revoke, and we act within 30 days.

Revoking stops future use. It cannot reverse research already completed or remove your data's influence from a model already trained — see Section 8.4, which explains this honestly.

We require a warrant.

We do not voluntarily give genetic data to law enforcement. See Section 12.

We do not store your biological sample.

The laboratory destroys it after sequencing. We never hold it.

Minors are handled differently.

Different consent, different retention limits, different reporting. See Section 13.

We will not broaden your terms retroactively.

If we want a new use, we ask you again. See Section 17.

Bankruptcy or sale of the company will not transfer your genetic data without your consent.

See Section 11.

1. Scope, and Which Rules Apply to Your Information

1.1 This policy describes how Profile Health, Inc. ("Profile Health," "we," "us") collects, uses, discloses, retains, and deletes information about patients of the Profile Health genomic analysis service (the "Service").

1.2 Two legal capacities. Because we sell through clinicians, we may hold information about you in either of two capacities, and the rules differ:

(a) As a HIPAA business associate of your clinician. Where your clinician is a HIPAA covered entity and we process protected health information ("PHI") on their behalf, that information is governed by HIPAA, by our business associate agreement with your clinician, and by our Notice of Privacy Practices — not primarily by this policy. Your rights of access, amendment, and accounting for that information run in the first instance through your clinician.

(b) Under our direct relationship with you. Information you provide to us directly, information in your Profile Health account, and information we hold under your own consent rather than your clinician's instruction, is governed by this policy and by applicable state law.

1.3 Why this matters to you. These two bodies of information may be about the same test. We maintain records of which capacity applies to which information, and when you make a privacy request we will tell you which rules govern your request and, where the request must be routed through your clinician, help you do that. If you are ever unsure, write to support@profilehealth.com and we will explain in plain language which category your information sits in.

1.4 Geography. The Service is offered only in the United States. This policy is written for U.S. residents.

2. Definitions

Aggregate Information — information combined with that of other people and analyzed as a whole, such that no individual can reasonably be identified.

Biological Sample — the physical specimen you provide. We never hold it; see Section 6.

De‑identified Data — information from which direct identifiers have been removed and which we maintain, and contractually require others to maintain, in de‑identified form, with no attempt at re‑identification. See Section 8.5 for an important and candid limitation on what "de‑identified" can mean for genomic data.

Derived Data — outputs computed from your Genetic Data, including variant calls, risk scores, and interpretive classifications. Derived Data is treated as sensitive, exactly as Genetic Data is.

Genetic Data — any data resulting from analysis of your Biological Sample, including raw sequence data (FASTQ), aligned reads (BAM/CRAM), variant calls (VCF), and Derived Data.

Individual‑Level Data — data about one person's genotypes, traits, or conditions, whether or not linked to your name.

Registration Information — name, date of birth, contact details, account credentials, payment information, and the identity of your ordering clinician.

Self‑Reported Information — health history, family history, medications, traits, and survey responses you or an authorized third party provide.

Sensitive Information — Genetic Data, Derived Data, Self‑Reported Information about health, and any information revealing a health condition. All of it is treated as sensitive under this policy regardless of whether a particular state statute classifies it that way.

3. Information We Collect

3.1 From you.

• Registration Information, including date of birth (which determines your eligibility, your reporting rules, and which legal protections apply to you)

• The Tube ID linking you to your Kit

• Self‑Reported Information

• Account settings, consent elections, and communications with our support team

3.2 From your clinician. The order, clinical context supplied with it, and where applicable information from your medical record that your clinician transmits to us.

3.3 From the laboratory. Raw Sequence Data and quality control metrics.

3.4 Generated by us. Variant calls, polygenic risk scores, pharmacogenomic classifications, interpretive text, quality metrics, and audit logs.

3.5 Automatically. Device and browser type, IP address, pages viewed, and interaction events, collected through log files and limited first‑party analytics.

3.6 What we do not collect.

• We do not use third‑party advertising trackers, advertising pixels, or session‑replay tools anywhere on authenticated pages of the Service, or on any page where health or genetic information is displayed or entered.

• We do not purchase personal information about you from data brokers.

• We do not collect precise geolocation.

3.7 Cookies. We use strictly necessary cookies for authentication and security, and limited first‑party analytics. Our cookie notice is at https://www.profilehealth.com/legal/cookies. We honor Global Privacy Control and other recognized universal opt‑out signals.

4. How We Use Information — Uses Permitted by the Terms of Service

The uses in this Section are the ones necessary to deliver the Service you purchased. They are permitted by your acceptance of the Terms of Service.

(a) Delivering your analysis — coordinating with the laboratory, running our pipelines, generating and delivering Reports to you and your clinician. (b) Your account — authentication, giving you access to your results, acting on sharing you authorize, and support. (c) Communications about your test — status, results availability, replacement kits, and material reclassifications affecting a finding previously reported to you. (d) Quality control — verifying that the analysis you received was performed correctly, and investigating suspected errors. (e) Security and fraud prevention. (f) Legal compliance and enforcement of our Terms. (g) Payment processing.

We do not treat "product improvement" as falling within this Section. Improving our pipelines, developing new features, and training models are uses beyond delivering your analysis, and we ask separately for them. See Section 5.

5. Uses That Require Your Separate Consent

The following require your specific, separate, revocable permission under the Research & Data Use Consent. They are presented to you together, as one optional election covering all four, on a screen of their own after you have already accepted the Terms of Service. Granting it permits all four; declining permits none of them. Your access to the Service and your Reports does not depend on granting it, and your price is the same either way.

If you want to permit some of these and not others, write to us at support@profilehealth.com and we will record a limited permission and confirm it to you in writing.

5.1 Product improvement. Using your de‑identified Genetic Data and Self‑Reported Information to improve the accuracy of our pipelines, variant classification, and interpretive content — beyond the quality control in Section 4(d).

5.2 Extended retention. Retaining your raw Sequence Data beyond the period needed to deliver and support your Reports, so that it remains available for the uses you have permitted.

5.3 Model training. Using your de‑identified Genetic Data and Self‑Reported Information to develop, train, validate, and evaluate machine‑learning models, including models relating genotype to phenotype. See Section 8.4 for what revocation can and cannot undo.

5.4 Research and publication. Using your de‑identified data in research intended to contribute to generalizable knowledge, including research we may publish.

5.5 What we will never ask for. We will not ask for, and will not accept, consent to:

• transfer, license, or otherwise disclose your Genetic Data or Derived Data to any third party for that party's own use — including research partners, universities, pharmaceutical or biotechnology companies, and data brokers. De‑identified data derived from your genome is used inside Profile Health only. We have chosen not to build a data‑licensing business, and there is no consent on offer that would permit one;

• disclose your Genetic Data or Derived Data to any health, life, disability, or long‑term care insurer, or to your employer;

• sell your Genetic Data or Derived Data under any definition of "sell"; or

• use your Genetic Data for advertising or marketing targeted at you or anyone else.

5.6 If that ever changes. If Profile Health were ever to reconsider, we could not apply a new policy to data you have already given us. We would have to come to you, name the specific recipient, describe exactly what they would receive and what they could do with it, and ask you then — one recipient at a time. Several states require that a consent to transfer genetic data name the recipient, so a blanket advance permission is not something we could obtain even if we wanted it. Declining would cost you nothing.

6. Your Biological Sample

The laboratory destroys your Biological Sample after sequencing and quality control. Profile Health never receives, holds, stores, or banks your Biological Sample. Because we retain no sample, we do not seek consent to sample storage. You may request confirmation of destruction, or destruction before sequencing, at support@profilehealth.com; where state law sets a deadline for honoring such a request, we meet it.

7. Who We Share Information With

7.1 Service providers. We use vendors who process information on our behalf under written contracts that limit them to our instructions, prohibit any independent use, require security controls, and require deletion or return on termination:

Function

Who

What they receive

Sequencing laboratory

Novogene Corporation Inc.

Biological Sample, Tube ID, minimum necessary identifiers

Cloud infrastructure and storage

Google Cloud Platform (United States regions)

Encrypted Genetic Data and account data

Payment processing

See subprocessor list

Billing information only — never Genetic Data

Shipping and logistics

See subprocessor list

Name and address only

Email and notification delivery

See subprocessor list

Name, email, non‑health message content

Only two outside companies ever handle your genetic data: Novogene, which sequences your sample, and Google Cloud, which stores it encrypted. Neither may use it for anything of their own. Everything else we do with your data — analysis, interpretation, reporting, support — we do ourselves, on our own systems.

The current list, with contact details and locations, is maintained at https://www.profilehealth.com/legal/subprocessors.

7.2 Your clinician. Reports and, where relevant, quality information, in accordance with the order.

7.3 People you choose. Anyone you authorize us to share with. Grants are revocable going forward, but we cannot retrieve what has already been viewed, downloaded, or copied.

7.4 Legal process. As described in Section 12.

7.5 Corporate transactions. As described in Section 11 — with the specific protections stated there.

7.6 What we never do.

• We never transfer or license your Genetic Data or Derived Data to any third party for that party's own use — not to research partners, universities, pharmaceutical or biotechnology companies, or data brokers, and not in de‑identified form. Every use of de‑identified data derived from your genome happens inside Profile Health.

• We never sell your Genetic Data or Derived Data, under any definition of "sell," including exchange for any valuable consideration.

• We never share Genetic Data or Derived Data with insurers, employers, advertisers, data brokers, or advertising networks.

• We never allow a service provider to use your information for its own purposes.

• We never voluntarily provide genetic data to law enforcement.

7.7 Offshore access. Genetic data is subject to the U.S. Department of Justice rule on bulk sensitive personal data (28 C.F.R. Part 202), which applies whether or not the data is de‑identified. We do not store Genetic Data outside the United States, and we do not permit access to Genetic Data by any person or entity in a country of concern designated under that rule. Our vendor and personnel arrangements are assessed against it.

8. Retention, Deletion, and What Revocation Can and Cannot Undo

8.1 Retention. We hold information for these periods:

Information

Retention

Reports and variant calls

While your account is open, so you can access your results

Raw Sequence Data (FASTQ)

While your account is open and you have granted extended‑retention consent under Section 5.2; otherwise deleted 12 months after Reports are delivered

Registration Information

While your account is open, then 24 months for dispute and legal purposes

Consent records and version history

10 years after the consent ends — we must be able to prove what you agreed to and when

Audit and security logs

6 years, matching the HIPAA documentation retention period

Payment records

As required by tax and financial law

8.2 Deletion. You may request deletion at any time by writing to support@profilehealth.com. We will:

• delete your Genetic Data, Derived Data, Reports, and Self‑Reported Information from production systems within 30 days;

• purge backups on our ordinary backup cycle, not exceeding 90 days, during which the data is inaccessible except for disaster recovery;

• instruct any service provider holding your data to delete it, and confirm they have; and

• confirm completion to you in writing.

8.3 What we keep after deletion, and why. A minimal record of the fact of your account, your deletion request, and your consent history — retained so that we can honor your deletion, prove we honored it, and avoid re‑enrolling you in anything. This record contains no Genetic Data.

8.4 Model training and irreversibility — please read this.

If you have consented to model training and later revoke:

• We will stop using your data in any future training, immediately.

• We will remove your data from the training corpus.

• We will delete your data as described above.

But we want to be straightforward with you about something the industry is often vague about: a model that has already been trained on data retains a statistical influence from that data, and there is no reliable technical method to fully remove it. We cannot promise to "untrain" a model. What we can and do promise:

(a) we will not train new models on your data after revocation; (b) we will not retrain existing models on your data; (c) we will not use any model to produce output about you specifically; and (d) we will tell you which models, if any, were trained on data including yours, if you ask.

This is the single most important thing to understand before granting model‑training consent. It is why we ask for it separately, and why it is genuinely optional.

8.5 What "de‑identified" honestly means for genomic data.

We remove your name, contact details, and other direct identifiers before using data for any permitted secondary purpose, and we contractually bind any recipient not to attempt re‑identification.

We are not going to tell you this makes the data anonymous. A whole genome is, by its nature, unique to you. Published research has repeatedly shown that genomic data can be re‑identified by matching against public genealogy databases, and that this works even for people who never took a genetic test, through their relatives. De‑identification meaningfully reduces risk. It does not eliminate it. Anyone who tells you genomic data can be fully anonymized is overstating the science.

8.6 Aggregate data. Aggregate statistics that describe groups and cannot be traced to any individual are not subject to the deletion right, because they contain no individual data.

9. Your Rights

Rights vary by state, and Section 14 sets out state‑specific detail. As a matter of policy, we extend the following to every patient regardless of where you live:

• Access — get a copy of the information we hold about you, including your raw Sequence Data

• Portability — receive it in a structured, machine‑readable format

• Correction — correct inaccurate Registration or Self‑Reported Information

• Deletion — as described in Section 8.2

• Revoke consent — withdraw any Research & Data Use Consent, in whole or in part, at any time

• Know recipients — a list of every third party your information has been disclosed to

• Opt out of marketing — at any time

• Non‑retaliation — we will never degrade your Service, change your price, or withhold results because you exercised a right

How to exercise. Write to support@profilehealth.com or call 802-318-6017. We respond within 45 days, extendable once by 45 days with notice. We verify your identity proportionately to the sensitivity of the request; for Genetic Data we require reasonable verification. Authorized agents may act for you with written permission and verification of your identity.

Appeals. If we decline a request, we will tell you why and how to appeal. Appeals are reviewed by someone not involved in the original decision, within 45 days. If we deny an appeal, we will give you the contact details of your state attorney general.

Revocation is easy. Revoking consent is at least as simple as granting it. One message to support@profilehealth.com is enough. We do not ask why, we do not offer you anything to stay, and we do not add steps.

10. Security

• Encryption in transit (TLS 1.3) and at rest (AES‑256)

• Genetic Data stored separately from Registration Information, linked by a rotating internal identifier

• Role‑based access, least privilege, and logging of every access to Genetic Data

• Multi‑factor authentication required for all personnel and available to all patients

• Annual third‑party penetration testing and security assessment

• Written incident response plan, tested annually

• Vendor security review before onboarding and on renewal

• Background checks and confidentiality obligations for personnel with data access

Breach notification. If your information is involved in a breach, we will notify you without unreasonable delay and in any event within 60 days of discovery, and we will notify regulators as required. We will tell you what happened, what information was involved, what we are doing, and what you can do.

No guarantee. No system is perfectly secure. We cannot guarantee the security of information transmitted to us, and we encourage you to use a strong unique password and enable multi‑factor authentication.

11. Corporate Transactions, Bankruptcy, and What Happens to Your Data

We are writing this section deliberately and specifically, because recent events in this industry showed that vague language here fails patients when it matters most.

11.1 Our commitment. In any merger, acquisition, reorganization, financing, sale of assets, receivership, assignment for the benefit of creditors, or bankruptcy proceeding:

(a) Your Genetic Data and Derived Data will not be transferred to any acquirer or successor unless that party agrees in writing to be bound by this Privacy Policy and by your existing consent elections, as they stood at the time you gave them.

(b) We will notify you before any such transfer takes effect, by email, with enough time to delete your data first if you choose. Where a transfer is compelled on a timeline that makes advance notice impossible, we will notify you as soon as we lawfully can.

(c) You may delete your data at any point before, during, or after such a process, and we will honor that deletion.

(d) We will not seek, and will oppose, any court order or transaction structure that would permit transfer of Genetic Data free of these commitments.

(e) A successor may not broaden the permitted uses of your data. If a successor wants a new use, it must ask you for a new consent, exactly as we would.

11.2 Why we are promising this. Under U.S. bankruptcy law, a sale of personally identifiable information is measured against the privacy policy in force when the data was collected. This section is that policy. We intend it to be enforceable against us and against anyone who acquires us.

12. Law Enforcement and Legal Process

12.1 We require valid legal process. We do not voluntarily disclose Genetic Data or Derived Data to law enforcement. We require a search warrant issued on probable cause for Genetic Data, and valid legal process for other categories.

12.2 We resist overbroad demands. We review every request, object to requests that are overbroad, unduly burdensome, vague, or legally defective, and require them to be narrowed or withdrawn. We will litigate where we believe a demand is unlawful.

12.3 We do not participate in familial or investigative genetic genealogy searching. Our database is not available for law enforcement searching of any kind, and we do not upload, permit uploading of, or otherwise make our data available to genealogy matching services.

12.4 We notify you. We tell you about legal process directed at your information before we respond, unless we are legally prohibited. Where we are prohibited, we seek to lift the prohibition and notify you as soon as we can.

12.5 Transparency report. We publish a report at least annually at https://www.profilehealth.com/legal/transparency stating the number of requests received, by type, the number we complied with in whole or in part, the number we resisted, and the number of individuals affected.

12.6 Other disclosures required by law. We may disclose information where required to prevent imminent serious physical harm, to comply with a lawful court order, or as otherwise required by law. We interpret these narrowly.

13. Minors

13.1 Who consents. For patients under 18, a parent or legal guardian accepts the Terms and gives any Research & Data Use Consent, and a patient aged 13 or older must also give assent. Our consent flow uses verifiable parental consent methods for patients under 13.

13.2 State variation in who controls. Some states — Colorado among them — treat a person aged 13 to 17 as the party whose consent is required for secondary uses, extended retention, profiling, and sale of their data, rather than the parent. We do not need to resolve who holds that right, because we do not ask for it while the patient is a minor: the Research & Data Use Consent is not offered for patients under 18, to a parent or to the minor. See Section 13.4.

13.3 Retention limits for minors. For any patient who was under 18 at the time of testing:

(a) we do not retain data indefinitely; (b) raw Sequence Data is retained for one purpose only — so that the patient's own genome can be re-run as new genes and findings are added, without another sample — and is deleted 90 days after the patient reaches the age of majority unless the patient, now an adult, has consented for themselves; (c) for patients under 13, we maintain a written retention schedule with a specific deletion date for each category, in accordance with the federal Children's Online Privacy Protection Act, which prohibits indefinite retention of children's personal information.

13.4 Model training and research.

Data from patients who were minors when tested is not used to improve our analysis, is not used to train models, and is not included in research datasets — unless and until that patient reaches the age of majority and consents for themselves. The Research & Data Use Consent is not presented during a pediatric registration at all, and there is no version of it a parent can sign.

We made this choice deliberately. A parent can consent to a test. We do not think a parent can meaningfully consent, on a child's behalf, to that child's genome permanently shaping a commercial model the child will never be able to withdraw from. If the patient, as an adult, wants to grant that permission, we will ask them then.

13.5 Re‑consent at the age of majority. When a patient reaches the age of majority, we contact them (and, before that date, the parent) to explain that:

• the account becomes theirs;

• parental access ends unless they choose to continue it;

• any permissions their parent gave lapse and will not be relied on;

• they may elect to release any findings withheld under Section 8.5 of the Terms, after being offered genetic counseling; and

• they may delete everything.

If we cannot reach them, permissions lapse and the retention limit in 13.3(b) applies.

13.6 Withheld findings. Findings withheld under Section 8.5 of the Terms are stored in a sealed record inaccessible to the patient, the parent, the clinician, and to our own analytical systems, and are released only on the adult patient's own election.

13.7 No profiling or targeted advertising. We do not use minors' data for targeted advertising, for profiling that produces legal or similarly significant effects, or for any sale — irrespective of consent.

14. State‑Specific Rights and Disclosures

14.1 All states. The rights in Section 9 are extended to every patient as a matter of policy, regardless of whether your state requires them.

14.2 California.

Genetic Information Privacy Act (Civ. Code §§ 56.18–56.186). Where GIPA applies to us, we obtain your separate express consent for each of: (i) the collection, use, and disclosure of your genetic data; (ii) storage of your biological sample beyond the initial test — not applicable, as we retain no sample; (iii) each use beyond the primary purpose of the test; (iv) each transfer or disclosure to a third party other than a service provider — not applicable, as we make none; and (v) any marketing based on your genetic data — not applicable, as we do none. We honor revocation within 30 days.

CCPA/CPRA. You have rights to know, delete, correct, opt out of sale or sharing (we do neither), and limit use of sensitive personal information. We do not use sensitive personal information for any purpose other than those permitted without a limitation right, plus the purposes you have separately consented to. We honor Global Privacy Control. We have not sold or shared personal information in the preceding 12 months, and have not sold or shared the personal information of consumers under 16.

CalGINA. California extends genetic nondiscrimination protection beyond federal law to life, disability, and long‑term care insurance, housing, mortgage lending, education, and emergency services.

Shine the Light (Civ. Code § 1798.83). We do not disclose personal information to third parties for their direct marketing purposes.

14.3 Washington — My Health My Data Act. Genetic data is consumer health data under this Act. Our separate Consumer Health Data Privacy Notice is at https://www.profilehealth.com/legal/consumer-health-data. You may access your consumer health data, obtain a list of all third parties to whom it has been disclosed with contact information, withdraw consent, and require deletion. We do not sell consumer health data, and accordingly we do not seek the signed valid authorization the Act requires for a sale. We do not operate geofences around healthcare facilities.

14.4 Nevada (SB 370). You may access a list of third parties to whom your health data has been disclosed, opt out of sale (we do not sell), and require deletion. We do not geofence healthcare facilities.

14.5 Maryland (MODPA). Maryland restricts processing of sensitive data — which includes genetic data — to what is strictly necessary to provide the product or service you requested, regardless of consent, and prohibits the sale of sensitive data outright, even with consent. Accordingly, for Maryland residents: we do not use genetic data for model training, research, product improvement, or any third‑party transfer, and we do not offer the Research & Data Use Consent. Maryland residents receive the full Service; their data is used only to deliver it.

14.6 Illinois. Under the Genetic Information Privacy Act (410 ILCS 513), genetic testing information is confidential and privileged, and is released only to you, your legal representative, or a person you have specifically authorized in writing. Illinois provides a private right of action. From January 1, 2027, the Act extends expressly to biomarker testing including genome sequencing. For Illinois residents, every disclosure and every secondary use rests on a specific written authorization identifying the recipient and the purpose.

14.7 Texas. Texas recognizes an exclusive property right in your DNA (Bus. & Com. Code ch. 503A) and requires separate express consent for third‑party transfer, use beyond the primary purpose, sample retention, and marketing. Under the Texas Genomic Act (HB 130) we do not store Texas residents' genomic data outside the United States, do not permit access from a foreign adversary jurisdiction, do not use sequencers or sequencing software produced by or on behalf of a foreign adversary, and file the annual compliance certification the Act requires.

14.8 Other genetic privacy statutes. Arizona, Florida, Utah, Wyoming, Kentucky, Montana, Tennessee, Virginia, Nebraska, Indiana, South Dakota, Connecticut, Vermont, and Rhode Island have enacted genetic privacy statutes with separate‑consent, deletion, destruction, and insurer/employer disclosure provisions. Our consent architecture is designed to the strictest of these, and we apply it nationally rather than varying it by state, except where a state's law requires something we cannot apply nationally, as in Maryland.

14.9 Montana, Wyoming, Kentucky, Tennessee, Texas, Indiana. These states require valid legal process — in Montana, a warrant — before genetic data is disclosed to government. Our policy in Section 12 meets or exceeds each.

14.10 Colorado, Connecticut, Montana, Oregon, and other states with minors' provisions. See Section 13.

14.11 Universal opt‑out mechanisms. We honor Global Privacy Control and other recognized universal opt‑out signals in every state, whether or not required.

14.12 Nevada Revised Statutes 603A. Nevada residents may submit a verified request that we not sell covered information. We do not sell it.

14.13 Do Not Track. Browsers send inconsistent Do Not Track signals and there is no common standard. We do not respond to DNT, but we honor Global Privacy Control, and we do not engage in the cross‑site tracking DNT was designed to address.

15. Consumer Health Data Privacy Notice

This Section is published separately at https://www.profilehealth.com/legal/consumer-health-data and linked from our homepage, as Washington and Nevada require.

Categories collected: genetic data, including raw sequence data and derived variant and risk information; self‑reported health, family history, and medication information; the fact of your purchase of a genetic testing service; and information inferred from these.

Sources: you; your clinician; the sequencing laboratory; our own analysis.

Purposes: delivering your analysis; supporting your account; quality control; security; legal compliance — and, only where you have separately consented, product improvement, retention, research, and model training.

Who we share with: the sequencing laboratory; cloud infrastructure providers; your clinician; and people you authorize. No one else — we do not transfer or license consumer health data to third parties for their own use. A current list with contact information is at https://www.profilehealth.com/legal/subprocessors.

We do not sell consumer health data.

Your rights: confirm whether we process your data and access it; obtain a list of all third parties to whom it has been shared, with contact details; withdraw consent; and delete your data. Contact support@profilehealth.com. Appeal a denial as described in Section 9.

16. Notice of Financial Incentive

We do not offer financial incentives, discounts, or price differences in exchange for your consent to research, model training, or any data use. Your price is the same whatever you consent to.

17. Changes to This Policy

17.1 We will post any updated policy with a new effective date and version number, and notify you by email at least 30 days before material changes take effect.

17.2 No retroactive expansion. We will not apply broadened data‑use, sharing, retention, licensing, or model‑training terms to data collected under narrower prior terms. If we want a new use for data you have already given us, we will ask you specifically. Declining costs you nothing and changes nothing about your Service.

17.3 Version archive. Every prior version of this policy, the Terms of Service, and the Research & Data Use Consent is published, dated, at https://www.profilehealth.com/legal/archive. You can always see the exact terms that applied when you enrolled, and those are the terms that govern your data.

18. Contact and Complaints

Privacy questions and requests Privacy Officer, Profile Health, Inc. 434 Sausalito Blvd, Sausalito, CA 94965 · support@profilehealth.com · 802-318-6017

Security matters: support@profilehealth.com

Complaints. If you are not satisfied with our response, you may complain to your state attorney general. Where we act as a business associate of your clinician, you may also complain to the U.S. Department of Health and Human Services, Office for Civil Rights, at www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for making a complaint.