Privacy Policy for One Tenacity Genomic Solutions

Effective Date: November 15, 2025

Welcome to One Tenacity Genomic Solutions ("One Tenacity," "we," "us," or "our"). At One Tenacity, we are committed to protecting your privacy and ensuring the security of your personal and genetic information. This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard your information when you access or use our services, including our genomic analysis platform, pharmacogenetic (PGx) reports, software tools, and related features ("Services"). By using our Services, you consent to the practices described in this Policy.

This Policy applies to all users of our Services, including individuals uploading genetic data for personalized medication insights. If you do not agree with this Policy, please do not use our Services.

1. Information We Collect

We collect information to provide accurate, personalized genomic insights and improve our Services. The types of information we may collect include:

Personal Information

  • Account Information: Name, email address, phone number, and billing details when you create an account or make a purchase.

  • Contact Data: Information you provide when contacting us for support or inquiries.

Genetic and Health Information

  • Genetic Data: DNA test results you upload (e.g., in CSV, VCF, TXT, BAM, or other formats) for analysis, including variants related to drug metabolism, efficacy, and side effects.

  • Health-Related Data: Any self-reported symptoms, medication history, or preferences you share to generate tailored reports.

Usage and Technical Data

  • Log Data: IP address, browser type, device information, pages visited, and timestamps.

  • Analytics Data: How you interact with our platform (e.g., reports viewed, features used) to enhance user experience.

We do not collect sensitive information beyond what is necessary for our Services, and we never request or store payment card details directly.

2. How We Use Your Information

We use your information solely to deliver high-quality, evidence-based genomic services. Specific uses include:

  • Providing Services: Analyzing your genetic data to generate PGx reports, identifying optimal medications, predicting side effects, and offering personalized recommendations.

  • Improving Our Platform: Developing and refining algorithms, software, and reports based on aggregated, de-identified data.

  • Communication: Sending service updates, report notifications, or responses to your inquiries. You can opt out of non-essential emails at any time.

  • Compliance and Safety: Ensuring adherence to legal requirements, detecting fraud, and protecting against unauthorized access.

  • Research (Optional): With your explicit consent, using de-identified data for anonymized research to advance precision oncology and genomic science.

We will never use your data for marketing third-party products without your consent.

3. How We Share Your Information

One Tenacity does not sell, rent, or trade your personal or genetic data. We share information only in limited circumstances:

  • Service Providers: With trusted third-party vendors (e.g., secure cloud storage providers, analytics tools) who are contractually obligated to protect your data and use it only for our Services.

  • Healthcare Professionals: If you authorize sharing reports with your doctor or clinician for treatment decisions.

  • Legal Requirements: To comply with laws, respond to subpoenas, or protect rights, property, or safety (e.g., in cases of suspected abuse).

  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred with appropriate notices.

All sharing complies with applicable laws, and genetic data is always de-identified where possible.

4. Data Security

We prioritize the security of your information using industry-standard measures:

  • Encryption: All genetic and personal data is encrypted in transit (TLS 1.3) and at rest (AES-256).

  • Access Controls: Role-based access limits who can view your data, with multi-factor authentication required for accounts.

  • Compliance: We adhere to HIPAA (for U.S. users where applicable), GDPR (for EU users), and PIPEDA (for Canadian users). Our platform is HIPAA-compliant for protected health information.

  • Breach Response: In the event of a data incident, we will notify affected users and regulators as required by law.

While no system is impenetrable, we continuously monitor and audit our safeguards.

5. Your Rights and Choices

You have control over your data. Depending on your location, you may exercise the following rights:

  • Access and Correction: Request a copy of your data or correct inaccuracies by contacting us.

  • Deletion: Request deletion of your account and data (subject to legal retention requirements).

  • Opt-Out: Withdraw consent for non-essential processing, such as research or marketing.

  • Portability: Receive your genetic data in a standard format for transfer to another service.

  • Restriction/Objection: Limit processing in certain cases, like for direct marketing.

To exercise these rights, email privacy@onetenacity.com. We respond within 30 days (or as required by law) and do not charge fees unless requests are excessive.

6. International Data Transfers

One Tenacity operates primarily in Canada but may transfer data to affiliates or providers in the U.S. or EU. We use Standard Contractual Clauses (SCCs) and adequacy decisions to ensure equivalent protection levels.

7. Children's Privacy

Our Services are not intended for individuals under 18. We do not knowingly collect data from children. If we discover such data, we will delete it promptly.

8. Changes to This Policy

We may update this Policy to reflect changes in our practices or laws. Significant updates will be notified via email or a prominent notice on our platform. Continued use of Services after changes constitutes acceptance.

9. Governing Law

This Policy is governed by the laws of the Province of Ontario, Canada, and federal Canadian laws. Disputes will be resolved in the courts of Ontario.

10. Contact Us

For questions, concerns, or to exercise your rights, contact:

One Tenacity Genomic Solutions Attn: Privacy Officer [Insert Address, e.g., 123 Innovation Drive, Toronto, ON M5V 2T6, Canada] Email: privacy@onetenacity.com Phone: [Insert Phone, e.g., +1 (416) 555-0123]

Thank you for trusting One Tenacity with your genomic journey. We are dedicated to empowering you with precise, secure insights for better health outcomes.