Privacy Policy

This Privacy Policy ("Privacy Policy") is published in compliance with:

This Privacy Policy governs the collection, use, and protection of information in connection with your use of our Platform, and sets out:

In accordance with Article 22 of the PDPL, the Personal Data may be transferred or processed outside the United Arab Emirates where the recipient country or jurisdiction provides an adequate level of protection for Personal Data under its applicable data protection laws. Accordingly, the Company may store, transfer or process Personal Data, including Sensitive Personal Data, in jurisdictions such as India, where the collection, use, storage, and disclosure of personal data are governed by applicable data protection laws, and the rules framed thereunder, subject to compliance with the PDPL and this Privacy Policy.

In particular, where Personal Data is processed in India, such processing shall be subject to the following applicable laws and regulations:

1.1 The Platform is owned and managed by EPIGENOME.AI FUNDAMENTAL RESEARCH PRIVATE LIMITED ("Company", "We", "Us", or "Our"), a health-technology company incorporated in India and engaged in providing AI-enabled preventive health insights and related services ("Services") through the website hosted at https://www.egenome.ai/ and mobile application (collectively, the "Platform"). This Privacy Policy applies to all current and former users accessing or using the Platform from the United Arab Emirates, or otherwise engaging with Us through email or other means (collectively, "You" or "Your").

1.2 This Policy shall be read together with the Terms of Use provided on the website. The words and expressions used in this Policy but not defined herein will have the meaning assigned to them under Terms of Use.

1.3 The collection and processing of information in the course of laboratory testing, sample collection, or other contractual engagements that we may enter into with our service providers and partners shall be governed by specific terms applicable thereto, and not by this Privacy Policy.

1.4 By accessing or using Our Platform, or otherwise providing Us with Your information, You confirm that You have the capacity to enter into a legally binding contract under applicable UAE laws and that You have read, understood, and agreed to the practices and policies set out in this Privacy Policy.

1.5 You hereby provide explicit, informed, and voluntary consent to Our collection, use, sharing, processing, and disclosure of Your information in accordance with this Privacy Policy and the PDPL.

1.6 We may update, modify, or amend this Privacy Policy from time to time. Your continued use of the Platform after any such update will be deemed as Your acceptance of the revised Privacy Policy. If You do not agree with this Privacy Policy, in part or whole, please do not use the Platform or provide Us with any of Your information.

2.1 We collect the following categories of information relating to You, both through the Platform and by means of ancillary offline processes, including but not limited to the collection of blood samples and consultations conducted with our dietitian or nutritionist:

(Collectively referred to as "Information").

2.2 We collect Your Information either directly from You through Our Platform and ancillary offline processes or indirectly by using different technologies including through cookies, analytics tools, and authorized service providers.

2.3 To access and use Our Platform, You may provide information such as Your name, age, date of birth, email address, mobile number, and account credentials ("User Information").

2.4 We may also collect User Information when You visit any of Our offices, attend seminars, webinars, conferences, or events organised by Us, or avail Our Services. This may include health-related and genetic information voluntarily provided by You through questionnaires, diagnostic reports, or assessments. Such information may constitute Sensitive Personal Data under the PDPL, and is collected solely for creation and maintenance of Your Profile and delivery of Services, with Your explicit consent.

2.5 We may collect demographic details including Your age, gender, and location ("Demographic Information").

2.6 We may also collect information about how You use the Platform and information about Your mobile device and software including usage statistics, traffic data, Your IP address, browser and operating system type, domain names, access times, locations, and details regarding the parts of the Platform that You access ("Behavioural Information").

2.7 In certain cases, when You use third-party services integrated with Our Platform, We may collect additional information as required for the provision of those services ("Indirect Information").

2.8 While We may collect Demographic Information, Behavioural Information and Indirect Information when You access or use Our Platform, We collect User Information only from You with Your prior consent unless there are other legal grounds for doing so, as further specified in this Privacy Policy. Where You provide Us with User Information of third parties, We understand that You have obtained consent of such third parties, and have appropriate rights, authorizations, permissions, approvals and licenses to provide such information to Us.

2.9 The PDPL and the ICT Health Law regulate the collection, usage, retention and disclosure of Personal Data and health information. "Personal Data" has been defined under the PDPL to mean any data related to a specific natural person or related to a natural person that can be identified directly or indirectly by linking the data, through the use of identification elements such as his/her name, voice, image, identification number, his/her electronic identifier, his/her geographical location, or by one or more physical, physiological, economic, cultural or social characteristics. Personal Data includes Sensitive Personal Data and Biometric Data.

2.10 The PDPL define "Sensitive Personal Data" ("SPD") as "Any data which directly or indirectly reveals a natural person's family, ethnic origin, political or philosophical opinions, religious beliefs, criminal record, biometric data, or any data relating to such person's health and physical, psychological, mental, genetic or sexual condition, including information related to the provision of healthcare services to him/her which reveals his/her health status."

2.11 The PDPL define "Biometric Data" as Personal Data resulting from processing using a specific technology related to the physical, physiological or behavioral characteristics of the Data Subject, which allows the identification or confirmation of the unique identification of the Data Subject, such as facial images or fingerprints.

2.12 Some of the Information collected by Us may qualify as Personal Data or SPD or Biometric Data, as explained below.

2.13 We understand that all Personal Data provided by You to Us is voluntary. Collection, use and disclosure of Personal Data requires Your express consent, unless there are other legal grounds available to us to collect such information as further specified in this Privacy Policy. By using or accessing the Platform or otherwise providing Us with Your Personal Data, where applicable, You are providing Us with Your consent to Our use, collection, retention, transfer and disclosure of the Personal Data in accordance with the terms of this Privacy Policy.

2.14 We understand that, under the ICT Health Law, certain categories of health data generated in connection with regulated healthcare services within the United Arab Emirates may be subject to restrictions on cross-border processing or storage. Accordingly, where the Services involve cross-border processing of health-related or genetic data, You acknowledge and agree that You should not submit any data that is required to be mandatorily processed or stored within the United Arab Emirates under applicable healthcare regulations, unless expressly permitted by law. By voluntarily submitting Your health-related or genetic data through the Platform, You confirm that such submission is made with full knowledge of the nature of the Services, and You declare and affirm that such data is not in relation to health services provided within the United Arab Emirates or otherwise subject to mandatory localization requirements under applicable UAE healthcare laws.

2.15 In the event of any change in the applicable data protection laws in India or UAE, You expressly consent to Our continued collection, use, storage, and disclosure of Your Information, including Personal Data, to the extent permitted under the revised legal framework. We may contact You to obtain any additional consents or approvals that may be required under the amended laws, and You agree to comply with such requests. If You choose not to provide the necessary consents or approvals, We may have to discontinue your access to the Platform.

2.16 You have the option to withhold or revoke any of your Personal Data. However, please be aware that doing so may prevent Us from granting you access to the Platform or from delivering specific services that depend on the collection and processing of this information.

2.17 We automatically receive and record information on Company's web server logs from Your device including the Internet Protocol (IP) address. Company records IP addresses for anonymous statistical purposes, administration of this Website and associated servers, and to improve Company's services.

3.1 We use Your Information (including User Information, Demographic Information, Behavioural Information and Indirect Information) for the following purposes:

3.2 In addition to the above, We also use Your Personal Data, including Health Information, for the following purposes ("Purposes"):

3.3 If You wish to opt out of receiving communications such as information regarding the Platform and/or any regulatory updates provided by Us, You may do so by emailing Us at info@egenome.ai.

3.4 Our processing of Your Personal Data in the context of Your visit to, and use of Our Platform is based on Our legitimate interests to operate a secure and reliable digital platform for providing AI-powered health insights, to optimise the functionality and user experience of the Platform, and to protect it from misuse or security threats. Furthermore, Our processing of Your Personal Data, including Health Information, for providing You with health reports, wellness updates, and related communications serves the legitimate interests of users in receiving meaningful, personalised health information, and serves Our legitimate interests to improve Our Services, enhance accuracy of Our AI models, and strengthen user trust and engagement.

4.1 We disclose Your Information, including Personal Data and Health Information, to third parties in the manner specified below:

4.2 The third parties referred to in the above clause may include:

5.1 The Platform may contain links to third-party websites, applications, and services ("Third Party Services"). These are operated and managed by persons or entities other than Us. We have no control over such Third Party Services and are not responsible for any collection, use, or disclosure of Your Information by such third parties

5.2 We are not liable for any loss or damage that may be incurred by You as a result of the collection, use, or disclosure of Your Information by Third Party Services. Any dispute or issue arising from Your interaction with such Third Party Services shall be solely between You and the relevant third party.

5.3 Such Third Party Services may have their own privacy policies governing the collection, storage, transfer, retention, and/or disclosure of Your Information. We strongly recommend that You exercise reasonable diligence, and review the privacy policies of such third parties before engaging with them, sharing Information, or availing their services.

6.1 You may review, correct, update, or change Your Personal Data and Health Information on the Platform by emailing Us at info@egenome.ai.

6.2 You may also request Us to delete Your Personal Data, and We will comply with such requests within a reasonable time, unless retention is required for legal, regulatory, or contractual purposes (including healthcare compliance requirements)

6.3 If You choose to delete Your Personal Data, or modify it in a manner that is not verifiable by Us, or which renders such Personal Data inaccurate, We may be unable to continue providing You with access to the Platform or deliver Our Services. Such deletion or modification may be treated as a discontinuation of Your use of the Platform.

6.4 We reserve the right to verify and authenticate Your identity and Your Personal Data, including Health Information, in order to ensure secure and accurate delivery of AI-powered health reports through the Platform.

6.5 Access to, correction, updating, or deletion of Your Personal Data may be denied or restricted if it would infringe upon the rights of another person, or if such action is not otherwise permitted under applicable law.

7.1 We adopt physical, technical, and procedural safeguards that are appropriate to protect Your Information, including Personal Data and Health Information, against loss, misuse, copying, damage, modification, unauthorised access, or disclosure. Some of the measures implemented by Us include:

7.2 Further, We shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond Our reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, etc.

8.1 We will implement measures to ensure that Your Personal Data and Health Information, which is in Our possession or under Our control, is securely destroyed and/or anonymised as soon as, and in any case within five (5) years of it being reasonable to assume that (i) the purpose for which such Information was collected is no longer being served by its retention; and (ii) retention is no longer necessary for any other reason, including compliance with applicable healthcare or legal requirements.

8.2 If You wish that We no longer use Your Personal Data in accordance with the terms of this Privacy Policy, You may contact Us at info@egenome.ai.

8.3 We, however, reserve the right to retain, store, and use Your Information, including Personal Data and Health Information, for Our legitimate business purposes and as required under applicable law, whether or not such Information has been deleted at Your request. After a certain period, Your Information may be anonymised and aggregated, and may thereafter be retained by Us as long as necessary to improve Our AI models, provide Services effectively, and for research and analytical purposes.

8.4 Please note that withdrawal of Your consent for processing of Personal Data and Health Information may result in Our inability to provide You with access to the Platform or may require termination of any existing relationship that We have with You.

We cannot guarantee that all of Your Information, including Personal Data and Health Information, will never be disclosed in ways not otherwise described in this Privacy Policy. While We are committed to safeguarding Your privacy and employ appropriate measures to protect Your data, We do not promise, and You should not expect, that Your Information or communications will always remain completely private or secure. As a user of the Platform, You assume full responsibility and risk for Your use of the Platform, the internet generally, and for any information You choose to share, post, or access, as well as for Your conduct on and off the Platform.

You agree and undertake to indemnify Us in any suit or dispute by any third party arising out of disclosure of information by You to third parties either through Our Platform or otherwise, and Your use and access of websites, applications and resources of third parties. We assume no liability for any actions of third parties with regard to Your Information or Personal Data which You may have disclosed to such third parties.

11.1 We are committed to protect your Personal Data collected and processed by us and look forward to your continued support for the same. In case of any feedback or concern regarding protection of your Personal Data, or any privacy related feedback or concerns you may contact us at info@egenome.ai.

11.2 We welcome your views about the Platform and the Privacy Policy. If you would like to contact us with any queries or comments, please send an email to info@egenome.ai.

11.3 In accordance with the PDPL, the name and contact details of the Data Protection Officer are provided below:

Data Protection Officer

EPIGENOME.AI FUNDAMENTAL RESEARCH PRIVATE LIMITED

Email: info@egenome.ai