Navigenics - Privacy policy

Our policy is that your genetic data is your property, and we understand that sensitive personal data and your health are very private subjects. Our goal is for you to feel as confident and comfortable as possible visiting our Web site and using our services. We have established this privacy policy to inform you about the specific practices and guidelines that help ensure the security and confidentiality of your personal information.

Navigenics respects our users' privacy. Here's how:

• Navigenics will never, without your explicit consent, reveal Your Account Information, Your Genetic Data or Your Phenotype Information to a third party except as required to provide services you have requested, or as required by law.
• We may improve our services and make new scientific discoveries using aggregated genetic data and phenotype information from our members, but we will not publish Your Genetic Data or Your Phenotype Information or share them with third parties without your explicit consent.
• We may aggregate non-personally identifiable demographic information and usage patterns about our users in order to improve our site or services. We will not track your behavior in any way that can identify you in particular.
• Our Web site uses cookies to help provide relevant information to you when you use the site and to prevent fraudulent access to your account. Cookies, stored on your computer, identify your computer to us alone. Cookies are only visible to us when you visit our site.
• We will be sending at least three types of e-mails: e-mails required to provide you with services you have requested; alerts giving you relevant and new information about service updates; and e-mails informing you about promotional services. Alerts and promotional e-mail messages will contain a link that will allow you to opt out of future mailings.

If you have any questions about privacy, contact:

Chief Privacy Officer
Navigenics, Inc.
(650) 585-7700
privacy@navigenics.com

Details of our privacy policy

Your privacy is extremely important to us. This privacy policy will explain how we collect and use the information that you provide to us.

Collection and use of information

Navigenics collects a variety of information regarding your use of our Web site and services, including personally identifiable information. The "personally identifiable information" in this policy refers to the following:

• "Your Account Information" means the information that you provide to us when creating or updating your Navigenics account, or purchasing our services, that can be used to uniquely identify you, such as your name, telephone number, e-mail address, billing/shipping address or credit card number.
• "Your Genetic Data" means the genotyping results that we generate for you through our services (namely, the set of "A"s, "G"s, "T"s and "C"s at particular locations in your genome) to the extent such results are sufficient in quantity to uniquely identify you.
• "Your Phenotype Information" means the personal information that you voluntarily provide to us, which may include your gender, your birth date, your ethnicity/ancestry, the geographic regions where you or your ancestors have lived, any diseases or other health conditions that run in your family, and personal traits such as height and weight.

We collect and use Your Account Information and other personally identifiable information about you to authenticate your use of our Web site and services, to process your purchase transactions, to provide you with the services you have requested, to communicate with you and to send you relevant information and materials. However, we will not, without your explicit consent, disclose or share personally identifiable information about you with third parties except as required to provide the services you have requested, or as otherwise required by applicable law.

Navigenics may freely collect, use and disclose any non-personally identifiable information collected on our Web site, unless otherwise prohibited by this privacy policy or applicable law. This information may include your computer's internet protocol (IP) addresses and cookies which are placed on your computer when you access our Web site (see the cookies section below), as well as the date and time, your computer's operating system and Web browser type, the identity of your internet service provider, and a list of Web pages you have visited. In some cases, this information is collected automatically and stored in log files. Navigenics has contracted with a third-party Web analytics company to help us use this information, which is not intended to uniquely identify you, to track and analyze aggregate usage volume and patterns regarding our Web site. Under certain circumstances, we may need to review this information in combination with Your Account Information to identify and resolve an issue regarding your access to our Web site.

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Research

Navigenics believes in bringing you the highest quality service available and helping further scientific and medical research. To that end, we may analyze our members' genetic data and associated phenotype information on an aggregated basis and de-linked from any member account information, to:

• Improve the quality and features of our Web site and services
• Provide our members with new and more accurate analysis of genetic data
• Discover or validate associations between certain genetic variations and certain health conditions or traits, as well as other insights regarding human health
• Publish our findings and insights without disclosing Your Genetic Data in a quantity sufficient to uniquely identify you, and without otherwise disclosing your identity

As the number of our members grows, potentially surpassing the size of currently available public data sets that we use to calculate risk estimates, our ability to study the aggregated genetic data and phenotype information we have collected from our members, and to publish our findings and insights, will help us to further the advancement of scientific and medical research and fulfill our mission to help you live healthier, longer.

We may also give you the opportunity to contribute your genetic information to science. If you elect to contribute your genetic information to science through the Navigenics service, you allow us to share Your Genetic Data and Your Phenotype Information (de-linked from Your Account Information) with not-for-profit organizations who perform genetic or medical research, and you allow such not-for-profit organizations to separately or jointly publish study results that include Your Genetic Data and Your Phenotype Information (but not Your Account Information), in peer-reviewed scientific and medical journals and otherwise, and to deposit such data and information into public data repositories or otherwise make them publicly available to the extent required by such journals.

If you elect not to contribute your genetic information to science through the Navigenics service, we will not share Your Genetic Data or Your Phenotype Information with such organizations.

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Cookies

Navigenics uses a combination of session and persistent cookies to track your navigation and use of our Web site, and your Web browser must be configured to accept cookies in order for you to create a Navigenics user account and access many of the features on our Web site. Cookies are small pieces of information that are stored by your Web browser on your computer's hard drive. Our cookies enable us to facilitate access to different aspects of your account across our Web site, and to enhance your experience on our Web site. For example, by showing when and how you and other users visit our Web site, cookies help us to see which pages of the Web site are particularly helpful to customers for providing information. This helps us improve our Web site, because we can eliminate pages that are unpopular and update and improve those pages that are visited frequently. Cookies also improve your ease of using our Web site, for example, by remembering your address or ordering information when you request information or services on our Web site. We also use cookies to securely link your Navigenics account with the computer you used to set up your account; if you choose to access your account from another computer, you will be asked to follow additional steps to verify your identity.

Please note that session cookies expire automatically when you close your computer's Web browser, whereas persistent cookies are stored on your computer's hard drive until deleted. If you set up or access your Navigenics account from someone else's computer, or a publicly accessible computer, we recommend that when your session is complete you delete any persistent cookies on the computer by following the Web browser's instructions and then close the Web browser.

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Communications from us

We will be sending at least three types of e-mails: e-mails required to provide you with services you have requested; alerts giving you relevant and new information about service updates; and e-mails informing you about promotional services. Alerts and promotional e-mail messages will contain a link that will allow you to opt out of future mailings.

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Advertising

The Navigenics Health Compass is not an advertising-subsidized service. Navigenics does not derive revenue from the use of banner advertisements. However, we may describe our collaborators' products and services on our Web site or in our communications to our members from time to time, and we may feature links to our collaborators' Web sites.

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Privacy practices of third-party Web sites

This Web site may contain links to other Web sites. Navigenics is not responsible for the privacy policies or practices of any third-party Web sites, including Web sites of any sponsors, collaborators or linked Web sites, or for the privacy policies or practices of any other third parties. To the extent that you disclose personally identifiable information to any collaborator Web sites, linked Web sites or other third parties, different rules may apply to their use or disclosure of any personally identifiable information you disclose to them, and we encourage you to review their privacy policies before disclosing personally identifiable information to them.

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Minors

This Web site is not directed toward minors under 18 years of age. Given the ethical, privacy and informed consent considerations regarding genetic testing of minors for predisposition or carrier status of adult-onset genetic disorders, Navigenics does not knowingly collect or use information from minors under the age of 18.

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Security practices and procedures

To prevent unauthorized access, we have put in place procedures to safeguard and secure the information we collect online. While we cannot guarantee that loss, misuse or alteration of data won't occur, we try to prevent such occurrences through the use of well-tested safeguards and routine security auditing consistent with the most rigorous industry practices. For example, to prevent fraudulent access to your Navigenics account, we use four methods of identification: your unique username, your password, your e-mail address and your mobile phone number (for verification via SMS text message).

We have installed the most advanced technology to ensure that your interaction with Navigenics is as secure as possible. Information that you provide to Navigenics through this Web site is encrypted using industry-standard Secure Sockets Layer (SSL) technology, with the exception of any information you choose to send via e-mail. Your personally identifiable information is processed and stored on controlled servers, and we have put in place appropriate physical, electronic and operational procedures to safeguard and help prevent unauthorized access, maintain data security and correctly use the personally identifiable information we collect.

• Unique anonymous ID numbers will be assigned to your Navigenics Health Compass DNA self-collection kit and to your corresponding test results.
• We store Your Account Information separately from Your Genetic Data and Your Phenotype Information, and store all three types of information in an encrypted format.
• We utilize SSL encryption to secure all connections to and from the Navigenics Web site. (Your computer's internet browser must support 128-bit encryption to take advantage of SSL encryption.)
• We use server hardware and software firewalls, intrusion detection and continuous monitoring and alerting services to secure our network perimeter, systems and facilities.
• We limit access to personally identifiable information about you to appropriate Navigenics personnel on a need-to-know basis only.
• Our employees, consultants and any third parties with whom we share personally identifiable information about you have agreed to confidentiality obligations consistent with this Privacy Policy.
• We monitor and document access by Navigenics personnel to personally identifiable information.
• Our external data center utilizes a SAS70 Type II audit process; access to the data center is limited to authorized personnel via biometric scanning, security camera monitoring, 24x7 onsite staff and unmarked facilities.
• Our security practices and procedures are audited by an independent security consulting firm.
• We require that all Navigenics personnel with access to personally identifiable information be trained on documented information security and privacy procedures.

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Legally required disclosure

We may be legally compelled in the future to disclose personally identifiable information about you to satisfy a court order, subpoena, government request, law, regulation or other legal process. We will use reasonable and lawful efforts to limit the scope of any such legally required disclosure, and we will make every attempt to notify you in advance insofar as we are legally permitted to do so.

In the event that Navigenics is acquired by or merges into another company, any personally identifiable information or other information owned or possessed by Navigenics may be transferred to the successor, whom we will require to comply with the terms of this Privacy Policy.

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Termination of your account

If you do not renew your account subscription with Navigenics, or if at any time you request us to terminate your Navigenics user account, we will delete Your Genetic Data and Your Phenotype Information within 90 days from all operational Navigenics systems, and Your Genetic Data and Your Phenotype Information will not be included in any future archive of these systems, unless we are required by applicable law to retain any such data and information, in which case we will do so only for so long as required, and only for the purposes of such law. However, we will not be obligated to delete your Genetic Data or Your Phenotype Information from historical archives of our systems.

Upon account termination, you will be given an opportunity to withdraw your consent for us to use Your Genetic Data and Your Phenotype Information (de-linked from Your Account Information) for our internal research purposes as described above. If you previously have elected to contribute your genetic information to science through the Navigenics service, you will also have the opportunity upon account termination to withdraw your consent for not-for-profit organizations to begin new studies using Your Genetic Data and Phenotype Information after the 90-day period. However, Your Genetic Data and Your Phenotype Information will not be removed from any ongoing or completed studies or publications in which Your Genetic Data or Your Phenotype Information was utilized.

Finally, we may retain Your Account Information solely to the extent required for our accounting and compliance purposes, and as otherwise required by applicable law.

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Changes to this Privacy Policy

Navigenics reserves the right to modify or amend this privacy policy at any time. Any material changes will be conspicuously posted on this Web site, and we will notify members by e-mail. Changes will be effective 30 days after posting to this Web site and e-mail notification.

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Contacting us

If you have any questions or concerns regarding this Privacy Policy, or if you wish to have access to or request corrections or updates to personally identifiable information in our records, please contact:

Chief Privacy Officer
Navigenics, Inc.
(650) 585-7700
privacy@navigenics.com

EFFECTIVE DATE: APRIL 8, 2008

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