Terms and conditions

Genehub Ltd
Company Number 1431353532-38
Leman Street,
C/O Antler,
Techspace,
London,
E1 8EW,
United Kingdom

• Customers
• Potential investors

Website Privacy Policy 1 INTRODUCTION
1.1 Important information and who we are Welcome to Genehub Ltd’s Privacy and Data Protection Policy (“Privacy Policy”). At Genehub Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting yourprivacy and Personal Data in compliance with the United Kingdom General Data ProtectionRegulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws andregulations of the United Kingdom. This Privacy Policy explains how we collect, process and keep your data safe. The PrivacyPolicy will tell you about your privacy rights, how the law protects you, and inform ouremployees and staff members of all their obligations and protocols when processing data.The individuals from which we may gather and use data can include:Customers Potential investors
and any other people that the organisation has a relationship with or may need to contact. This Privacy Policy applies to all our employees and staff members and all Personal Dataprocessed at any time by us.

1.2 Your Data Controller and Data Protection Officer
Genehub Ltd is your Data Controller and responsible for your Personal Data. 1 23 March 2023 We have appointed a data protection officer (“DPO”) who is responsible for overseeingquestions in relation to this Privacy Policy. If you have any questions about this PrivacyPolicy, including any requests to exercise your legal rights surrounding your Personal Dataplease contact the DPO using the details set out below: Name: Edward Straiton
Email: ed.straiton@genehub.co.uk Postal address: 32-38 Leman Street, C/O Antler, Techspace, London, E1 8EW, UnitedKingdom You have the right to make a complaint at any time to the Information Commissioner’sOffice (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). Wewould, however, appreciate the chance to deal with your concerns before you approachthe ICO so please contact us in the first instance.


1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. TheData Controller and our Processors have the following responsibilities:
Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation ofconfidentiality;
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorisation of the Controller before engaging another Processor; Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contributeto audits, including inspections, conducted by the Controller or another auditormandated by the Controller; Maintain a record of all categories of processing activities carried out on behalf of aController; Cooperate, on request, with the supervisory authority in the performance of itstasks; Designate a data protection officer where required by the GDPR, publish theirdetails and communicate them to the supervisory authority; Support the data protection officer in performing their tasks by providing resourcesnecessary to carry out those tasks and access to Personal Data and processingoperations and to maintain their expert knowledge; 2 Ensure that any person acting under the authority of the Processor who has accessto Personal Data does not process Personal Data except on instructions from theController; and Notify the Controller without undue delay after becoming aware of a Personal DataBreach. 2 LEGAL BASIS FOR DATA COLLECTION 2.1  Types of data / Privacy policy scope “Personal Data” means any information about an individual from which that person canbe identified. It does not include data where the identity has been removed (anonymousdata). We may collect, use, store and transfer different kinds of Personal Data about you whichwe have grouped together below. Not all of the following types of data will necessarily becollected from you but this is the full scope of data that we collect and when we collect itfrom you: Contact Data: This is data relating to your phone number, addresses, emailaddresses, phone numbers. Medical Data: this is data relating to health conditions recorded by your caregiver. For the purposes of our business we also collect what is known under the GDPR as specialcategories of Personal Data. We collect the following types of special Personal Data: Genetic information and biometric data In order to collect this special kind of data we need enhanced legal justifications beyondthe ordinary legal justifications under the GDPR. We explain which justifications we rely onin paragraph 2.2 below. 2.2  The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are: “Consent”: Certain situations allow us to collect your Personal Data, such as whenyou tick a box that confirms you are happy to receive email newsletters from us, or‘opt in’ to a service. “Contractual Obligations”: We may require certain information from you in orderto fulfil our contractual obligations and provide you with the promised service. “Legal Compliance”: We’re required by law to collect and process certain types ofdata, such as fraudulent activity or other illegal actions. “Legitimate Interest”: We might need to collect certain information from you to beable to meet our legitimate interests - this covers aspects that can be reasonablyexpected as part of running our business, that will not have a material impact onyour rights, freedom or interests. Examples could be your address, so that we knowwhere to deliver something to, or your name, so that we have a record of who tocontact moving forwards. 3 For the special categories of data that we collect, the enhanced legal justification we relyon is: (a) The data subject has given explicit consent to the processing of such Personal Datafor one or more specified purposes (“Explicit Consent”). 3 HOW WE USE YOUR PERSONAL DATA3.1 Our data uses We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and thelawful basis for processing that data. Please refer to section 2.2 for more information onthe lawful basis listed in the table below. Examples provided in the table below are indicative in nature and the purposes for whichwe use your data may be broader than described but we will never process your datawithout a legal basis for doing so and it is for a related purpose. For further inquiriesplease contact our Data Protection Officer. Activity Type of data LegalJustification Lawful basis forprocessing data Through medicalrecord import Profile/Identity Data Consent ExplicitConsent Medical We only process data withyour consent 3.2  Marketing and content updates You will receive marketing and new content communications from us unless youspecifically request that you would not like to receive these communications. From time totime we may make suggestions and recommendations to you about goods or services thatmay be of interest to you. 3.3  Change of purpose We will only use your Personal Data for the purposes for which we collected it, unless wereasonably consider that we need to use it for another reason and that reason iscompatible with the original purpose. If you wish to get an explanation as to how theprocessing for the new purpose is compatible with the original purpose, please contactour Data Protection Officer. If we need to use your Personal Data for an unrelated purpose, we will notify you and wewill explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent,in compliance with the above rules, where this is required or permitted by law. 4 4 YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US4.1 Your legal rights Under certain circumstances, you have the following rights under data protection laws inrelation to your personal data: Right to be informed. You have a right to be informed about our purposes forprocessing your personal data, how long we store it for, and who it will be sharedwith. We have provided this information to you in this policy. Right of access. This enables you to receive a copy of the personal data we holdabout you and to check that we are lawfully processing it (also known as a "datasubject access request"). See section 4.5 below for more details on how you canmake a data subject access request. Right to rectification. You have a right to request correction of the personal datathat we hold about you. This enables you to have any incomplete or inaccurate datawe hold about you corrected, though we may need to verify the accuracy of the newdata you provide to us. Right to erasure. You have the right to ask us to delete or remove personal datawhere there is no good reason for us continuing to process it, where you havesuccessfully exercised your right to object to processing (see below), where we mayhave processed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not always beable to comply with your request of erasure for specific legal reasons which will benotified to you, if applicable, at the time of your request. Right to object. You can object to the processing of personal data we hold aboutyou. This effectively allows you to stop or prevent us from processing your personaldata. Note that this is not an absolute right and it only applies in certaincircumstances, for example: (i)  Where we are processing your personal data for direct marketing purposes. (ii)  Where we are relying on a legitimate interest (or those of a third party) andthere is something about your particular situation which makes you want toobject to processing on this ground as you feel it impacts on yourfundamental rights and freedoms. (iii)  In some cases, we may continue processing your data if we can demonstratethat we have compelling legitimate grounds to process your informationwhich override your rights and freedoms. Right to restrict processing. You have the right to request the restriction orsuppression of their personal data. Note that this is not an absolute right and it onlyapplies in certain circumstances: (i)  If you want us to establish the data's accuracy. (ii)  Where our use of the data is unlawful but you do not want us to erase it. (iii)  Where you need us to hold the data even if we no longer require it as youneed it to establish, exercise or defend legal claims. (iv)  You have objected to our use of your data but we need to verify whether wehave overriding legitimate grounds to use it. 5 Right to data portability. You have the right to request the transfer of yourpersonal data to you or to a third party. If you make such a request, we will provideto you, or a third party you have chosen, your personal data in a structured,commonly used, machine-readable format. Note that this right only applies toautomated information which you initially provided consent for us to use or wherewe used the information to perform a contract with you. If you wish to make a request under any of these rights, please contact us at ed.straiton@genehub.co.uk. 4.2  Your control over Genehub Ltd’s use of your Personal Data
You may delete your account at any time – this will remove your account page from our systems and our related software.
We guarantee this will delete all stored data. You can access information associated with your account by logging into your account youcreated with us. Your account information will be protected by a password for your privacy and security.You need to prevent unauthorized access to your account and personal information byselecting and protecting your password appropriately and limiting access to yourcomputer or device and by signing off after you have finished accessing your account. California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, Californiaresidents are entitled to ask us for a notice identifying the categories of personal customerinformation which we share with our affiliates and/or third parties for marketing purposes,and providing contact information for such affiliates and/or third parties. If you are aCalifornia resident and would like a copy of this notice, please submit a written request toed.straiton@genehub.co.uk. 4.3  How Genehub Ltd protects customers' Personal Data We are concerned with keeping your data secure and protecting it from inappropriatedisclosure. We implement a variety of security measures to ensure the security of yourPersonal Data on our systems, including We implement certain security measures toensure the security of your Personal Data on our systems, including encryption at rest andtransit of data, with access control utilising ledgers to provide a single source of consent. .Any Personal Data collected by us is only accessible by a limited number of employeeswho have special access rights to such systems and are bound by obligations ofconfidentiality. If and when we use subcontractors to store your data, we will notrelinquish control of your Personal Data or expose it to security risks that would not havearisen had the data remained in our possession. However, unfortunately no transmissionof data over the internet is guaranteed to be completely secure. It may be possible forthird parties not under the control of Genehub Ltd to intercept or access transmissions orprivate communications unlawfully. While we strive to protect your Personal Data, wecannot ensure or warrant the security of any Personal Data you transmit to us. Any suchtransmission is done at your own risk. If you believe that your interaction with us is nolonger secure, please contact us. 4.4  Opting out of marketing promotions
You can ask us to stop sending you marketing messages at any time by Contacting data controller, ed.straiton@genehub.co.uk.. 6 Where you opt out of receiving these marketing messages, we will continue to retain otherPersonal Data provided to us as a result of interactions with us not related to yourmarketing preferences. 4.5 How to request your data and the process for obtaining it You will not have to pay a fee to access your Personal Data (or to exercise any of the otherrights). However, if your request is clearly unfounded, we could refuse to comply with yourrequest. We may need to request specific information from you to help us confirm your identityand ensure you have the right to access your Personal Data (or to exercise any of yourother rights). This is a security measure to ensure that Personal Data is not disclosed toany person who has no right to receive it. We may also contact you to ask you for furtherinformation in relation to your request to speed up our response. 5  YOUR DATA AND THIRD PARTIES
5.1 Sharing your data with third parties We may share non-Personal Data with third parties. We may share your Personal Datawith subcontractors or affiliates, subject to confidentiality obligations to use it only for thepurposes for which we disclose it to them and pursuant to our instructions. We may also share Personal Data with interested parties in the event that Genehub Ltdanticipates a change in control or the acquisition of all or part of our business or assets orwith interested parties in connection with the licensing of our technology. If Genehub Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer,sell or assign your Personal Data to a third party as part of or in connection with thattransaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern thefurther use of your Personal Data. In all other situations your data will still remainprotected in accordance with this Privacy Policy (as amended from time to time). We may share your Personal Data at any time if required for legal reasons or in order toenforce our terms or this Privacy Policy. 6  HOW LONG WE RETAIN YOUR DATA We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposeswe collected it for. We may retain your Personal Data for a longer period than usual in the eventof a complaint or if we reasonably believe there is a prospect of litigation in respect to ourrelationship with you. 7  INTERNATIONAL TRANSFER OF DATA Your information may be stored and processed in the US or other countries or jurisdictionsoutside the US where Genehub Ltd has facilities. By using Genehub Ltd, you are permitting andconsenting to the transfer of information, including Personal Data, outside of the US. 8  NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY We keep our Privacy Policy under review and will place any updates here. This version is dated 23March 2023. 7 By using Genehub Ltd, you consent to the collection and use of data by us as set out in thisPrivacy Policy. Continued access or use of Genehub Ltd will constitute your express acceptance ofany modifications to this Privacy Policy. 9  INTERPRETATION All uses of the word "including" mean "including but not limited to" and the enumeratedexamples are not intended to in any way limit the term which they serve to illustrate. Any emailaddresses set out in this policy may be used solely for the purpose for which they are stated tobe provided, and any unrelated correspondence will be ignored. Unless otherwise required bylaw, we reserve the right to not respond to emails, even if they relate to a legitimate subjectmatter for which we have provided an email address. You are more likely to get a reply if yourrequest or question is polite, reasonable and there is no relatively obvious other way to deal withor answer your concern or question (e.g. FAQs, other areas of our website, etc.). Our staff are not authorised to contract on behalf of Genehub Ltd, waive rights or makerepresentations (whether contractual or otherwise). If anything contained in an email from aGenehub Ltd address contradicts anything in this policy, our terms or any official publicannouncement on our website, or is inconsistent with or amounts to a waiver of any GenehubLtd rights, the email content will be read down to grant precedence to the latter. The onlyexception to this is genuine correspondence expressed to be from the Genehub Ltd legaldepartment. 10  TERMS OF USE
Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of Genehub Ltd. SeedLegals - Website Privacy Policy - PYCP-2-2022-10-22d_ZjlZHf30mj 8