Introduction

This Privacy Policy explains how Genefluence Limited (“Genefluence”, “we”, “us” or “our”) collects, uses, protects and manages personal information in connection with the Genefluence services, websites, applications and related experiences (the “Services”).

Genefluence Limited is a company registered in England and Wales with company number 15385485 and registered office at Scale Space, Imperial College White City Campus, 58 Wood Lane, London W12 7RZ, United Kingdom.

Genefluence operates the Genefluence and DnaNudge services.

Protecting personal information including sensitive genetic and trait-related information is fundamental to how we design and operate our Services.

Scope

This Privacy Policy explains:

• what information we collect
• how we use it
• how we protect it
• how information may be shared
• your rights and choices

This Policy does not apply to information that has been irreversibly anonymised or aggregated such that it can no longer reasonably identify an individual.

Who is responsible for processing your information?

Genefluence Limited is the data controller responsible for processing personal information collected through the Services, including:

• account information
• customer communications
• interpreted genetic trait information
• product recommendations
• app usage data
• Matching and profile interaction features

Contacting us

If you have questions about this Privacy Policy or our handling of personal information, please contact:

Genefluence Limited
Scale Space
Imperial College White City Campus
58 Wood Lane
London W12 7RZ
United Kingdom

Email: customer.service@genefluence.com

For data protection enquiries, please contact our Data Protection Officer using the details above.

Information we collect

Account information

To access certain Services, you may create an account and provide information such as:

• name or chosen display name
• email address
• telephone number
• age or date of birth
• password and login credentials

Genetic and skincare trait information

To provide the Genefluence experience, users may provide a DNA sample using an authorised swab and testing system.

Genefluence is designed around selected skincare-related genetic markers relevant to the Services. We do not sequence or store your full genetic profile.

Once testing is completed, the physical DNA sample is destroyed.

The testing process generates encrypted marker measurements that are interpreted to produce skincare-related trait insights relevant to areas such as hydration, brightness, antioxidant support, barrier function and visible ageing.

The Services are designed so that interpreted skincare traits - rather than raw genetic code or full genomic data - support product guidance, personalisation and related app experiences.

Matching and profile information

Certain Services may include profile comparison, Matching or sharing features.

These features may allow users to:

• compare interpreted skincare traits
• receive similarity or compatibility insights
• share selected profile information
• participate in community or discovery experiences

Participation in these features may be optional and subject to user controls and visibility settings.

Raw genetic data is not shared with other users.

Information you provide to us

We may collect information you choose to provide through:

• customer support enquiries
• surveys and questionnaires
• research participation
• app interactions
• communications with us
• marketing preferences

Device, browsing and usage information

We may automatically collect information relating to:

• device type
• browser type
• operating system
• app usage
• interactions with the Services
• website analytics
• cookies and similar technologies

This information helps us improve, personalise and secure the Services.

How we use your information

We may use personal information to:

• provide and operate the Services
• personalise skincare recommendations and experiences
• support Matching and profile features
• manage accounts and subscriptions
• process purchases and payments
• communicate with users
• provide customer support
• improve and develop the Services
• conduct analytics and research
• maintain security and prevent misuse
• comply with legal and regulatory obligations

We may also use anonymised or aggregated information for research, analytics and business improvement purposes.

AI and automated processing

Genefluence may use automated systems, algorithms and machine-learning technologies to help:

• interpret skincare-related traits
• personalise recommendations
• support Matching experiences
• improve app functionality
• analyse service performance

These systems are designed to support skincare personalisation and related experiences.

Genefluence does not use these systems to make medical, insurance, employment or financial decisions about users.

Legal basis for processing

Depending on the circumstances, we process personal information based on:

• user consent
• contractual necessity
• legitimate interests
• legal obligations

Where genetic or sensitive personal information is processed, we rely on explicit consent where required by law.

Users may withdraw consent in certain circumstances, although this may affect the availability of some Services.

Sharing information with third parties

We may share information with trusted service providers and partners who support the operation of the Services, including providers of:

• cloud hosting
• infrastructure
• analytics
• customer support
• marketing services
• payment processing
• technical maintenance
• app functionality

We may also share information:

• where required by law
• to protect rights, safety or security
• in connection with a business transfer or acquisition
• with regulators or law enforcement where legally required

We do not sell identifiable genetic information.

International transfers

Some service providers or infrastructure providers may process information outside the United Kingdom or European Economic Area.

Where personal information is transferred internationally, we take steps designed to ensure appropriate safeguards are in place in accordance with applicable data protection laws.

Security and protection of information

Genefluence uses technical and organisational measures designed to protect personal information, including:

• encryption
• access controls
• authentication measures
• restricted staff access
• confidentiality obligations
• secure infrastructure providers

We are committed to minimising the amount of genetic information retained as part of the Services.

No digital system can be guaranteed to be completely secure, and users should take reasonable steps to protect their own account credentials.

Data retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to:

• provide the Services
• comply with legal obligations
• resolve disputes
• enforce agreements
• maintain legitimate business records

Account-related information may be deleted or anonymised following account closure, subject to legal and operational requirements.

Your rights

Depending on applicable law, users may have rights to:

• access personal information
• correct inaccurate information
• request deletion
• restrict processing
• object to certain processing
• withdraw consent
• request portability of certain information

Requests may be submitted using the contact details provided above.

Children’s privacy

Users under the age of 16 require consent from a parent or legal guardian to participate in DNA testing services.

Third-party services

The Services may contain links to third-party websites, platforms or services. Genefluence is not responsible for the privacy practices of third parties.

Users should review the privacy policies of any external services they access.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Updated versions will be published through the Services together with the revised effective date.

Last updated: May 2026