Phaeno Privacy Policy

Last Modified: November 21, 2025

Introduction

Phaeno Inc. (“Company”, “we”, “us”, or “our”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the websites www.phaenobiotech.com, portal.phaenobiotech.com, or any other phaenobiotech.com domains (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website;
  • In email, text, and other electronic messages between you and this Website;
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by us offline, through any other means, or by any third party (including our affiliates and subsidiaries).

By accessing or using the Website, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy”).

Important Note – Nature of Our Service

Phaeno is a research and bioinformatics analysis platform only. We do not accept clinical specimens, diagnostic samples, or any data containing protected health information (PHI), patient identifiers, or direct identifiers of research participants. Users are solely responsible for ensuring that any human-origin genetic or genomic data uploaded to the platform has been appropriately de-identified or anonymized in accordance with applicable laws, regulations, and ethical guidelines before upload. We process all uploaded data as non-clinical research data.

Children Under the Age of 13

Our Website is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we learn we have collected such information, we will delete it promptly.

Information We Collect and How We Collect It

We collect:

  • Personal information (e.g., name, work address, email, phone);
  • Non-identifying information (e.g., employer, job title);

We collect this information directly from you, and occasionally from third-party business partners.

Automatic Data Collection Technologies

We use cookies, web storage, web beacons to improve the Website and your experience. You may disable cookies in your browser, but some features may stop working.

How We Use Your Information

We use your information to:

  • Provide and operate the Website and our services;
  • Perform analytics, troubleshooting, and system monitoring;
  • Communicate with you about your account and our services;
  • Fulfill contractual obligations;
  • Comply with legal requirements; and
  • With your consent, send you marketing communications about our own or selected third-party offerings.
Data Retention

We retain your data only as long as necessary to provide our services, fulfill the purposes in this policy, meet legal obligations, resolve disputes, and enforce agreements. You may request deletion at any time. See our Data Policies for more details.

How We Share and Disclose Your Information

We do not sell personal information. We may share personal information:

  • With your explicit consent;
  • With affiliates, contractors, and service providers bound by confidentiality;
  • In connection with a merger, sale of assets, or similar transaction;
  • To comply with law or legal process;
  • To protect rights, property, or safety.

Aggregated or de-identified data may be shared without restriction.

International Data Transfers

Data may be transferred to and processed in the United States and other countries. For transfers from the EEA, UK, or Switzerland, we rely on Standard Contractual Clauses approved by the European Commission or other lawful mechanisms.

Lawful Basis for Processing (EEA, UK, Switzerland)
PurposeCategories of DataLawful Basis (Art. 6 GDPR)Special-Category Data (Art. 9 GDPR)
Providing the Website and servicesAccount data, uploaded research data, usage dataPerformance of a contractNot applicable
(no clinical or identifiable health data)
Analytics and website improvementUsage data, cookies, IP addressLegitimate interestsNot applicable
Marketing communicationsName, email addressConsentNot applicable
Legal compliance and safetyAny relevant dataLegal obligation or legitimate interestsNot applicable
Your Privacy Rights

Depending on your location, you may have the right to access, correct, delete, restrict, object to processing, or receive a portable copy of your personal information, and to withdraw consent.

U.S. Residents (California, Colorado, Virginia, Connecticut, etc.)

You have rights under CCPA/CPRA and similar state laws (right to know, delete, correct, opt-out of sale/sharing, limit sensitive PI use, non-discrimination). Exercise these rights by emailing info@phaenobiotech.com or using your account settings.

EEA, UK, and Switzerland Residents

You have the rights above under GDPR/UK GDPR and may lodge a complaint with your local supervisory authority.

Choices About How We Use and Disclose Your Information
  • Disable cookies in your browser settings;
  • Opt out of marketing emails via the unsubscribe link or by contacting us;
  • Opt out of third-party targeted advertising via NAI or your browser.
Data Security

We implement industry-standard measures (including encryption in transit and at rest, access controls, and regular assessments) to protect your information. However, no internet transmission is 100% secure.

Data Breach Notification

In the event of a personal data breach likely to result in risk to your rights, we will notify you and relevant authorities as required by law.

Changes to Our Privacy Policy

Material changes will be posted on this page and notified via email or a prominent notice on the Website. The “Last Modified” date reflects the current version.

Contact Information

For questions, rights requests, or to contact our Data Protection Officer:

Email: info@phaenobiotech.com
Mail: Phaeno Inc., 5270 California Avenue, Suite 300, Irvine, CA 92617, USA