Privacy Policy

Genomic Commons is a nonprofit project that provides free educational tools for calculating and comparing polygenic scores. In this Policy, Genomic Commons, the Organization, we, and us mean the nonprofit organization or group operating this website and its related genomic-analysis service.

This Policy applies to our website, accounts, file-upload and analysis features, support communications, and related services (collectively, the Service). It does not govern an independent website or service that we merely link to.

We operate for nonprofit, educational purposes. We do not charge for the Service, sell personal information, or use genomic information for advertising. Nonprofit status does not reduce our commitment to protecting your information.

Depending on how you use the Service, we collect:

• Account information: name, email address, profile image, email-verification status, authentication-provider identifiers, session information, and account timestamps.
• Uploaded genomic information: raw genotype files, file name, file type, file size, a file hash used to identify duplicate uploads, sample nickname, and identifiers connecting a file to your account and processing job.
• Generated information: polygenic scores, percentiles, inferred predispositions and disease-risk indicators, job status, analysis outputs, and the trait weights or comparison choices you select.
• Technical information: IP address, device and browser information, request timestamps, authentication and security events, cookie identifiers, and server or error logs generated when you use the Service.
• Communications: information you include when contacting us about support, privacy, security, or other questions.

Raw genomic files and the results inferred from them may constitute genetic, health, biometric, consumer-health, or other specially protected information under applicable law.

Most information comes directly from you, from a person authorized to act for the individual whose data is uploaded, or from an authentication provider you choose. We generate scores and inferences by applying published polygenic-score models and reference data to uploaded genotype information. Hosting, authentication, and security providers automatically generate limited technical records.

We use personal information only as reasonably necessary to:

• create and secure your account and authenticate sign-ins;
• receive genomic files, perform the analysis you request, display and compare results, and enable exports;
• detect duplicate files, prevent abuse, troubleshoot failures, maintain availability, and protect users and infrastructure;
• respond to support, access, correction, deletion, consent-withdrawal, and complaint requests;
• comply with law, enforce our Terms of Use, and establish or defend legal claims; and
• produce genuinely de-identified and aggregated operational statistics that cannot reasonably be linked back to an individual.

We do not use identifiable genomic information to make decisions about employment, insurance, credit, housing, education, or eligibility for services.

Where consent is required, we ask for affirmative consent before accepting a genomic upload. By uploading, you authorize us and our service providers to read, temporarily store, transfer, and analyze the file to provide the requested results. You may withdraw consent prospectively and request deletion, although withdrawal does not invalidate processing already lawfully completed.

Where laws such as the GDPR apply, we rely on your explicit consent to process genetic and health information; performance of the service you requested for necessary account and service operations; our legitimate interests in security, abuse prevention, reliability, and legal defense; and legal obligations where applicable. We do not rely on consent for a use when the law provides another appropriate basis.

Consent for the core analysis does not authorize research, publication, advertising, sale, or unrelated model training. Any future optional research use would require a separate, specific opt-in and any additional ethical or legal approvals that apply.

1. Your browser uploads the raw file over HTTPS to temporary object storage.
2. Our application retrieves that file and sends it over HTTPS to our separate genomic-analysis service, which is hosted in Germany. The analysis service and authorized operators can technically read the file while processing it. The Service is not end-to-end encrypted.
3. The analysis service creates intermediate files and score results. Our application receives and stores results associated with your account.
4. After a successful handoff, the application normally requests deletion of the raw object from temporary storage. Processing copies and outputs remain only for the operational periods described below unless an earlier valid deletion request is completed.

Please do not upload a file unless you understand and accept this processing flow.

We disclose information only to volunteers, contractors, and service providers that need it for an authorized purpose, or when legally required. Current categories include:

• Hosting and delivery: Vercel and infrastructure providers used to deliver the website and server functions.
• Object storage and queues: Amazon Web Services for temporary file transfer and processing coordination.
• Database services: Neon or a successor database host for accounts, job records, and derived results.
• Analysis infrastructure: the Genomic Commons/Polygen analysis service hosted in Germany and the infrastructure provider operating that server.
• Authentication and email: Google, if you choose Google sign-in, and Resend for email sign-in links and transactional messages.
• Professional and legal support: advisers, incident responders, auditors, or authorities when reasonably necessary and legally permitted.

Providers may process information only to supply services to us under their applicable terms and safeguards. We may also disclose information to prevent serious harm, investigate abuse or security incidents, comply with valid legal process, or protect legal rights. We do not sell or rent personal or genomic information and do not share it for cross-context behavioural advertising.

Our primary genomic-analysis server is hosted in Germany. Other providers may process account, storage, authentication, database, email, and technical information in Canada, the United States, the European Economic Area, or other countries where they operate. Those countries may have privacy laws different from those where you live.

Where required, we use appropriate contractual or other lawful transfer safeguards. By requesting the Service and providing valid consent, you understand that the processing necessary to complete your request involves these locations. We do not claim that every item of data remains exclusively in Germany.

We keep identifiable information only for as long as reasonably needed for the purposes described in this Policy, subject to technical, security, legal, and backup requirements. Our expected operational schedule is:

• temporary raw files on the analysis server: normally no longer than 24 hours;
• intermediate processing files: normally no longer than 7 days;
• analysis-server job outputs: normally no longer than 30 days;
• account records and derived scores in the website database: until you delete the applicable record or account, or until the information is no longer reasonably needed to operate the Service;
• authentication, security, and error logs: for a limited period reasonably necessary for security, reliability, and legal compliance; and
• backups: until overwritten or expired through the applicable provider's backup cycle.

Deletion is a process, not a guarantee of instantaneous erasure from every system. When you delete a record or account, we delete active database records and request cleanup from storage and analysis systems. A failed or delayed provider cleanup, an unexpired upload URL, legal preservation duty, security record, or backup cycle may temporarily delay complete erasure. We will take reasonable follow-up steps when we learn that cleanup failed.

Do not rely on the Service as the only copy of any data or result. Once deletion is completed, information may not be recoverable.

We use safeguards designed for the sensitivity of genomic information, including authenticated account access, HTTPS transmission, scoped storage access, access controls, and deletion workflows. No system is perfectly secure. We cannot guarantee that unauthorized access, loss, misuse, or disclosure will never occur, and your use of an internet-based genomic service carries residual risk.

You are responsible for protecting access to your email and authentication account, signing out on shared devices, and promptly reporting suspected unauthorized access to us.

This section supplies additional disclosures for laws governing consumer health data, including the Washington My Health My Data Act where it applies.

• Categories collected: raw genetic data, inferred genetic traits and health risks, disease-related polygenic scores, account identifiers linked to that information, and technical records necessary to provide and secure the analysis.
• Sources: you or an authorized submitter; authentication providers; and inferences generated by our analysis.
• Purposes: providing, securing, troubleshooting, and improving the reliability of the analysis you request; responding to your requests; and complying with law.
• Sharing: the hosting, storage, database, authentication, email, analysis, security, and professional-support providers described in Section 7. We have no affiliates with which we share consumer health data for their independent use.

We do not sell consumer health data. We obtain affirmative consent before collecting genomic information for analysis and before sharing it when consent is legally required. We will seek new consent before using consumer health data for a materially different purpose not disclosed when it was collected.

You may ask to confirm whether we collect or share your consumer health data, obtain access to it, withdraw consent, or request deletion by using the in-product deletion controls or emailing us. If we deny a request, you may appeal by replying with the subject Privacy Appeal; a person not involved in the original decision will review it where reasonably possible.

Subject to applicable law and appropriate identity verification, you may have rights to:

• know whether and why we process your information and obtain access to it;
• correct inaccurate account information;
• delete a genomic record or your account;
• receive certain information in a portable form;
• withdraw consent, object to or restrict certain processing, or limit use of sensitive information;
• appeal a denied request where applicable; and
• complain to the privacy or data-protection authority where you live.

We voluntarily aim to offer reasonable access and deletion controls to all users, even where a particular statutory right does not apply. Rights may be limited where an exception applies, where fulfilling a request would expose another person's information, or where we must retain information for security or legal reasons. We will not unlawfully discriminate against you for exercising a privacy right.

The Service is intended only for adults who can give legally valid consent. We do not knowingly permit a minor to create an account or independently upload genomic data. Contact us if you believe a minor's information was submitted without valid authority.

You may upload another person's or an embryo's genomic information only if you are legally authorized to do so and have obtained every consent required by applicable law. Because one person's genome can reveal information about biological relatives, you should consider those privacy implications before uploading. We may request evidence of authority, suspend processing, or delete disputed data.

We use cookies and comparable technologies necessary for sign-in, session security, preferences, load management, and abuse prevention. These technologies do not currently serve behavioural advertising. Necessary cookies cannot always be disabled without making account features unavailable.

If we introduce non-essential analytics, personalization, or advertising technologies, we will update this Policy and obtain opt-in consent where required before activating them. You can also control cookies through your browser, although doing so may break sign-in or other features.

EEA, United Kingdom, and Switzerland: genetic and health data receive special protection. Where applicable, you may withdraw consent, request access, correction, erasure, portability, restriction, or objection, and complain to your local supervisory authority. We will identify an EU/UK representative or data-protection officer if the law requires one.

Canada: you may request access or correction and challenge our compliance through the contact below. Information may be processed outside your province or Canada and may be accessible to foreign authorities under local law.

United States: genetic information and health inferences may be sensitive personal or consumer health data. Applicable state rights supplement the controls described above. We do not sell personal information or use it for targeted advertising.

Nothing in this Policy limits a mandatory right or remedy that cannot lawfully be waived.

We may update this Policy as the nonprofit Service, providers, or law changes. We will post the revised version and update the date above. If a change materially expands how we use or disclose genomic information, we will provide prominent notice and seek new consent where required.

For privacy questions, rights requests, complaints, or suspected security incidents, email privacy@genomic-commons.me. Please do not send genomic files by email.

We will verify and respond to requests within the period required by applicable law. You may also complain to the privacy or data-protection authority in your jurisdiction.