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Privacy Policy

Last Updated: April 1st, 2026, effective April 15th, 2026

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This Privacy Policy describes how we process the information we collect about you when you use the Services. We define “Services” below, but it generally means the products and services that we offer to you.

Please carefully review this Privacy Policy and let us know if you have any questions or concerns. We encourage you to contact us, at any time, using the contact information at the end of this Privacy Policy.

Depending on how you use the Services, we may ask you to sign an informed consent form that describes certain aspects of the Services and asks for your consent to process your information as part of those Services. To the extent that there is a conflict between this Privacy Policy and an informed consent form that you have signed, the informed consent form will control.

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1. Key definitions

“Aggregate Information” is information about multiple individuals that we have combined so that no specific individual may be identified. Aggregate Information is not Personal Information because it cannot be used to identify you. For example, Aggregate Information may include a statement that “30% of our female users share a particular genetic trait,” without providing any data or testing results specific to any individual user.

“GENOMELINK” means Genomelink, Inc., which operates both the Genomelink™ and YourRoots™ brands and services. We will refer to GENOMELINK and YourRoots collectively as “we,” “us,” and “our” throughout this Privacy Policy. References to the “Services” include the products and services offered under both the Genomelink™ and YourRoots brands, including our websites at https://genomelink.io/ and https://yourroots.com.

“Cookie” is a text file that is placed on your hard disk by a web server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. Cookies cannot be used to run programs or deliver viruses to your computer. To learn more about Cookies, visit www.allaboutcookies.org.

“Data Collection Technologies” refer to Cookies, pixel tags, web beacons, and other technologies that we or third parties use on our websites and other digital services to collect information about your use of these services.

“De-Identified Data” is data that cannot be used to infer information about, or be linked to, an individual.

“Designated European Countries” means countries the European Economic Area, the United Kingdom, and Switzerland.

“DNA” stands for deoxyribonucleic acid, which is the molecule that contains your genetic information. Your DNA is what makes you uniquely you.

“Genetic Information” is any data concerning genetic material obtained from the analysis of your biological sample by us or by Third Party DNA services. Genetic Information also includes the fact that you have provided a biological sample or undergone genetic testing with us or any Third Party DNA Service, and any information derived from such testing. Genetic Information includes, but is not limited to, DNA, Raw Data and Traits.

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

“Raw Data” means information about your genotypes that is generated by Third Party DNA Services. Your Raw Data contains the “letters” (nucleotides A, C, G, T) that comprise DNA.

“Sensitive Information” is a subcategory of Personal Information under applicable data protection laws that may include, for example, your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic information, biometric information, and information concerning your health, sex life, or sexual orientation. Additional information on the types of Sensitive Information we may collect can be found in Section 2 below.

“Service” means the GenomelinkTM service, associated websites (http://genomelink.io and http://www.genomelink.io/) and mobile applications, and other ancillary or related services we offer from time to time.

“Third Party DNA Services” means companies and organizations not related to or operated by us that you may use to obtain DNA testing and results.

“Traits” means the characteristics or attributes that may be influenced by your DNA. Your Traits may include your preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. The traits we analyze as part of the Service are personal - not medical - in nature.

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2. Information we collect

Depending on how you interact with or use the Service, we may collect the following categories of Personal Information about you:

We may collect your Personal Information directly from you, such as when you register for a Genomelink account, provide us with certain electronic health record data, complete a family history questionnaire, survey or form, contribute to blogs and forums, or contact us with a question.

We may also collect your Personal Information from third party sources, such as Third Party DNA Services, social media platform providers, or your friends and family who refer our Service to you. The Personal Information we collect from these third parties sources typically depends on the privacy settings or permissions that you have communicated with these third parties or otherwise set on their platforms.

Finally, we may collect certain Personal Information automatically through the use of Data Collection Technologies. Please see Section 7 and our Cookie Policy for more details about our use of Cookies and other Data Collection Technologies.

Non-Personal Information. We may also collect information that cannot be used to identify you. This non-Personal Information may include Aggregate Information about our users’ browser types, device types, and pages clicked. We collect this non-Personal Information through server logs and Data Collection Technologies. We may associate this information with the Personal Information that we collect about you -- if we do, we will treat the combined information as Personal Information.

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3. Genetic Information

We collect your Genetic Information in the following ways:

We use your Genetic Information for the following purposes:

You may revoke your consent for the use of your Genetic Information at any time by submitting a request at https://privacy.genomelink.io/privacy-request.

We disclose your Genetic Information as follows:

Genomelink will not sell, lease, or rent your individual-level information to a third party for research purposes without your explicit consent. In addition, without your consent:

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4. How we use your Personal Information

In addition to the purposes for which we collect your Personal Information listed in Section 2 above, we may use your Personal Information for the following purposes:

If we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide us with the information when requested, we may not be able to perform the contract we have, or are trying to enter into, with you. We will inform you of any Personal Information we require from you and the consequences if you fail to provide it.

Special Categories: We only process Special Categories of Personal Information if you give us your explicit consent (such as through our informed consent), the processing is necessary to meet a legal or regulatory obligation, the processing is in connection with the establishment, exercise or defense of legal claims, or is otherwise expressly permitted by law. Special Categories of Personal Information includes information about your racial or ethnic origin, genetic data (such as Raw Data), and data concerning health, sex life, and sexual orientation.

Other Uses: Any other purposes for which we wish to use your Personal Information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you by amending this Privacy Policy in accordance with the Section 17.

Hints and AI-Generated Suggestions.

DNA Match.

Family Tree Data.

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5. When we share your Personal Information

We may share your Personal Information in the following circumstances:

Note: When we share your Personal Information with research partners, we do not have control over how those research partners use or disclose your Personal Information. We recommend that you review the privacy policies of the research partners and any other third party with whom you share, or ask us to share, your Personal Information.

DNA Match Sharing.

What We Share with Matches. When you participate in DNA Match, limited information about you may be shared with other participating users who share DNA with you. The specific information shared depends on your privacy settings and may include: your chosen display name or anonymous identifier, the amount of shared DNA (in centimorgans), the number of shared DNA segments, a predicted relationship range, and, if you have opted in, your ethnicity estimate and/or a link to your family tree.

What We Do Not Share. We will never share your raw genotype data, your email address, or your physical address with other users through DNA Match. You may adjust what information is visible to your matches at any time through your privacy settings. If you opt out of DNA Match, your information will be removed from all match lists.

Sharing Aggregate Information. We may share Aggregate Information with third parties or the general public for our marketing or research purposes. For example, we may provide Aggregate Information in commercial arrangements with our business partners so that they may develop new research or products. We may also provide Aggregate Information to advertisers so they may tailor marketing messages or advertisements to our general user demographics. Disclosures for these purposes will never contain your Personal Information.

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6. Viewing and correcting your Personal Information

You can log into your Genomelink account and view or amend the Personal Information associated with your account at any time. Please note that if you amend the Personal Information in your account, our servers may retain the old information as part of our logs and backups.

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7. Cookie Policy

We and our partners may collect, use, and disclose information about you and your device through Data Collection Technologies. For more information on our use of Data Collection Technologies, please see our Cookie Policy available here.

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8. Security

We maintain reasonable and appropriate safeguards designed to protect your Personally Information from unauthorized access, use, disclosure, alteration or destruction. For example, we limit our collection and use of your Personal Information to the extent necessary to provide you with the Service. However, we cannot guarantee the security of our systems or your Personal Information, and we encourage you to take reasonable precautions to safeguard your Personal Data.

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9. Data retention

We will keep your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including any legal, professional, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, whether we can achieve those purposes through other means, and all applicable legal requirements.

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10. Users outside of the U.S.

We are committed to complying with this Privacy Policy and the data protection laws, including those outside of the United States, that apply to our collection and use of your Personal Information. We are located in the U.S. and may use facilities in the United States and other countries. When you provide us with your Personal Information or use the Service, we will process and store your Personal Information in the United States and such other countries where we have facilities. We recognize that the laws in the United States and such other countries may be different and, in some cases, not as protective as the laws where you are located. By providing us with your Personal Information or using the Service, you acknowledge that your Personal Information will be transferred to and processed where we operate.

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11. California privacy rights

If you are a resident of California, we are providing the following information to you in accordance with the California Consumer Privacy Act (“CCPA”).

This Privacy Policy describes our practices over the last 12 months with respect to categories of information we collect, the sources of that information, and how we have disclosed it. Specifically, in the last 12 months, we have disclosed each category of your Personal Information as follows:

It is not our practice to sell Personal Information for money. However, we understand that under the CCPA, the use of certain types of Data Collection Technologies may be considered a “sale” or “sharing” of Personal Information for targeted advertising. If you have not opted out from the use of certain Data Collection Technologies within the preceding 12 months, your Internet or other electronic network activity information may have been used to serve you targeted advertisements and “sold” or “shared” with providers of Cookies, advertisers, and advertising platforms and networks. We do not knowingly sell or share Personal Information about children under 16 years old.

As a California resident, you have the following privacy rights under the CCPA:

You may exercise your right to know, your right to correction, and your right to deletion twice a year free of charge. To exercise your right to know, your right to correction, or your right to deletion, please submit a request at https://privacy.genomelink.io/privacy-request.

We will take steps to verify your identity before processing your request to know, request to correct, or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have an account with us, we will use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you to verify your identity, such as your name and email address. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses unless you initially provided the information for another purpose.

You may use an authorized agent to submit rights requests. When we verify your agent’s request, we may verify your identity and request a signed document from your agent that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

We only use and disclose Sensitive personal information to provide the Service and for other purposes specified under California law, including to improve the Service and for safety and security purposes.

Notice of financial incentive. We may offer programs or benefits in exchange for your Personal Information, such as a free trial for the Service or enhanced reporting about your traits or family members. The categories of Personal Information we collect will depend on the program or benefit but may include Identifiers, Demographic information and other protected classifications, Customer records, Internet and other electronic network activity information, Commercial information, Inferences, and Sensitive personal information. Our good faith estimate of the value of your Personal Information is the value of the benefit that we give you, which we have calculated by evaluating our expenses in offering the benefit. Your participation in these programs and benefits is optional and you will not be enrolled unless you choose to opt-in. You may withdraw from the program or benefit at any time by contacting us at info@genomelink.io.

Shine the Light – Third Party Marketing. California law permits individual California residents to request certain information regarding our disclosure of certain categories of Personal Information to third parties for those third parties’ direct marketing purposes. To make such a request, please contact us using the information at the end of this Privacy Policy. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the email or mailing addresses specified below.

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12. California Genetic Information Privacy Act

If you are a resident of California, you may be entitled to the following rights regarding your Genetic Information:

To exercise these rights, you can submit a request at https://privacy.genomelink.io/privacy-request.

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13. Nevada Residents

Pursuant to Nevada law, you may direct a business that operates an internet website not to sell certain Personal Information a business has collected or will collect about you. We do not sell your Personal Information pursuant to Nevada law. For more information about how we handle and share your Personal Information or your rights under Nevada law, contact us at info@genomelink.io.

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13.5 Additional State Genetic Privacy Rights

In addition to California and Nevada, a number of U.S. states have enacted genetic privacy laws that may provide you with additional rights regarding your Genetic Information. These states currently include Alaska, Alabama, Arizona, Florida, Illinois, Indiana, Kentucky, Maryland, Montana, South Dakota, Tennessee, Texas, Utah, Virginia, and Wyoming. We are committed to complying with all applicable state genetic privacy statutes. Across these states, our commitments include: (a) we will not collect, retain, or disclose your Genetic Information without your express consent, which must be separate and specific for each purpose beyond providing the Service; (b) we will not share your Genetic Information with insurance companies, employers, or risk assessment businesses under any circumstances, regardless of consent; (c) we will not sell, lease, or rent your Genetic Information; (d) Maryland residents are not eligible to participate in the DNAsolves forensic genealogy program or any other optional third-party sharing program, as the Maryland Online Data Privacy Act restricts genetic data sharing to what is strictly necessary to provide the Service; (e) we will not store your Genetic Information in any country designated as a foreign adversary by the U.S. government; and (f) you have the right to access, correct, delete, and request destruction of your Genetic Information and to revoke your consent at any time. To exercise your rights under applicable state genetic privacy laws, please submit a request at https://privacy.genomelink.io/privacy-request.

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14. Rights for individuals in the EEA

If you are located in the European Economic Area and we maintain your Personal Information, you have the following additional rights (under the European Union’s General Data Protection Regulation (the “GDPR”) with regard to your Personal Information:

Please note that if you decide to exercise some of your rights, we may be unable to provide you with certain services, or you may not be able to use or take full advantage of the services we offer. We may charge you a reasonable fee if you request additional copies of your Personal Information or make other requests that are manifestly unfounded or excessive. If we are unable to honor your request, or before we charge a fee, we will let you know why.

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15. Children’s privacy

Our services are not directed to or intended for use by children. If we learn that we have received Personal Information directly from a child without his or her parent or legal guardian’s verified consent (where required by law), we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our services. Subsequently, we will delete such Personal Information.

DNA Match and Minors.

Age Requirement. Users must be at least 18 years of age to independently enable DNA Match features.

Guardian-Managed Accounts. If a parent or legal guardian manages a minor’s account and wishes to enable DNA Match on the minor’s behalf, the guardian must provide explicit consent. When DNA Match is enabled for a minor’s account, the minor’s identity (name, profile details) will not be displayed to other users’ match lists. All match interactions, including messaging, will be managed exclusively through the guardian’s account.

Children Under 13. We do not knowingly collect or process Genetic Information from children under 13 years of age.

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16. Third party websites and services

When interacting with us, you may come across links or references to third party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies and terms of use. This Privacy Policy does not apply to any Personal Information that you provide to a third party website or service. We recommend that you read the privacy policy that applies to that third party website or service. A link or reference to a third party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

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17. Effective date; changes

The last updated and effective date of this Privacy Policy is posted at the top of this page. We may update this Privacy Policy from time to time to reflect changes in our practices, our industry, or applicable laws. When we make material changes to this Privacy Policy, we will give you advance notice by posting an alert through the Service or by sending you an email to the email address we have on file. The amended Privacy Policy will apply on a go-forward basis to the Personal Information we already collected about you, as well as any Personal Information we may collect in the future. If you disagree with any changes, please let us know by contacting us using the information at the end of this Privacy Policy.

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18. Transparency Reporting and Law Enforcement Disclosure Policy

We are committed to transparency about how we handle law enforcement and government requests for user data. We maintain a separate Law Enforcement and Government Agency Disclosure Policy, available at genomelink.io/legal/law-enforcement-policy, which details our procedures for responding to legal process. We will publish an annual Transparency Report disclosing the number, type, jurisdiction, and outcome of all law enforcement requests received during the prior calendar year. We require a valid search warrant for all requests for Genetic Information. We will challenge overbroad or otherwise improper requests. We will notify affected users to the extent permitted by applicable law.

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