BioMarker CoachBioMarker Coach

Privacy Policy

Effective Date: October 26, 2026 · Last Updated: October 26, 2026

15751608 Canada Inc., operating as "BioMarker Coach" ("BioMarker Coach," "we," "us," or "our"), respects your privacy and is committed to handling your personal information and health information responsibly.

BioMarker Coach provides an application and related website services that analyze user-uploaded blood-test results against BioMarker Coach's proprietary nutrition knowledge base, developed from professional nutrition education, peer-reviewed scientific literature, established nutrition resources, and evidence-informed nutrition principles, using artificial intelligence to generate personalized educational reports (the "Service").

This Privacy Policy explains what information we collect, how we collect and use it, how your information is processed, when and with whom we share it, how long we retain it, where it is processed, the choices and privacy rights available to you, and how you can contact us about our privacy practices.

This Privacy Policy should be read together with our Terms of Service, Informed Consent for Processing Blood-Test and Health Information, Medical & Nutrition Disclaimer, AI-Generated Content Disclaimer, Cookie Policy, Account & Data-Deletion Policy and Credit Package, Cancellation and Refund Terms.

1. Scope and Availability

1.1.

This Privacy Policy applies to information collected through the BioMarker Coach website, application, and related services, subject to the jurisdiction-specific provisions below.

1.2.

The BioMarker Coach Service is currently offered only to eligible residents of Canada, excluding Quebec, and the United States.

1.3.

Our public marketing website, social-media pages, and other publicly accessible content may be viewed by individuals worldwide. However, viewing our public content does not mean that BioMarker Coach offers or provides the Service in every jurisdiction.

1.4.

Account creation is restricted by geographic eligibility requirements. Users must select their province or state during account creation, and account creation is blocked for users who select Quebec or indicate that they are outside Canada and the United States. BioMarker Coach is not currently available to residents of Quebec because the Company has not yet completed the additional legal, operational, and French-language requirements applicable to that market.

2. Information We Collect

2.1.

Account and Authentication Information

2.1.1.

When you create a BioMarker Coach account, we collect information necessary to establish and authenticate your account, including:

(a)

your email address;

(b)

your name, which you provide when creating your account;

(c)

authentication credentials associated with your BioMarker Coach account;

(d)

your selected province or state;

(e)

your account or user identifier; and

(f)

where you choose to use Google Sign-In on the BioMarker Coach website, the profile information provided by Google, such as your Google profile identifier and associated account information.

2.1.2.

If you sign in using Google on the BioMarker Coach website, Google provides us with the information described above. We do not receive or store your Google password. Google Sign-In is not used for account creation or authentication in the iOS or Android applications.

2.2.

Health and Laboratory Information

2.2.1.

When you use the Service to generate a report, we collect and process the following laboratory and report-related information: blood-test reports or other laboratory documents that you upload;

(a)

photographs of laboratory reports captured through your device camera;

(b)

PDF or image files containing laboratory results;

(c)

laboratory marker names and values extracted from uploaded documents;

(d)

generated health-related observations, patterns, trends, nutrition insights, urgency or practitioner-referral flags, dietary and lifestyle suggestions, supplement-related educational information, personalized meal plans, action lists, monitoring suggestions, and other report content generated from the information you provide; and

(e)

report-specific questions and answers submitted through the report-chat feature, together with information from the relevant report and other information used to generate an answer, as applicable to the operation of that feature.

2.2.2.

The health questionnaire is used to improve the personalization of your report. The health questionnaire may include the following information used to personalize your report:

(a)

age;

(b)

sex;

(c)

height and weight;

(d)

pregnancy or postpartum status;

(e)

menopause status and, where applicable, menstrual cycle timing;

(f)

symptoms, health concerns, or other concerns reported by you;

(g)

diagnosed medical conditions, as reported by you;

(h)

medications and supplements;

(i)

whether you are currently experiencing digestive or inflammatory symptoms, together with any optional description you provide;

(j)

whether you are currently following a specific diet or nutrition protocol for a health condition, together with any optional description you provide;

(k)

dietary information, food allergies, and dietary avoidances; and

(l)

exercise, sleep, and stress information.

2.2.3.

Questionnaire Storage. Your health questionnaire answers are stored in your BioMarker Coach account on our systems, including Supabase, after you provide the required consent for the profile to be saved. Your profile is linked to your account and can sync between the website and the application. A temporary copy of the profile may also be stored locally on your device to support the Service. When you generate a report, BioMarker Coach saves a snapshot of the questionnaire answers used for that report together with the report, so the report can be understood and accessed in the context of the information on which it was based. The profile and report-specific snapshots are subject to the retention and deletion practices described in this Privacy Policy and our Account & Data-Deletion Policy.

2.2.4.

Marker values used by the Service come from an uploaded laboratory document or information provided through the questionnaire. There is currently no separate manual marker-entry feature.

2.2.5.

This information is sensitive information and may constitute consumer health data or other specially protected information under applicable privacy laws, including applicable U.S. state consumer-health-data laws.

2.2.6.

When you upload a laboratory report as a PDF, photograph, or other supported file, BioMarker Coach processes the original file to extract relevant laboratory information and generate your report. The original uploaded file is not retained by BioMarker Coach after processing. However, BioMarker Coach may retain the file name and a file fingerprint for duplicate-detection purposes, together with extracted laboratory marker names and values, relevant questionnaire information, and the generated report, as described in this Privacy Policy. The original file may be transmitted to third-party service providers, including Anthropic, for processing on behalf of BioMarker Coach. Such processing does not mean that the original uploaded file is retained by BioMarker Coach after processing.

2.2.7.

Medication-Aware Supplement Safety. BioMarker Coach may use the medication name you provide in your profile to identify the medication’s active ingredient and check for known safety or administration issues between that medication and a supplement that the Service is about to suggest.

2.2.8.

AI-Generated Reports and Report History. We collect and retain the personalized reports generated by the Service from your laboratory information and the questionnaire information used for that report, including a snapshot of the relevant questionnaire answers, so that you can access your report history and review prior reports over time.

2.2.9.

Reports may include explanations of individual laboratory markers, comparisons between laboratory reference ranges and BioMarker Coach's target ranges, identified or flagged patterns, trends, nutrition insights, urgency tiers or practitioner-referral flags, dietary and lifestyle suggestions, supplement-related educational information where supported by the BioMarker Coach knowledge base, monitoring suggestions, visual summaries of relevant markers, personalized meal plans, suggested additional laboratory panels, and categorized action steps.

2.2.10.

Generated observations and recommendations are inferences or educational outputs based on the information you provide and BioMarker Coach's proprietary nutrition knowledge base. They may be inaccurate, incomplete, or unsuitable for your individual circumstances and are not medical diagnoses, clinical determinations, or individualized medical treatment. Please review the Medical & Nutrition Disclaimer and AI-Generated Content Disclaimer.

2.2.11.

BioMarker Coach does not continuously monitor your health, laboratory values, symptoms, medications, or other health information. The Service processes information submitted through the applicable features and does not independently detect changes in your health between submissions.

2.3.

Report Chat

2.3.1.

Where the report-chat feature is available, you may ask follow-up questions about a specific generated report.

2.3.2.

To provide this feature, BioMarker Coach may process your question together with the information necessary to answer it, which may include the relevant generated report, extracted laboratory information, relevant questionnaire information, and other context associated with that report.

2.3.3.

Report-chat interactions may involve artificial intelligence processing through Anthropic’s Claude API. Questions submitted through report chat, together with the relevant report information and other context necessary to respond, may be transmitted to Anthropic for processing on behalf of BioMarker Coach. Report-chat questions and answers may also be retained with the relevant report or associated account data, subject to the retention and deletion practices described in this Privacy Policy and our Account & Data-Deletion Policy.

2.3.4.

BioMarker Coach does not use report-chat content for advertising purposes. Where product analytics are used, they are intended to collect limited usage information rather than the text of your health-related questions or the underlying laboratory and questionnaire information. However, BioMarker Coach does not represent that every technical log, error record, support record, or other operational record associated with report chat will be completely free of information relating to the feature or interaction.

2.3.5.

Report-chat content and related information are subject to the applicable retention and deletion practices described in this Privacy Policy and our Account & Data-Deletion Policy.

2.4.

Communications and Support Information

2.4.1.

If you contact us, including by email, we may collect the information contained in your communication, including your email address and the contents of your message. Our business email services are provided by Zoho Corporation.

2.4.2.

Email and support communications may not provide the same safeguards as the authenticated BioMarker Coach Service. You should not send laboratory reports, laboratory values, medical records, symptoms, medication information, or other sensitive health information by email unless BioMarker Coach specifically requests it through an appropriate secure process.

2.5.

Credit Package and Transaction Information

2.5.1.

If you purchase a credit package through our website, Stripe processes your payment card information directly. We do not receive or store your full payment card number. We receive limited billing and transaction information necessary to provide purchased credits, manage your account, and maintain appropriate business records.

2.5.2.

If you purchase a credit package through the Apple App Store or Google Play, Apple or Google processes your payment directly through its own in-app purchase system. RevenueCat is used to manage and validate in-app purchases and related entitlements. RevenueCat may receive your internal BioMarker Coach account identifier and applicable purchase or transaction details, but does not receive your health information. BioMarker Coach receives information necessary to confirm the purchase and provide the corresponding credits. The current in-app purchase model consists of one-time credit packages and does not include recurring Premium subscriptions or automatic subscription renewals.

2.5.3.

Gift Purchases. If you purchase a gift, the purchaser may provide the recipient’s email address so that we can deliver the gift code and related delivery communications. The recipient is not automatically registered for an account and must create their own account to redeem the gift. The purchaser will not receive the recipient’s health information, reports, or analysis results. The recipient’s email address may be processed by our payment, email-delivery, hosting, or fraud-prevention providers, and will not be used for marketing communications unless the recipient separately provides any consent required by applicable law.

2.5.4.

Promotional Codes. Where BioMarker Coach issues promotional codes for credits, we may process information necessary to issue, redeem, validate, and administer those codes, including the code, its redemption status, the account that redeems it, and any applicable expiry date or usage limit. Each promotional code may be redeemed once per account and may be subject to a deadline or maximum number of redemptions. Promotional credits have no cash value, are non-refundable and non-transferable, and are forfeited when the associated account is deleted, subject to applicable law and the Credit Package, Cancellation and Refund Terms.

2.6.

Technical and Usage Information. We automatically collect certain technical information necessary to operate, secure, and troubleshoot the Service, which may include IP address, browser or device type, basic error and diagnostic information, and other technical information generated through normal operation of the Service. IP addresses may be used transiently for request handling and security purposes and are not stored as a persistent user profile.

2.7.

Push Notification Information. If you use the native iOS or Android application and enable notifications, Firebase Cloud Messaging may provide us with a device push-notification token. We use this token to notify you when a report has finished processing. The push-notification token is a device identifier and is not itself health information. Firebase Cloud Messaging does not receive your health information for this notification function.

2.8.

Product Analytics and Feedback

2.8.1.

BioMarker Coach uses PostHog for limited product analytics and feedback functionality, only after you have given analytics consent through the cookie preferences on the website or the equivalent choice in the iOS and Android applications. If you decline or withdraw consent, PostHog is not loaded. The same web-based analytics integration may operate through the web application and the WebView used by the iOS and Android applications.

2.8.2.

PostHog may receive limited behavioral metadata associated with your account or device, such as feature usage, page or screen interactions, counts, durations, and whether an action occurred.

2.8.3.

Autocapture and session recording are disabled. BioMarker Coach does not intentionally send laboratory results, extracted marker names or values, questionnaire answers, report content, or report-chat question text to PostHog. Technical logs, error records, or other information generated by the Service may nevertheless contain limited information associated with the operation of the relevant feature.

2.8.4.

If you provide an optional feedback response, do not include laboratory results, medical information, or other sensitive health information in any open-text field.

2.9.

Referral Program Information. Where the Referral Program is available and you interact with a referral link or participate in the Program, BioMarker Coach may collect and process referral-related information, including the referral link or Referrer identifier, the date of the first referral-link visit, registration date, the account associated with the referral, and information about the first qualifying purchase, such as the transaction identifier, purchase date, and package purchased. This information is used to attribute referrals, determine eligibility, verify qualifying purchases, administer referral credits, prevent fraud or abuse, and maintain records of the Program. Referral tracking does not provide the Referrer with access to the referred customer’s health information, reports, or purchase details.

3. How We Collect Information

3.1.

We collect information directly from you when you create an account; through Google when you choose Google Sign-In on the website; when you complete or update the BioMarker Coach health questionnaire and provide the required consent for your profile to be saved; when you upload a blood-test report or laboratory document; when you use features of the Service; when you purchase or manage credit packages; when you contact us; when you enable push notifications; through technical information generated when you use the Service; through product analytics as described above; and through our public marketing website where cookies and similar technologies are used, as described in our Cookie Policy.

3.2.

Before laboratory information or questionnaire information is transmitted for analysis, you must provide the affirmative consent requested through the applicable in-app consent notice. Consent is obtained through an unchecked-by-default checkbox and must be actively provided before the analysis process can proceed. The consent record may include your user identifier, the document or policy version referenced, and a server-generated timestamp. The consent record does not duplicate the underlying health information.

4. How We Use Your Information

4.1.

Providing the Service. We use your information to create and maintain your account; save, store, and synchronize your health questionnaire profile between the website and application after you provide the required consent; authenticate your identity and provide account access; process uploaded laboratory information and health questionnaire information; extract laboratory marker values from uploaded documents; generate personalized educational reports; provide report-specific AI-assisted question-and-answer functionality; maintain your report history; allow you to view and compare previous reports, export or share reports; provide relevant meal-plan and nutrition information; and provide other features of the Service.

4.2.

Customer Support. We use information you provide to respond to support requests, troubleshoot issues, investigate reported errors, and communicate with you about your account or use of the Service.

4.3.

Payments and Account Entitlements. We use limited payment and transaction information to process and administer purchases, confirm purchases, provide purchased credits and other applicable entitlements, manage your account, and maintain necessary billing records.

4.4.

Notifications. Where you have enabled push notifications, we use your device token to notify you when your report has finished processing.

4.5.

Security and Fraud Prevention. We may use technical and account information to detect, prevent, investigate, and respond to unauthorized access, fraud, abuse, security incidents, misuse of the Service, and other activity that threatens the security or integrity of the Service.

4.6.

Legal and Regulatory Compliance. We may use and disclose information where reasonably necessary to comply with applicable legal obligations, regulatory requirements, lawful requests, or legal processes.

4.7.

Communications and Marketing. We may communicate with you regarding your account, the Service, security or operational matters, changes to our policies or terms, and product updates or marketing communications where permitted by applicable law and, where required, where you have provided the required separate consent. Marketing consent is separate from consent to the processing of health information and is not intended to be bundled with or inferred from health-information consent. You may withdraw marketing consent through the mechanism provided in the relevant communication or by contacting us.

4.8.

Referral Program Administration. Where the Referral Program is available, we use referral-related information to attribute registrations to referral links, verify qualifying purchases, administer referral credits, prevent fraud and abuse, and maintain appropriate Program records.

5. Consent and Legal Bases for Processing

5.1.

Health Information

5.1.1.

Because BioMarker Coach processes sensitive health and laboratory information, we require affirmative consent before you upload laboratory information or submit health information for processing. The relevant consent is presented through a required, unchecked-by-default consent mechanism. You must actively select the consent checkbox before the applicable upload or submission can proceed.

5.1.2.

Consent is obtained separately for each new analysis submission. The consent mechanism presented at the point of analysis refers to the laboratory information and questionnaire information submitted together for that analysis. The resulting consent record is maintained separately from the underlying health information and may include the user identifier, applicable document or policy version, and timestamp.

5.2.

Canadian Users. For users in Canada, BioMarker Coach generally relies on meaningful consent for the collection, use, and disclosure of sensitive health information. Where permitted by applicable Canadian privacy law, BioMarker Coach may also collect, use, or disclose information without consent for limited purposes permitted by law, including security, fraud prevention, legal compliance, and other purposes authorized by applicable privacy legislation. These limited legal grounds do not replace the affirmative consent required for the processing of health information for the core Service where consent is required.

5.3.

U.S. Users. For residents of U.S. states with applicable consumer-health-data or comprehensive privacy laws, BioMarker Coach processes health information and consumer health data in accordance with the requirements of the applicable law. Where affirmative consent is required for the collection, sharing, or other processing of consumer health data, BioMarker Coach will obtain the required consent. Where applicable law permits processing that is strictly necessary to provide a service requested by the user or permits another lawful basis, BioMarker Coach may rely on that basis to the extent permitted by law.

5.4.

Withdrawal of Consent. You may withdraw consent to future processing of your health information by deleting your account or contacting us at support@thebiomarkercoach.com. Withdrawal of consent does not affect the lawfulness of processing that occurred before withdrawal. It may also limit or prevent your continued use of features that require health-information processing. Where applicable, withdrawal and deletion requests will be handled in accordance with the Account & Data-Deletion Policy.

6. How Your Health Information Is Processed by AI

6.1.

Two-Stage AI Processing. The central function of BioMarker Coach is to analyze laboratory information and questionnaire responses using artificial intelligence. When you submit a laboratory report: (1) the uploaded PDF, photograph, or other laboratory file is processed for extraction of laboratory marker names and values; (2) the uploaded file and/or information extracted from it may be processed through Anthropic PBC's Claude API as part of the applicable AI processing workflow; (3) relevant extracted marker values and relevant questionnaire information are evaluated together with BioMarker Coach's proprietary nutrition knowledge base; and (4) the Service generates the personalized educational report. The original uploaded laboratory file is processed for these purposes but is not retained as a stored laboratory document by BioMarker Coach after processing. BioMarker Coach may retain the file name and a file fingerprint for duplicate-detection purposes, together with the extracted laboratory values and generated report.

6.2.

Medication-Aware Supplement Safety. Where the Medication-Aware Supplement Safety feature is available, the Service may separately identify the active ingredient of a medication listed in your profile by querying Health Canada’s Drug Product Database and, if necessary, the U.S. FDA’s openFDA database. The lookup is made by BioMarker Coach’s server rather than your device. The medication name or matched active ingredient may be sent to the relevant public drug-information database. If Health Canada’s Drug Product Database returns a matching product, our server may also send the public Health Canada drug product code back to that database to retrieve product details, including the active ingredient. This code identifies a drug product, not you. No account details, other health information, or the user’s IP address are sent as part of the lookup.

6.3.

The resulting report may save the matched ingredient, source, retrieval date, and caution wording shown. This limited lookup does not check medication-to-medication interactions or medication effects on biomarkers or nutrients. The public databases are information sources, not service providers engaged by BioMarker Coach.

6.4.

The BioMarker Coach knowledge base was developed from professional nutrition education, peer-reviewed scientific literature, established nutrition resources, and evidence-informed nutrition principles, by BioMarker Coach's founder, based on her professional nutrition education and experience in nutrition practice. It includes the reference ranges, nutrition-oriented target ranges, condition-pattern information, and supplement-related information used by the Service.

6.5.

Anthropic Processing

6.5.1.

Anthropic PBC provides the Claude API used in connection with the Service's AI processing. Relevant information may be transmitted to Anthropic for AI processing, including information extracted from uploaded laboratory documents and relevant questionnaire information. Where report-chat functionality is processed through Anthropic, information necessary to answer the user's report-specific question may also be transmitted for that purpose.

6.5.2.

Under BioMarker Coach's agreement with Anthropic, BioMarker Coach's data is not used to train Anthropic's models. Anthropic is based in the United States, and relevant health information may therefore be transferred to and processed in the United States.

6.5.3.

The retention of prompts, inputs, outputs, and other information by Anthropic is governed by the applicable contractual and technical configuration between BioMarker Coach and Anthropic. BioMarker Coach does not represent that information sent to Anthropic is subject to zero retention unless the applicable configuration and agreement expressly provide for that result.

6.6.

BioMarker Coach does not use your health information to make automated decisions that produce legal or similarly significant effects about you. The reports generated by BioMarker Coach are educational and are not medical diagnoses, medical treatment, or clinical determinations—see our Medical & Nutrition Disclaimer and AI-Generated Content Disclaimer for details on the limitations of AI-generated content.

6.7.

Generated and Inferred Information

6.7.1.

The Service may generate or infer information from your laboratory results, questionnaire responses, report history, and other information you provide. This may include health-related observations, patterns, trends, flagged conditions or urgency tiers, nutrition insights, dietary and lifestyle suggestions, supplement-related educational information, meal plans, action lists, monitoring suggestions, and practitioner-referral flags.

6.7.2.

These outputs are generated or inferred for educational purposes and may be inaccurate, incomplete, or unsuitable for your individual circumstances. They are not diagnoses, clinical determinations, medical treatment, or a substitute for professional medical advice. Please see the Medical & Nutrition Disclaimer and AI-Generated Content Disclaimer for further information.

6.7.3.

Generated or inferred information may be treated as health information or sensitive personal information under applicable law even where it is not directly supplied by you. BioMarker Coach does not represent that every generated or inferred observation is accurate, complete, medically significant, or independently verified.

7. Who We Share Information With

We do not sell your personal information or your health information. We share information with service providers and other recipients only as necessary for the purposes described in this Privacy Policy, subject to applicable contractual, legal, and privacy requirements.

7.1.

Supabase. Supabase provides database, authentication, and related infrastructure used to operate the Service. Supabase may store account information, information associated with your profile, report-specific questionnaire snapshots used to generate particular reports, extracted laboratory values, generated reports, and other information necessary to operate the Service. The original uploaded laboratory PDF, photograph, or other laboratory file is not retained by BioMarker Coach after processing. BioMarker Coach may retain the file name and a file fingerprint for duplicate-detection purposes. The BioMarker Coach Supabase project is hosted in the United States, including Oregon.

7.2.

Anthropic PBC. Anthropic provides the Claude API used for AI processing. Relevant laboratory information, extracted marker information, questionnaire information, and, where applicable, information necessary to provide report-chat functionality may be transmitted to Anthropic for processing. Anthropic is based in the United States.

7.3.

Google LLC. Google LLC provides authentication services if you choose Google Sign-In on the BioMarker Coach website and shares the relevant account information described in this Policy, such as your name, email address, and Google profile identifier. We do not share your health information with Google for the purpose of Google Sign-In. Google Sign-In is not used for account creation or authentication in the iOS or Android applications.

7.4.

Firebase Cloud Messaging (Google). Delivers push notifications when your report is ready, processing the relevant device push token for this purpose. It does not receive your health information as part of the notification service.

7.5.

Stripe, Inc. Processes payment card details and billing information for purchases made through the BioMarker Coach website. Stripe does not receive your health information from BioMarker Coach for payment processing.

7.6.

Apple Inc. and Google LLC (as app marketplaces). If you purchase through the iOS App Store or Google Play, Apple or Google processes the transaction through its own payment system. We receive limited information necessary to confirm your purchase, validate the transaction, and manage your purchased credits and related purchase entitlements. We do not receive your payment card details through these transactions. These are one-time purchases and do not create recurring subscriptions.

7.7.

RevenueCat. RevenueCat provides purchase and entitlement management for purchases made through the iOS and Android applications. RevenueCat may receive your internal BioMarker Coach account identifier and purchase or transaction information necessary to validate and manage your in-app purchases and credits. RevenueCat does not receive your laboratory results, health questionnaire information, reports, or other health information from BioMarker Coach.

7.8.

PostHog. Where PostHog is enabled for applicable product analytics or feedback functionality, it may process usage events associated with your account identifier. PostHog is not intended to receive laboratory results, extracted marker values, health questionnaire answers, or report-chat question text

7.9.

Zoho Corporation. Provides our business email infrastructure, including email associated with support@thebiomarkercoach.com, and may process the contents of messages you send to us.

7.10.

Resend. Delivers transactional emails, such as gift codes sent to a gift recipient’s email address; processes only the recipient’s email address and the gift-code message content, and does not receive your health information.

7.11.

Meta Platforms, Inc. BioMarker Coach may use Meta’s advertising pixel on specified public marketing pages to measure advertising performance and, where permitted by law and based on the user’s applicable consent or privacy choices, support advertising and retargeting. The Pixel is restricted to public marketing pages and is not used on authenticated application pages or pages and API routes where health information is entered, viewed, uploaded, or processed, including upload, questionnaire, history, profile, and report-chat functionality. The information shared through this functionality may include limited browsing information, such as public marketing pages visited and general interactions with those pages. BioMarker Coach does not intentionally send laboratory results, extracted marker values, questionnaire answers, report content, or report-chat content to Meta through the Pixel. BioMarker Coach does not currently use Meta’s server-side Conversions API for the Service. The use of the Meta Pixel may constitute “sharing” or another regulated disclosure under applicable privacy laws even where BioMarker Coach does not receive monetary payment. Additional information is provided in the Cookie Policy.

7.12.

Legal, Regulatory, and Safety Disclosures. We may disclose information to law enforcement, regulators, courts, government authorities, or other parties where disclosure is required by applicable law or is reasonably necessary to protect the rights, property, or safety of BioMarker Coach, our users, or others.

7.13.

Render. Render provides hosting for the BioMarker Coach website, application, and server infrastructure. In providing these services, Render may process information transmitted to or stored through the hosted Service. Render is located in the United States.

7.14.

What We Do Not Do. Subject to the limited public-marketing functionality described in this Privacy Policy and our Cookie Policy, we do not sell your health information, sell your personal information to data brokers, use your health information for cross-context behavioral advertising, or provide your laboratory results, questionnaire answers, report content, or report-chat content to advertisers. We do not use social-media direct messages to collect or process laboratory results or other sensitive health information.

8. Cross-Border Processing and Data Transfers

8.1.

BioMarker Coach is a Canadian company, but some of the infrastructure and service providers used to operate the Service are located in or process information in the United States. These may include Supabase, Anthropic, Stripe, Render, PostHog, Resend, RevenueCat, and other service providers described in Section 7, depending on the feature or transaction involved.

8.2.

Accordingly, your personal information and health information may be transferred to, stored in, and processed in the United States even if you are located in Canada. Privacy laws in the United States may differ from those applicable in your province or territory.

8.3.

The processing described above is disclosed as part of the Service's data practices. BioMarker Coach remains responsible for handling personal information in accordance with applicable law and uses contractual, technical, and organizational measures appropriate to the services it provides.

8.4.

By providing the required consent for health-information processing and using the relevant features of the Service, you acknowledge that your information may be transferred to and processed in the United States as described in this Privacy Policy.

9. Data Retention and Deletion

BioMarker Coach retains different categories of information for different periods depending on the purpose for which the information is collected, the functionality of the Service, deletion requests, and applicable legal requirements.

9.1.

Account and Profile Information. Account information and your health questionnaire profile may be retained while your account remains active and as necessary to provide the Service, synchronize your profile between the website and application, maintain account security, administer entitlements, and comply with applicable legal obligations. Your profile is stored on our systems after you provide the required consent and may also exist as a temporary copy on your device. The profile is deleted through in-app account deletion as described in this Privacy Policy and our Account & Data-Deletion Policy, subject to the retention exceptions described below.

9.2.

Health Information, Reports, and Report History. Extracted laboratory marker information, report-specific questionnaire snapshots, generated reports, and related report-history information may be retained while necessary to provide the Service and allow you to access your report history. The original laboratory PDF, photograph, or other uploaded laboratory file is not retained by BioMarker Coach after processing, although BioMarker Coach may retain the file name and a file fingerprint for duplicate-detection purposes. You may request deletion of your information in accordance with our Account & Data-Deletion Policy, including the applicable account and data-deletion processes described in that Policy.

9.3.

Report Chat. Report-chat questions and answers associated with your BioMarker Coach account are deleted through in-app account deletion, subject to applicable legal requirements and the retention exceptions described in this Privacy Policy. Where report-chat information is transmitted to Anthropic for processing, Anthropic’s current configuration retains prompts, inputs, outputs, and other submitted information for a default period of 30 days and may permit access for safety and security purposes during that period. Under BioMarker Coach’s commercial agreement with Anthropic, our data is not used to train Anthropic’s models. Deletion from BioMarker Coach’s systems does not mean that information transmitted to Anthropic is deleted immediately.

9.4.

Authentication Records. In-app account deletion deletes the sign-in account associated with your BioMarker Coach account, including the associated email address, name, and province or state, as well as the health profile stored on our servers. It also deletes saved reports and their questionnaire snapshots, report-chat questions and answers, push-notification tokens, unused credits, and the temporary profile copy on the device used for deletion. A temporary profile copy may remain on another device until you sign out on that device or remove the application. Consent records, billing and transaction records, and gift codes purchased for another person are retained as described in this Privacy Policy. Information transmitted to third-party providers remains subject to their applicable retention arrangements.

9.5.

Backups. Supabase maintains daily backups with a retention period of seven days. Information deleted from active systems may therefore remain temporarily in backups until those backups expire. BioMarker Coach will handle deletion from backups in accordance with applicable law and its operational deletion procedures. Information retained by third-party providers, including Anthropic, is subject to the applicable provider retention arrangements described in this Privacy Policy.

9.6.

Consent Records. Consent records may be retained for as long as reasonably necessary to demonstrate the existence and scope of consent, respond to disputes, and comply with legal or regulatory obligations. Consent records may include your user identifier, the document or documents referenced by the consent, the relevant document version or effective date, and the timestamp of consent. They do not duplicate the underlying health information.

9.7.

Billing and Tax Records. Limited billing, transaction, purchase, credit-entitlement, and tax records may be retained for the period required or permitted by applicable Canadian and U.S. tax, accounting, legal, or regulatory requirements.

9.8.

Deletion Requests

9.8.1.

You may delete your account through the functionality made available in the Service. For information about the distinction between account deletion, deletion of saved reports and questionnaire information, and a request for full deletion, please see our Account & Data-Deletion Policy.

9.8.2.

If you need to request deletion or follow-up action for information not covered by the in-app account-deletion process, you may email support@thebiomarkercoach.com from your registered email address with the subject line “Full account deletion.” We may verify your identity before processing the request. BioMarker Coach will handle the request in accordance with applicable law, this Privacy Policy, and our Account & Data-Deletion Policy.

9.8.3.

We will process verified deletion requests in accordance with applicable law and our Account & Data-Deletion Policy. We will take reasonable steps to delete information from our active systems and applicable backup systems within the period required by applicable law or stated in the Account & Data-Deletion Policy. Certain information may be retained where required or permitted by law, including limited records necessary to demonstrate compliance, billing and tax records, security records, consent records, and information held in systems subject to separate retention periods. Information transmitted to third-party service providers may remain subject to their applicable contractual, technical, and legal retention requirements. BioMarker Coach does not represent that it can immediately retrieve, modify, or delete every item of information processed by every third-party provider.

9.9.

Information Downloaded or Shared by You. Deletion from BioMarker Coach cannot retract information that you have independently downloaded, exported, shared with another person, or otherwise disclosed outside the Service.

10. Your Privacy Rights and Choices

10.1.

Rights Available to All Users. Subject to applicable law, you may access information associated with your account; update or correct account information through your profile; request a copy of personal information we hold about you; request correction of inaccurate information; request deletion of your information; and withdraw consent to future processing where processing is based on consent. To exercise these rights, contact support@thebiomarkercoach.com . We may need to verify your identity before completing a request, generally by confirming account ownership through your registered email address.

10.2.

Canadian Users. If you are located in Canada, applicable privacy law may provide rights including access to personal information held about you; correction of inaccurate personal information; withdrawal of consent, subject to legal limitations; information about our collection, use, and disclosure practices; and the ability to make a privacy complaint to the applicable privacy regulator, including the Office of the Privacy Commissioner of Canada, where applicable. Withdrawing consent may limit or end your ability to use portions of the Service that require processing of health information.

10.3.

California Residents

10.3.1.

If you are a California resident and the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to our processing of your information, you may have rights including the right to know what personal information we collect and how it is used and disclosed; the right to access and correct personal information; the right to request deletion, subject to applicable exceptions; the right to opt out of the sale or sharing of personal information; the right to limit certain uses and disclosures of sensitive personal information, including health information; and the right not to receive discriminatory treatment for exercising these rights.

10.3.2.

Where applicable, the Meta Pixel described in this Privacy Policy may constitute a sale or sharing of personal information under California law even though BioMarker Coach does not receive monetary payment for the disclosure. California residents may exercise applicable rights by contacting support@thebiomarkercoach.com and may use the privacy-choice mechanisms made available on the public marketing website. Where applicable, BioMarker Coach will not require a user to create an account solely to exercise a privacy right and will not discriminate against a user for exercising rights granted by applicable law, subject to lawful exceptions.

10.4.

Washington, and Similar Consumer-Health-Data Laws. If you reside in a jurisdiction with a consumer-health-data privacy law that applies to our processing, you may have rights to confirm whether we collect, share, or sell consumer health data; access consumer health data; withdraw consent to collection or sharing; and request deletion of consumer health data, including from archived or backup systems, with confirmation once completed. We do not sell consumer health data and do not use geofencing around healthcare facilities. Where applicable, BioMarker Coach will process such requests within the time periods required by applicable law.

10.5.

Nevada, Connecticut and Other U.S. State Privacy Laws. Residents of other U.S. states, Nevada and Connecticut may have additional rights under applicable comprehensive state privacy laws, including rights relating to access, correction, deletion, portability, consent, or opting out of certain processing. We will respond to privacy requests in accordance with the law applicable to the requesting individual.

10.6.

Appeals and Authorized Agents. Where applicable law provides a right to appeal a decision concerning a privacy request, you may request an appeal by contacting support@thebiomarkercoach.com. Where applicable law permits you to use an authorized agent to exercise privacy rights, BioMarker Coach may require appropriate documentation confirming the agent's authority and may independently verify the requesting individual's identity as required by law.

10.7.

Verification and Response Times. We may request reasonable information necessary to verify your identity and protect against unauthorized disclosure of personal information. We will respond to valid privacy requests within the time period required by applicable law and may extend a response period where the applicable law permits an extension.

11. Cookies and Similar Technologies

11.1.

BioMarker Coach uses cookies and similar technologies, including browser storage, to operate and secure its website and web application. Essential browser storage is used to maintain sign-in sessions and related account functionality. Sign-in sessions are maintained using browser storage rather than cookies.

11.2.

BioMarker Coach also uses PostHog for product analytics, subject to the user's consent. Analytics events may include pages or screens viewed, report-open events, report-view duration and report-chat interaction counts, and may be associated with an internal user identifier. PostHog autocapture and session recording are disabled. BioMarker Coach does not send laboratory values, questionnaire answers, report content or report-chat text to PostHog. On the website, PostHog analytics is activated only after the user consents through the available cookie preferences. Selecting Accept All includes Analytics; selecting Reject Non-Essential leaves Analytics disabled. Users may change or withdraw their analytics consent at any time. The iOS and Android applications provide an equivalent analytics choice, and PostHog is not activated in the applications without consent.

11.3.

On specified public marketing pages of the website, BioMarker Coach may also use Meta’s advertising pixel, but only after the user has given the required consent. The Meta Pixel is separate from PostHog analytics. If the user selects Reject Non-Essential, neither the Meta Pixel nor PostHog analytics is activated. The categories of cookies and similar technologies, their purposes, and the ways to manage consent are described in the Cookie Policy.

11.4.

Non-essential advertising cookies should not be activated before the user has provided the consent required by applicable law. Our cookie consent mechanism may provide options such as accepting all cookies, rejecting non-essential cookies, or managing cookie preferences.

11.5.

Where required by applicable law, the public marketing website will provide a continuing privacy-choice mechanism, such as a "Do Not Sell or Share My Personal Information" or "Your Privacy Choices" link, allowing eligible users to change or withdraw applicable privacy choices after their initial visit.

11.6.

The categories of cookies used, the purposes for which they are used, how non-essential cookies may be declined, and how you can manage your preferences are described in our separate Cookie Policy, which forms part of this Privacy Policy by reference.

12. Security

12.1.

We use technical and organizational safeguards designed to protect the information we process, including encryption of information in transit using HTTPS/TLS; encryption at rest for data stored in Supabase; database access controls; row-level security policies designed to restrict users’ database records to their own accounts; and authentication through Supabase Auth. The Service also uses automatic sign-out after 15 minutes of inactivity as an additional security measure. Data stored in Supabase is encrypted at rest.

12.2.

No method of transmission, processing, or storage is completely secure, and we cannot guarantee absolute security of your information. If you believe your account has been accessed without authorization or become compromised, please contact us promptly at support@thebiomarkercoach.com.

12.3.

If BioMarker Coach experiences a security incident involving personal information or health information, we will investigate the incident and provide notices to affected individuals, regulators, service providers, or other parties where required by applicable law. The timing, content, and recipients of any notice will depend on the nature and scope of the incident and the requirements of the applicable law.

13. Children's Privacy

The Service is intended solely for individuals 18 years of age or older. We do not knowingly collect personal information or health information from individuals under 18. Account creation requires an affirmative confirmation that the user is at least 18 years old. If we learn that we have collected personal information from an individual under 18, we will take appropriate steps to delete that information in accordance with applicable law.

14. Your Responsibility When Uploading Information

You may upload only laboratory results and health information that you have the legal right and authorization to provide to BioMarker Coach. By uploading information, you confirm that the information belongs to you, or that you have the necessary authorization from the person to whom the information relates to provide it to BioMarker Coach and permit the processing described in this Privacy Policy. Please do not upload another person's health information without the appropriate authorization.

15. Social Media

BioMarker Coach maintains public accounts and content on platforms including Instagram, TikTok, YouTube, and Facebook. Interactions that take place directly on those platforms including comments, follows, messages, and other platform activity are subject to the relevant platform's privacy policy and terms. BioMarker Coach may use social-media direct messages to provide an account-creation link or other general information. You should not send blood-test results, laboratory values, medical information, or other sensitive health information to BioMarker Coach through social-media direct messages.

16. Deleting Your Account and Data

16.1.

In-app account deletion deletes your sign-in account, including the associated email address, name, and province or state; your server-side health profile; saved reports and their questionnaire snapshots; report-chat questions and answers; push-notification tokens; unused credits; and the temporary profile copy on the device used for deletion. A temporary profile copy may remain on your other devices until you sign out there or remove the application. Consent records, billing and transaction records, and gift codes purchased for another person are retained as described in this Privacy Policy and our Account & Data-Deletion Policy. Information transmitted to third-party providers may remain subject to their applicable retention periods.

16.2.

You may delete your account through the account-deletion functionality made available in the Service. If you need deletion or follow-up action for information not covered by that process, including requests concerning information held by relevant service providers, you may contact support@thebiomarkercoach.com from your registered email address with the subject line “Full account deletion.” We will verify and process such requests in accordance with applicable law and the procedures in our Account & Data-Deletion Policy. Deletion from BioMarker Coach’s systems does not guarantee immediate deletion of information already transmitted to third-party providers.

16.3.

Deletion and Unused Credits. Account deletion does not result in a refund of unused credits. Any unused credits associated with your account, including credits purchased directly, redeemed through a gift code, awarded through the Referral Program, or issued through a promotional code, are forfeited when the account is deleted, subject to the applicable Credit Package, Cancellation and Refund Terms. An unredeemed gift code that was purchased for another person is not affected by deletion of the purchaser's account and remains redeemable by its recipient in accordance with the applicable terms. Deletion also cannot retract information you have independently downloaded, shared with another person, or otherwise disclosed outside the Service.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Service, our data practices, our service providers, applicable law, security practices, or other operational circumstances. If we make a material change, we will provide notice through email, an in-app notice, or another legally appropriate method before the change takes effect where required. The updated Privacy Policy will identify the applicable effective or last-updated date.

18. Contact Us

If you have questions, concerns, complaints, or requests relating to this Privacy Policy or our privacy practices, please contact:

15751608 Canada Inc., operating as BioMarker Coach Email: support@thebiomarkercoach.com Mailing Address: 62 Mary Street, Brampton, Ontario, Canada, L6W 2R3

Designated Privacy Officer: Tatiana Kuznetsova, founder of BioMarker Coach, is designated as the Privacy Officer responsible for privacy-related questions, requests, and complaints. Privacy-related questions, requests, or complaints may be directed to BioMarker Coach’s designated Privacy Officer at support@thebiomarkercoach.com.

For privacy requests, please include enough information for us to identify your account and process your request. We may request verification of account ownership before completing a request.

Related documents: Terms of Service, Informed Consent, Cookie Policy, Account & Data-Deletion Policy.