Petwell, Inc.

1.1 Information You Provide  
 • Account information: name, email address, mailing address, phone number, and payment information
 • Pet information: pet name, breed, age, weight, sex, and medical history you choose to share
 • Biological samples: samples you submit through our at-home diagnostic test kits for laboratory analysis
 • Communications: messages, support requests, and feedback you send to us

1.2 Information Generated Through Our Services  
 • Laboratory biomarker results: data produced from the analysis of your pet's biological samples across 50+ biomarker data points
 • Health Score Data: the Petwealth Health Score™ and related algorithmic outputs generated by our proprietary algorithm from your pet's laboratory results
 • Usage data: how you interact with the Services, including features used, pages viewed, and actions taken

1.3 Information Collected Automatically  
 • Device information: device type, operating system, browser type, and unique device identifiers
 • Log data: IP address, access times, referring URLs, and pages visited
 • Cookies and similar technologies: as described in Section 8 below

We use the information we collect for the following purposes:

2.1 Providing and Improving Services  
• To process your biological samples and deliver laboratory biomarker results
 • To generate Health Score Data through automated algorithmic processing of your pet's laboratory biomarker results
 • To display results, Health Score Data, and data insights on your dashboard
 • To facilitate veterinarian access to your pet's laboratory data through the veterinary professional dashboard (see Section 3.1)
 • To process payments and manage your subscription
 • To provide customer support and respond to your inquiries

2.2 Algorithm Improvement and ResearchAlgorithmic Processing Disclosure:
Your pet's laboratory biomarker data is processed by automated algorithms to generate Health Score Data. This processing occurs without individual human clinical review, unless you specifically request it.We may use de-identified and aggregated pet health data to improve the accuracy of our algorithms and to conduct research into pet health trends. This research use is conducted only on data that cannot reasonably identify you or your pet.

2.3 Communications  
• To send you transactional communications related to your account and test results
 • To send you marketing communications (with your consent, where required by law)
 • To send you data alerts and Health Score updates

We do not sell your personal information. We may share your information in the following circumstances:
‍
3.1 Veterinary Professionals: If you are connected with a veterinary professional through the Services, we share your pet's laboratory biomarker results and Health Score Data with that professional to facilitate their review and any follow-up care.
‍
3.2 Third-Party Telehealth Providers: If you use our referral to Pawp or another third-party telehealth provider, we may share limited pet health information necessary to facilitate that consultation. These providers have their own privacy policies governing use of your information.
‍
3.3 Service Providers: We may share information with trusted third-party service providers who perform services on our behalf, including laboratory processing, payment processing, data storage, customer support, and communications. These providers are contractually required to use your information only as directed by Petwealth and in accordance with this Policy.

3.4 Legal Requirements: We may disclose information if required by law, regulation, legal process, or governmental request, or if we believe disclosure is necessary to protect the rights, property, or safety of Petwealth, our users, or the public.

3.5 Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change via email or a prominent notice on the Services.

Petwealth uses automated algorithms to process your pet's laboratory biomarker data and generate the Health Score™. You have the right to understand how this works:What is processed: Raw laboratory biomarker results from your pet's submitted samples (50+ data points).

How it is processed: A proprietary algorithm compares your pet's biomarker values against peer-reviewed veterinary reference ranges and population data to produce a numerical Health Score and related data summaries.What it produces: A Health Score (numerical index) and related data summaries displayed on your dashboard.What it does not do: The algorithm does not make clinical diagnoses, treatment recommendations, or medical decisions. It is an informational data aggregation tool only.

You may request human review of any algorithmically generated output by contacting support@petwealth.com.

We retain your information for as long as necessary to provide the Services and fulfill the purposes described in this Policy, unless a longer retention period is required by law. Laboratory results and Health Score Data are retained for a minimum of 7 years to support longitudinal pet health tracking.You may request deletion of your data at any time (see Section 7).

We implement industry-standard technical and organizational measures to protect your information, including:  • Encryption of data in transit (TLS 1.2+) and at rest (AES-256)
 • Access controls limiting employee access to personal and pet health data on a need-to-know basis
 • Regular security assessments and vulnerability testing
 • Secure laboratory data processing environments
 • Contractual security requirements for all third-party service providersWhile we take reasonable measures to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your data.

7.1 All Users
Regardless of where you live, you have the right to:  
• Access your personal information and pet health data
 • Correct inaccurate information
 • Delete your account and associated data (subject to legal retention requirements)
 • Opt out of marketing communications
 • Opt out of algorithmic data use for research and algorithm improvement
 • Request human review of algorithmically generated Health Score Data

7.2 California Residents (CCPA/CPRA)If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:  
 • Right to Know: You may request details about the categories and specific pieces of personal information we have collected, used, shared, or sold about you.
 • Right to Delete: You may request that we delete your personal information, subject to certain exceptions.
 • Right to Correct: You may request correction of inaccurate personal information.
 • Right to Opt Out of Sale/Sharing: Petwealth does not sell personal information. We do not share personal information for cross-context behavioral advertising.
 • Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.To exercise these rights, contact us at privacy@petwealth.com. We will verify your identity before processing your request.

7.3 Virginia, Colorado, Connecticut, and Other State ResidentsResidents of states with comprehensive privacy laws (including Virginia, Colorado, and Connecticut) may have similar rights to those described above. To exercise any applicable rights, please contact us at privacy@petwealth.com.

We use cookies and similar technologies to operate and improve the Services. You can manage your cookie preferences through your browser settings or our cookie preference center.

We use:  
 • Essential cookies: required for account authentication, security, and core functionality
 • Analytics cookies: help us understand how you use the Services so we can improve them
 • Marketing cookies: used to deliver relevant communications (only with your consent where required by law)

The Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will delete it promptly. If you believe a child under 13 has provided us with personal information, please contact us at privacy@petwealth.com.

The Services may contain links to third-party websites and services, including Pawp. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through the Services.

Your information is processed and stored in the United States. If you access the Services from outside the United States, your information will be transferred to and processed in the U.S., where privacy laws may differ from those in your country.

We may update this Privacy Policy from time to time. We will notify you of material changes by sending an email to the address associated with your account or by posting a prominent notice on the Services. The updated Policy will be effective as of the date indicated at the top of the Policy.

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle your information, please contact us at: Petwell, Inc.
‍
Privacy inquiries: privacy@petwealth.com
General support: support@petwealth.com
Website: www.petwealth.com