Ani Research Master Data Privacy Policy

(“Privacy Policy”)

Effective Date: November 1st 2025

For purposes of this Privacy Policy, “Ani.ai” refers to the digital platform and related services operated by ANI BIOME PBC. This Privacy Policy applies to the Services provided by ANI BIOME PBC, its subsidiary Cidrani d.o.o., and any other affiliates, subsidiaries, or related entities (collectively, “Ani”). The terms “Ani.ai” and “Ani” may be used interchangeably throughout this Policy.

Relationship Between Informed Consent and This Privacy Policy

Ani conducts multiple scientific and clinical research studies, each of which may collect different combinations of biological, digital, and behavioral data.

Each study you participate in is governed by a study-specific Informed Consent Form (ICF) that describes the purpose of the research, the data collected, and any specific data sharing or retention conditions.

This Research Data Privacy Policy applies across all Ani studies, Ani digital tools, and Ani partner-led research studies. It explains how Ani handles and protects personal data, regardless of which study you join. In the event of a conflict between this Policy and a study’s ICF, the ICF will govern that study’s specific data use.

Relationship Between Ani Terms of Service and This Privacy Policy

This Privacy Policy is incorporated by reference into the Ani terms of service (“Terms” or “Terms of Service”), which can be found on our websites located at www.ani.ai, www.anibiome.ai, and mobile software applications. Please carefully review this Privacy Policy and Terms of Service.

“Services” means the research, data processing, analysis, digital platform access, and related activities provided by Ani.ai, including but not limited to (i) collection, handling, testing, and analysis of biological samples (such as stool, blood, saliva, tongue, cheek, or skin swabs) and related data; (ii) collection and analysis of digital and behavioral information (including questionnaires, sensor data, and self-reported information); (iii) generation of analytical outputs, test data, and results derived from Ani.ai’s proprietary algorithms, artificial intelligence systems, or statistical models; (iv) delivery of informational reports, insights, or recommendations through Ani.ai’s website, mobile application, or partner platforms; and (v) optional participation in Ani.ai’s research programs, product development initiatives, or wellness programs (such as the AgeBiotics Service as defined herein).

These Services are provided for research, informational, and educational purposes only and do not constitute medical advice, diagnosis, or treatment.

By using our Services, you agree, accept, and consent to all of the policies and procedures described in these documents. If you do not agree with or are not comfortable with any aspect of this Privacy Policy or the Terms of Service, you should immediately discontinue use of our Services.

Scope and Participants

Ani.ai provides its applications and related research services for scientific and clinical research purposes. Individuals who use the Ani app or dashboard, provide biological samples, or otherwise participate in Ani-led or partner-led studies are referred to in this Privacy Policy as “Participants.”

Participation is voluntary and may involve submission of health, biological, and questionnaire data under informed consent. Ani processes such information in accordance with this Privacy Policy, applicable data protection laws, and ethical research standards. References in this Policy to “you” or “your” refer to these Participants.

Where Ani provides non-research features (for example, subscription content or general wellness information), the same privacy protections apply.

Introduction

Ani.ai is a next-generation AI platform creating dynamic, evolving digital twins of human biology to advance the science of longevity and precision interventions. We integrate deep multi-omics analysis – including but not limited to genomics, epigenomics, transcriptomics, microbiomics, mitochondrial health, and microRNA expression – to decode the complexity of aging biology.

Founded in the emerging field of Affectoneuroimmunology, Ani.ai bridges the biological and emotional layers of health. By capturing how multi-omics data, digital biomarkers, emotions, cognition, immunity, and microbial ecosystems interact, we generate personalized models that go beyond diagnostics – with the focus on predictive, preventative, and adaptive health intelligence.

Our Services include access to the Ani public websites, Ani.ai and AniMedical.ai mobile application and dashboard (“Ani Digital Platform”), Ani supplements (“AgeBiotics”), Ani families of subscription services (“Subscription Service”), and “omics” testing services (e.g., microbiome, genetic, epigenetic, etc.) that include Ani Labs Tests (“Ani Labs Tests”). In the course of these Services, we may collect and analyze (i) your biological samples (such as tongue tissue, stool, blood, saliva, or other biological materials) and (ii) relevant digital data you provide through our mobile application (including but not limited to questionnaires, sensor data, and other user inputs).

The biological samples we collect include stool, blood, saliva, tongue swab, cheek swab, skin swab, and other (“Samples”), using sample collection kits (“Kits”) provided by Ani.ai. Participants will collect the Samples using the Kits and ship them to Ani.ai for testing and analysis. Data obtained from testing the Samples are subjected to a process of scientific testing to produce sample data (“Sample Data”) used for producing test data (“Test Data”) that will be stored and used with Participant-provided information (in response to our questionnaires and other self-reported information) and Ani.ai proprietary technology that use analytics and Artificial Intelligence to generate test results (“Test Results”). Based on our analysis of Test Results of Ani VQ Score line of products including Ani’s proprietary digital aging clocks (“Vitalligence Scores”) and Participant-provided data, using Ani technology, Ani makes supplement and lifestyle recommendations and offer AgeBiotics supplements (“AgeBiotics Service”) to individuals via Ani website located at www.ani.ai and Ani mobile applications. Based on our analysis of Samples associated with Ani Labs Tests line of Services and Participant-provided data, using Ani.ai technology, Ani.ai detects molecular features and deliver associated Test Results and recommendations using its Ani digital platform via web platforms, mobile platforms or its partner web or mobile platforms.

Disclaimer: Not Medical Advice

The Services, including all Test Data, Test Results, recommendations, and related reports, are intended for research, informational, and educational purposes only and are not a substitute for professional medical advice, diagnosis, or treatment.

Ani.ai is not a healthcare provider and does not engage in the practice of medicine. The Services have not been evaluated or approved by the U.S. Food and Drug Administration (FDA) or any other regulatory authority as medical devices or diagnostic tests.

Participants should not interpret or rely on any information provided by Ani.ai as medical advice, and should always seek the guidance of qualified healthcare professionals regarding any medical conditions or health-related decisions.

Based on our analyses of your Samples, Test Data, and any other Participant-provided data, Ani.ai uses advanced analytics and Artificial Intelligence to generate Test Results, personalized recommendations, Vitalligence Scores and other predictive insights. We may also use these data to create “synthetic” datasets, which are artificially generated data records that do not identify you as an individual. We use these predictive insights and synthetic data to improve and develop our products and services, conduct research, refine our AI models, create research or analytic reports, and for other lawful business purposes.

Ani takes privacy very seriously. We are committed to protecting the privacy and security of “Personal Information” which could be used to identify Participants, either alone or in combination with other information. By accessing or using the Service (as defined above), Participants allow us to collect, store, and use their Personal Information that enables us to provide services associated with Ani Services (as defined above). Ani recognizes and understands the importance of privacy and respects our Participants’ desire to store and access Personal Information in a private and secure manner.

“Participants” or “Users” of Ani’s Services may also include individuals who enroll in our partners’ research programs (hereinafter, “Partner Research Participants”). Such research programs may be administered directly by Ani.ai or through our partners’s network, and may be conducted on our website, mobile application, or by other means. By enrolling in Ani partner research programs, you acknowledge that your Personal Information is subject to this Privacy Policy, as well as additional terms found in any separate study participation agreement you sign.

THIS PRIVACY POLICY DESCRIBES HOW INFORMATION ABOUT YOU MAY BE COLLECTED, USED, STORED, MAINTAINED, SHARED, DISCLOSED, PROTECTED, AND ABLE TO ACCESS THIS INFORMATION. THIS PRIVACY POLICY FURTHER DESCRIBES OUR POLICIES ON OUR PARTICIPANT’S PERSONAL INFORMATION, PERSONAL DATA, PERSONALLY IDENTIFIABLE INFORMATION, SELF-REPORTED INFORMATION, PROTECTED HEALTH INFORMATION, AND SENSITIVE INFORMATION. PLEASE REVIEW IT CAREFULLY.

Acceptance of Privacy Policy

By enrolling in a study conducted by Ani or any of its partners, subscribing to, becoming a Participant or otherwise using our Services (including our Subscription Service), or accessing any content or materials made available through the Service, you agree to be bound by our Terms of Service, that includes this Privacy Policy. Ani reserves the right to change or modify this Privacy Policy at any time and in its sole discretion. Any changes or modifications will be effective immediately upon posting of the revised Privacy Policy (with the revision effective date posted on the top left side) on our Service. Your continued use of the Service following the posting of revised Privacy Policy will constitute your acceptance of those.

What Information We Collect

When you subscribe to or use our Services, Ani collects and uses several types of information as identified below. These include information you provide directly to us, your clinical and test data, medical information and history, information you provide in response to Ani questionnaires, self-reported information, information we receive from our Partner Services, data we retain in order to improve our data analytics methods and artificial intelligence engine and our Service, data you provide us for the purpose of providing Participant services, data we retain for provisioning our Service and securing payments for same, information we collected through tracking technology, chatbot, web analytics, and other types of information we receive about you from third party sources.

We may collect “Personal Information” about you that amounts to any factual or subjective information whether recorded or not about an identifiable individual.

“Personally, Identifiable Information” or “PII” is information about an individual when used alone or with other relevant data that can identify an individual (e.g., first and last name, birthdate, home address, social security number, bank account number, credit card number, passport number, Health insurance ID number, etc.).

“Personal Data” is any information relating to a natural person, when that person can be identified, directly or indirectly, in particular by reference to an identification number (e.g., social security number or credit card number) or one or more factors specific to his physical, physiological, mental, economic, cultural or social identity (e.g., last name and first name, date of birth, biometrics data, fingerprints, or DNA).

“Sensitive Information” or “Sensitive Data” is a category of Personal Information or Personal Data of an individual relating to confidential medical facts, medical history, records, racial or ethnic origins, political or religious beliefs, or sexuality.

“Self-Reported Information” is all information you provide us about yourself, including input and answers to surveys, forms, questionnaires, email, features on our website and software applications, while participating in any of Ani or Ani’s partners’ research activities, engaging with our Participant service (“Participant Service”) or while using the Service (e.g., information about your personal traits (e.g., eye color, height), ethnicity, disease conditions (e.g., Type 2 Diabetes), physical health-related information (e.g., pulse rate, cholesterol levels, visual acuity, medicine you currently take, habits such as smoking), diet related information (e.g., vegetarian, vegan, allergies, etc.), mental health related information (e.g. emotional conditions such as fear or anxiety), your disease conditions, medical history, and family history (e.g., information similar to the foregoing about your family members).

“Protected Health Information” or “PHI” is any information about health status, provision of health care, or payment for health care that can be linked to a specific individual that also includes such information as any part of a medical record or payment history.

“Registration Information” is collected when you subscribe to or register for our Services, or when your participation is facilitated through a partner research institution or clinical site.

For individuals who register directly with Ani.ai, this information may include, but is not limited to, Personal Information such as your name, date of birth, password, payment information (of which Ani stores only the last four digits and expiration date unless your Services include a recurring Subscription Service), billing and shipping addresses, and contact details such as email address and telephone used to create your Ani Account (“Account”).

For participants enrolled in Ani.ai’s partner-led or institutional research studies, Ani.ai may not receive direct identifiers such as names or contact details. Instead, such participants are represented in Ani.ai’s systems by coded identifiers or pseudonyms generated by the research site. Only the authorized administrator of that research center retains the key linking such codes to individual identities. Ani.ai processes such coded data solely for research and analytical purposes. In such cases, Ani.ai functions as a data processor or joint controller in collaboration with the research institution, depending on the study’s data governance structure.

Ani uses Registration Information to authenticate your access to Ani Account, websites and mobile applications for purposes that include but not limited to the following: use the Service, complete your orders, or access add-ons and new features related to the Service, charge recurring fees for Subscription Services, deliver personalized reports, send consent forms and questionnaires, marketing and communications, and certain other purposes.

“Biological Samples” are the self-collected stool, blood, and other fluid samples such as saliva, tongue swab, cheek swab, skin swab, or urine, that you collect using Sample collection kits (“Kits”) and used for epigenome, microbiome, genome, and other testing and analysis performed by Ani.

“Sample Data” is molecular data created from the Samples you provide to Ani for testing and analysis. Sample Data analysis includes, but is not limited to, primary sequencing and other types of analysis including but not limited to RNA and DNA, microbiome analysis, microbial gene expression analysis, human gene expression, and personal genotype.

“Medical Information” refers to information contained in your medical records or held by your healthcare provider that you expressly authorize Ani.ai to access.

Ani.ai will access such Medical Information only with your explicit written consent, obtained either directly from you (for example, through a signed consent form or verified digital authorization) or indirectly through your treating physician or research site where the consent process forms part of an approved research study.

Access to Medical Information is limited to the data necessary for the performance of the relevant research or Service and will be carried out in accordance with applicable data- protection and medical-privacy laws, including HIPAA, GDPR, and related national regulations. Where applicable, you may also choose to connect Ani.ai to third-party digital health platforms or electronic medical record systems to import Medical Information. Ani.ai will access such data only after you authorize the connection and may revoke it at any time.

“User Content” is information that you create or content that you post or upload on our website, social media, or public forums that relate to us, such as blogs, data, text, software, documents, audio, photographs, graphics, video, messages, discussions, emails, or other materials that you create or provide to us through public or private transmissions.

“Test Data” is information we extract from Sample Data for use in our testing services that produce data and test results that help us provide you with accurate and personalized recommendations and Services.

“Pseudonymized and De-identified Information” or “De-identified Data” refers to Samples and other forms of data from which direct personal identifiers are removed immediately upon receipt and replaced with a unique alphanumeric code. All downstream testing, research, and data analyses are conducted using this code rather than direct identifiers.

Where the data are processed in a manner that still allows a coded link to be maintained by Ani or its authorized partners (for example, to allow follow-up or quality-control procedures), the data are considered pseudonymized. Where identifiers have been irreversibly removed and no code or key exists that could reasonably re-identify a Participant, the data are considered fully de-identified or anonymized.

Ani follows established industry practices for data minimization and pseudonymization, ensuring that information likely to identify you is removed or separated from Sample Data, Test Data, internal records, or other digital inputs (including images or sensor data such as tongue or facial features).

Ani does not store your direct identifiers together with your Samples, Test Data, or other digital data in any database and does not release identifiable information externally. Your identifiable Personal Information is used only to the extent necessary to deliver the Service to you and to communicate directly with you when required. For all other purposes, including research, algorithmic analysis, or improvement of our Artificial Intelligence systems, Ani uses pseudonymized or de-identified data only, unless you have specifically consented to additional use.

Pseudonymized Information or Pseudonymized Data refers to Samples and other forms of data from which direct personal identifiers have been removed and replaced with artificial identifiers or pseudonyms. These identifiers are held separately and protected by strong technical and organizational safeguards to prevent re-identification of the data with any natural person.

For the purposes of this Privacy Policy, de-identified or pseudonymized data means information that cannot be attributed to you or to any specific individual without the use of additional information, and such additional information is accessible only to authorized administrators and not to other users of the data.

Ani takes all reasonable precautions, including encryption, access controls, and compartmentalized data storage, to avoid inadvertent re-identification of Samples, Test Data, and other sensitive information.

“Aggregate Information” or “Aggregate Data” means high-level information or data collected from a group of individual Samples or other data combined with similar data of the others and compiled into data collections or summaries such that when evaluated as a whole, that no specific individual may be reasonably identified. Aggregate Data is often used for data analysis and sometimes for Research.

“Individual-level Data” means information or data about a single individual’s Sample or other types of data provided by the individuals themselves or collected from other sources.

“Web Information” is information on how you use Ani website (e.g., browser type, domains, page views, etc.) or other online media owned by Ani, and are collected through log files, cookies, pixels, and web beacon technologies.

Use of Cookies

Ani and its third-party service providers from whom it receives your information may use “cookies” and similar tracking technologies (such as web beacons, pixel tags, scripts, and device identifiers used for automatic collection of information), for a variety of purposes. Cookies are small data files that are stored on a user’s hard drive at the request of a website to enable the website to recognize and retain certain user information.

Cookies help us recognize when and how you use our Services, customize, and improve your experience, provide security, analyze your interactions with our Services and their features, gather demographic information about our user base, make special offers of our Service, retarget marketing content, monitor the success of marketing programs, and for targeted advertising on our website and on other websites on the Internet. To learn more on cookies and tracking technologies, please read our Cookie Policy at https://www.ani.ai/cookie-policy

Third Party Cookies and Pixels

When Ani engages third party cookie service providers for targeted advertising and obtaining reports on how certain functionalities of our website work and obtaining usage and statistical information such as the user’s browser type, operating system, device IDs, etc., these third- party providers may collect personal and non-personal information from you including your IP address, email address, and demographic information, in connection with the services they provide. They may place cookies, Pixel tags, or web beacons on your device to collect personal and non-personal information.

When you visit our website, log in, register, or open an email, cookies, pixels, ad beacons, and similar tracking technologies may be used by our online data partners or service providers to associate your activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing or advertising messages about our Services to these email addresses. You can read our Cookie Policy to learn more about cookies, analytics, and advertising partners we use on our Services.

You may choose to opt-in or optout of the collection or sale of your personal information in compliance with the privacy laws applicable to you (such as GDPR, CCPA, etc.). If you are a resident of certain U.S. States that provide you with a legal right to opt out of such cookies, you can choose to opt out of non-essential cookies as stated in our Cookie Policy, or you may opt- out of collection, sale, or sharing of your personal information by our third party cookie service providers by visiting their websites.

Your information may be used, among other things to deliver advertising targeted to your interests, cross-referencing information, better understand the usage of the Service, and for other services tracked by these third parties. In addition, certain third-party cookie service providers may use your information for purposes other than providing their services to us, such as licensing and sharing your information with their Participants. Except as expressly stated in a legally binding agreement executed between Ani and these third parties with terms that contractually restrict access or processing personal information, Ani is not responsible for, and does not control, any actions or policies of any third-party service providers.

For additional details, including the types of cookies and your privacy choices, please see our Cookie Policy (that is incorporated herein by reference and that supplements this Privacy Policy), located at https://www.ani.ai/cookie-policy.

The information reports we receive from third party service providers can be in de-identified, individual-level, or at aggregate-level, and we may also use these reports to initiate communications with you, make Service offerings, and improve our data analytics methods. If we combine cookies with, or link them to, any of the Personal Information, Ani will treat this information as Personal Information.

If you wish to block, erase, or be warned of cookies, please refer to your browser instructions or help screen to learn about these functions. However, if you reject certain cookies or your browser or device settings do not accept cookies, you may not be able to use certain parts of our website or sign in to your Ani Account and may not be able to access certain Service features. For more information, including the types of cookies found on our Service and how to control cookies, please read our Cookie Policy.

Google Analytics

Like many websites, we use Google Analytics for web behavior monitoring, a service that provides information about how many users visit our website and online resources, when they visit, and how they navigate our website. We also may use other Google Analytics tools, such as Demographics and Interest Reporting, which enable us to learn more about the characteristics and interests of the users who visit our website, and Remarketing with Google Analytics, which enables us to provide relevant advertising on different websites and online services.

To learn more about Google’s privacy practices, please go to Google Privacy Policy at: https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt- out Browser Add-on to prevent your data from being used by Google Analytics at: https://tools.google.com/dlpage/gaoptout.

User Content

Some features of our Service may include functionality enabling you to post user content, whether publicly posted or privately transmitted, such as profiles, posts, emails, feedback, experiences, suggestions, notes, messages, photos, and videos (“User Content”) that may be made available to Ani and other users of the Service.

You should be aware that any User Content you provide or post in public media may be read, collected, and used by others who access them, and we have no control over these media. Please exercise caution before and when you choose to share personal information on our blogs, forums or in any other public media.

Ani at its sole discretion, has the right (but not the obligation) to screen, reject, retain, or remove any User Content on our Service that infringes Ani’s or any third party’s intellectual property or other rights, violates our Terms and this Privacy Policy or our other policies, or is otherwise objectionable.

By sending User Content, you grant Ani a perpetual, irrevocable, worldwide, royalty-free, freely transferable and sub-licensable, non-exclusive right to use, reproduce, modify, transmit, translate, publish, publicly perform, display, distribute, commercialize, share with third parties, transmit or distribute over public network and media, and create derivative works of such User Content for purposes specified in Ani Terms of Service and for delivering the Service to you and other users of the Service.

Services Processors

Where applicable, Ani may engage accredited laboratories, sequencing facilities, data- hosting providers, or logistics partners (collectively, “Service providers” or “Processors”) to assist with the collection, storage, processing, or analysis of biological or digital data.

These providers may include, for example, laboratories performing sample sequencing, biobanks storing biological materials, cloud service providers hosting digital datasets, or authorized logistics companies managing sample collection and transportation.

All service providers handling identifiable or pseudonymized data operate under written agreements or standardized contractual terms, such as industry-standard Data Processing Addenda (DPAs) provided by certified cloud providers, that ensure confidentiality, data security, and compliance with applicable data-protection laws.

In cases where samples or datasets are fully de-identified or anonymized such that no individual can reasonably be identified, Ani may share or process them without such agreements, consistent with applicable data-protection laws and ethical research standards.

Medical History

During participation in research studies or when using Ani Services, we may collect information related to your medical history, health status, lifestyle, or symptoms. Such information may be collected directly from you (for example, through questionnaires or digital forms within the Ani platform) or indirectly through Ani’s network of partners, including healthcare providers, research institutions, and associated physician or laboratory networks.

This information is used for the provision of Ani Services, which may include research, analysis, generation of Test Data or Test Results, and communication of related insights to you or your authorized research site.

In addition, pseudonymized or de-identified medical data may be used by Ani for scientific research and the development of commercial products, such as diagnostic tools, digital algorithms, nutritional formulations, or wellness programs. Such use occurs in compliance with applicable data-protection laws and ethical research standards, without identifying any individual participant.

For research studies conducted jointly with or on behalf of Ani’s partners, including healthcare providers, research institutions, or laboratory networks, specific contractual agreements are in place to govern data sharing, data protection, and ownership of results. These agreements ensure that all parties handle data in accordance with applicable privacy laws and ethical research standards.

All medical history information is processed for research, analytical, and informational purposes only and is not used for medical diagnosis or treatment.

Ani retains ownership of any aggregated, pseudonymized, or de-identified datasets and derivative insights generated through its research and product development activities.

Order Data and Test Results

In the course of providing Ani Services, including both research activities and test-based offerings, Ani may process information related to orders placed on your behalf by an authorized healthcare provider, researcher, or partner institution (“Authorized Partner”). Such orders may involve the shipment of sample-collection kits, supplements, or related materials, as well as the delivery of Test Results and analytical outputs generated by Ani.

Ani collects and processes order-related information, which may include your coded identifier, contact information (where applicable), the type of test or kit ordered, and logistical details necessary to complete the order. Where required for fulfillment, Ani may share limited information with logistics or distribution partners to arrange shipment and delivery of kits, biological-sample containers, or supplements. These partners process data only as necessary to perform their delivery functions under strict confidentiality and data-protection obligations.

For research studies and clinical collaborations conducted through Ani’s Ani Medical Product Suite as part of Ani Digital Platform, study activities may be coordinated using Ani’s secure digital dashboard. Within this environment, authorized research or clinical partners may access pseudonymized operational data, such as sampling timelines, receipt confirmations, and alerts or notifications related to potential adverse events, to ensure study oversight and participant safety.

When studies are conducted by Ani’s external research partners, Ani may not have access to direct participant identifiers. In such cases, Ani processes only coded or pseudonymized data, and any link between the code and a participant’s identity is held exclusively by the partner research site or clinical administrator.

Test Results and related outputs are stored and transmitted through secure systems and made available only to you, your Authorized Partner, or other parties you have explicitly authorized. Ani does not release personally identifiable Test Results to any third party without your consent or a lawful requirement to do so.

Ani may use trusted service providers and subprocessors (such as accredited laboratories, cloud-hosting providers, or logistics partners) to support the secure storage, processing, or delivery of Test Results and related Services. These entities act solely on Ani’s behalf and under written Data Processing Agreements (DPAs) where applicable, or equivalent contracts that ensure compliance with applicable privacy laws. No additional consent is required for such processing, as it forms part of the Ani Services described in this Privacy Policy.

Other Types of Information

From time to time, we may collect other types of information automatically about your use of our Service through the log files. Such information may include your device’s Internet Protocol (IP) address, operating system, browser type, and your device ID. Ani uses this information for purposes such as analyzing trends, administering the Service, providing, and improving Participant service, diagnosing problems with our servers, monitoring the security of our website and systems, tracking user movement, and gathering broad demographic information for aggregate use.

We may collect information about you or your interactions with our website, directly or indirectly through our authorized third party chatbot service provider, for the purpose of providing you with guidance on use of our website or better Participant service. The terms governing use of your personal information by such chatbot service are subject to the terms of the legally binding contractual agreements with Ani. Use of your personal information, interaction with our website, and conversation record or content by such chatbot services are generally limited for the purpose of providing their service to us and for fulfilling their contractual obligations. They may however use de-identified information about you for improving their chatbot and for other services as specified in their contractual agreements with us.

By using our websites and our Services, you agree to this Privacy Policy and provide express consent for our chatbot service, on our behalf, to retain a record or transcription of your interaction with our website or chatbot service. Any information collected by our chatbot service will be used by us in manners consistent with this Privacy Policy. All other information we receive directly or indirectly through the above methods, from you, our website, social media, referral, or a third party associated with you will be used in manners consistent with this Privacy Policy.

Information on our Services

To participate in Ani Services, you may be enrolled in a research study, request access to a specific test or program (“Test Request”), receive a kit or subscription as part of a study or partner collaboration, or obtain a kit or subscription directly from Ani or through one of Ani’s authorized partners.

Upon enrollment or order confirmation, you may be required to create an Ani Account, register your Kit or Subscription Service, and, where applicable, collect and submit your biological Sample according to the instructions provided in the Kit and within the timeframe specified in your study or Service materials.

Ani may also receive orders or authorizations for participation from your healthcare provider, research site, or authorized partner acting on your behalf. In all cases, the collection, shipment, and processing of Samples are conducted in accordance with Ani’s quality and privacy standards, and Samples are pseudonymized immediately upon receipt for testing and analysis.

Depending on our needs we may use certified and licensed third-party service facilities in the for testing and Sample collection services. Our partner laboratories will use your Samples associated with our Services for testing, analysis and generation of Sample Data that will be used to generate Test Data. Test Data is used with Self-Reported Data in conjunction with our data analysis methods and artificial intelligence engine that we use for generating the Test Results that we use in order to provide personalized diet, lifestyle, supplements, and other intervention recommendations, and providing you with Ani Supplements and Subscription Services.

During the Kit Registration, Test Requests, and at various stages of using our Services, you will be requested to review this Privacy Policy, Terms of Service, and other relevant documents (such as study specific Consent Forms and questionnaires) and accept them. By accepting these documents, you consent to use of your information according to the terms specified in these documents, that include informed consent for use of your Samples, Sample Data, Test Data, Medical History, Test Requests, and other types of information for purposes specified herein and in our Terms in accordance with this Privacy Policy.

How We Use your Information
Ani will use and share your information (including Personal Information) in the ways that are described below and elsewhere in the Privacy Policy.

a) Provide you with the Services
We use your information to perform activities necessary for the provision, improvement, and safe operation of Ani Services. These activities include testing and analysis of biological and digital data, coordination of research studies, management of partner collaborations, delivery of Test Results, generation of insights and recommendations, production and customization of nutritional formulations such as Supplements and probiotics + prebiotics, and continuous improvement of Ani’s digital, scientific, and analytical capabilities.

Specifically, Ani may use your information to:
i) Establish and manage your Ani Account and maintain secure access to Ani’s digital platforms;
ii) Coordinate research and operational logistics, including shipment of sample-collection kits or supplements through Ani or its logistics partners;
iii) Process and analyze biological Samples and digital data for research, analytics, and generation of Test Results;
iv) Communicate with you, your authorized research site, or partner institution about your participation, including updates, notifications, delivery confirmations, or relevant study communications;
v) Provide and improve Ani Services, including development of personalized insights, recommendations, and formulations based on aggregated and pseudonymized data;
vi) Support and monitor research and clinical collaborations conducted through Ani’s authorized partners or the AniMedical Product Suite, including management of sampling timelines, data dashboards, and alerts related to study safety or adverse events;
vii) Conduct scientific research and development, including projects performed by Ani or in collaboration with Ani Research Institute or partner organizations;
viii) Perform analytics and algorithmic modeling to enhance Ani’s artificial intelligence systems and improve the precision of data interpretation and personalization;
ix) Ensure compliance, security, and integrity of Ani’s systems by detecting, investigating, and preventing fraud, misuse, or prohibited activities; and
x) Develop new products and Services, including commercial offerings derived from aggregated, pseudonymized or de-identified data, such as analytical tools, digital biomarkers, or nutritional interventions.
All processing of identifiable or pseudonymized data is performed in accordance with applicable data-protection laws, and de-identified or aggregated data may be used for research and product development purposes consistent with Ani’s mission to advance scientific understanding of health and longevity.
We may also use your information to fix bugs or issues, analyze the use of our website, charge recurring Subscription Fees, to improve or optimize the Participant experience and Participant Service, or assess the efficacy of our marketing campaigns.
For individuals located in Europe and in certain Designated Countries, we process your Personal Data in compliance with the applicable law, in the same way in accordance with this Privacy Policy and our Terms of Service.
Ani may deliver certain Services and research activities through its affiliated entities and subsidiaries, including those located outside your country of residence (for example, Ani’s subsidiary in Croatia). All such entities operate under Ani’s unified data-protection policies and contractual safeguards to ensure compliance with applicable privacy laws and ethical research standards.
Ani processes personal data only where permitted by applicable law.
For Participants located in the European Union, the United Kingdom, or other jurisdictions applying similar data-protection laws, Ani relies on the following legal bases: (i) Explicit consent (Articles 6(1)(a) and 9(2)(a) GDPR) — when Participants voluntarily provide biological or digital data for analysis, testing, or research; (ii) Scientific research purposes (Articles 9(2) (j) and 89 GDPR) — when Ani or its partners use pseudonymized or de-identified data for research, algorithmic development, or product improvement; (iii) Performance of a contract (Article 6(1)(b) GDPR) — when processing is necessary to provide requested Services, such as shipping kits or delivering Test Results; (iv) Legal obligations (Article 6(1)(c) GDPR) — to comply with recordkeeping, accounting, or reporting requirements; and (v) Legitimate interests (Article 6(1)(f) GDPR) — to maintain platform security, improve user experience, and support business operations, provided such interests are not overridden by Participant rights.
For Participants located in the United States or other jurisdictions outside the EU, Ani processes information with the Participant’s consent and in accordance with applicable privacy and consumer-protection laws (including the California Consumer Privacy Act and Federal Trade Commission standards).
All processing of identifiable or pseudonymized data is conducted under appropriate contractual, organizational, and technical safeguards, and de-identified or aggregated data may be used for research, product development, and analytical purposes consistent with Ani’s mission to advance scientific understanding of health and longevity.

b) Provide Research and Partner Services
Ani collaborates with research institutions, clinics, and healthcare partners (“Research Partners”) who may enroll participants, collect biological samples, or manage aspects of data collection using Ani’s systems and infrastructure (for example, the AniMedical Product Suite).
In these cases, Ani may receive order-related or coded participant information (such as sample IDs, kit registration data, or test identifiers) from the Research Partner in order to process samples, generate analytical results, and provide data back to the Research Partner through secure digital environments (“Partner Services”).
Ani and its Research Partners operate under written agreements that define their respective responsibilities, data access rights, and ownership of results. When data are processed within such collaborations, Ani uses pseudonymized or coded data and does not have access to direct participant identifiers unless explicitly authorized by the Research Partner or the participant.
Ani may share limited information with logistics or data-processing providers (for example, laboratories, sequencing facilities, or shipping partners) when required to fulfill study or service operations. All such entities operate under confidentiality and data-protection agreements and may not use the data for any other purpose.

c) For Research and Research Studies
When you use our Services, Ani may use your Personal Information, and other data at individual-level or otherwise (in de-identified, pseudonymized, or aggregate forms) for providing an improved Service and ongoing research conducted by Ani that help us better understand health and longevity at individual as well as at population scale (“Population Research”). The information we use in Population Research is often summarized, aggregated, or combined across a group of subjects to minimize the chance of identification.
With your consent as expressed by acceptance of this Privacy Policy presented to you at Registration, Test Request, or while using the Service, Ani may use your information in Ani lead clinical studies and scientific research activities identified by Ani study protocols that support a specific diagnosis of a disease, to improve our Service, development of a treatment, or predict certain health conditions.
Such research cases are important aspects of our Service. The primary aim of research is to improve our Service using the data we gather from such activities. Ani conducts and supports ongoing research aimed at advancing scientific understanding of biological, cognitive, and environmental factors that influence human health, longevity, and well-being.
By choosing to participate in these studies, you contribute to research that may help improve Ani’s Services and lead to new scientific discoveries in areas such as microbiota, gene expression, and affectoneuroimmunology.
The insights gained from these studies are intended to benefit the broader scientific and medical community and may, over time, contribute to better prevention, wellness, and longevity solutions for society as a whole. While your individual participation does not guarantee a direct personal benefit, your contribution helps expand the collective knowledge that supports innovation in human health.
The research activities may include but not limited to conducting data analysis to develop new or improve existing Services, perform quality control, and identifying potential areas or targets for specific diet or lifestyle recommendations. Research activities may encompass population- scale studies, development of a specific diagnosis or treatment, predict certain health conditions, or develop scientific knowhow, technology, discoveries, and intellectual property assets that improve healthcare for the population as a whole. They may also include publishing study results in peer reviewed scientific journals publications and commercialization activities.
Research activities may also entail use of your Personal Information (including Medical Information), for selecting candidates suitable for a particular research study for identifying the correlations between dietary and lifestyle inputs and illness or wellness at molecular levels.
As a result, we may reach out to you from time to time with requests for additional information about you, your diet, lifestyle, or certain conditions by way of surveys and questionnaires as well as additional consents as necessary. When we do, you have the opportunity to choose which surveys to take, which questions to answer and grant us or decline your specific consent for such research activities. By choosing to answer, you are granting us the consent for such research activities.
Unless required by law or a court order, Ani will not release your individual-level Personal Information to any third party not identified in this Privacy Policy without first receiving your explicit consent by way of acceptance of a Consent Form.
For individuals located in the European Union (“EU”): Our legal basis for processing your Sensitive Data for the purposes described above is based on your consent. Please read below on Data Privacy for EU Residents Under GDPR for further details.

d) For Study Participations
From time to time, Ani may engage in additional certain study specific research in collaboration with third parties such as non-profit foundations, academic institutions, healthcare organizations, or commercial research partners with the intent to study about a specific disease condition or a segment of the population (“Study Participations”). In the event we identify you as a potential participant in a specific Partner Study Participation that requires use of individual-level Personally Identifiable Information, we will reach out to you for obtaining study specific informed consent applicable to such Study Participations.
Study Participations are governed by specific regulations and require approval by an independent review board (“IRB”) and your informed consent by way of acceptance of a study specific optional informed consent form that contains specific details on the study, collaborator, and the type of information we collect and share.
Some of these Study Participations are aimed at publication in peer-reviewed journals and other research publications. Study Participations are completely optional and voluntary for participants, and if you wish, you can choose to decline to accept the consent forms or choose not to respond.
Study Participations may require use of Personal Information by way of collection and analyses of physiological and molecular data such as Samples, individual Clinical Data, Test Data, and Self Reporting Information. When you have accepted a study specific consent form for Study Participations, we may share your Personal Information with the identified third-party study collaborators. Ani employs industry standard controls and safeguards in protecting and using your Personal Information for Study Participations as specified in the consent form and in accordance with the terms of this Privacy Policy.
When you have consented to Study Participations by way of accepting a study specific informed consent form, we may store and use your Sample Data and other Personal Information for current and future Study Participations. In addition, based on your Personal Information, if you were a potential fit for other Study Participations, we may contact you at any time of Service via email, website, or mobile application, with a notification for specific Study Participation and acceptance of a study specific consent form. You may choose to accept, decline, or choose not to respond to these invitations and consent forms. In the event you have not accepted a consent form or an invitation for Study Participation, you may still choose to join Study Participations in the future. Similarly, if you have accepted an invitation and a consent form and you do not wish Study Participations, you may decline to participate by withdrawing your consent.
For example, if a university or a collaborator tells us about a new research project on a specific condition, we may send you the study specific details and a consent form to make you aware of the Study Participation. Ani scientists may run, in such a case in collaboration with a university, an extensive clinical study program focused on developing science-based personalized nutrition algorithms towards treatment, prevention, and reversal of a chronic disease.
In the event if you do not wish to receive the Study Participation notifications, you can send a request to our Studies Team using the details below:

By Email:
Send in a request with the subject line Assistance with “Study Notifications” using info@ani.ai

By Mail:
ANI BIOME PBC
Ani Labs
525 Market Street Suite 700
San Francisco 94158
California

What happens if you do NOT sign or accept a consent form?
If you choose not to accept the consent form applicable to a Study Participation, your Individual-level Personal Information will not be used for Study Participations or shared.