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BASED ON GENES

Canada Privacy and Complaint Procedure

Accountability, access, correction, complaints and breach handling under PIPEDA.

Effective: 14 August 2026

1. Accountability and Privacy Officer

Linus Ammer, handelnd unter Abakos-Systeme, Schönrain 10, 84152 Mengkofen, Germany, is accountable for personal information controlled by Based on Genes. Linus Ammer is the designated Privacy Officer. Contact: contact@basedongenes.com, telephone +49 152 27640571.

The genome file and score results remain on the device. Canadian purchases involve cross-border processing only of the preview, purchaser-name, order, contract, consent, licence, payment and refund data described in the general Privacy Information.

2. Requests, access and correction

Requests may be sent to contact@basedongenes.com or the provider's postal address. Include “Canada privacy request”, the order reference where available and the email used. Additional information is requested only where needed for secure matching.

We acknowledge requests, explain use and disclosure of matched data and provide correction or annotation. We generally respond within 30 days. Any extension permitted by PIPEDA is communicated with its length and reason within the first 30 days; a legally required refusal is reasoned and identifies the complaint route.

3. Complaint handling

The Privacy Officer records and investigates complaints, considers additional information and provides the outcome, reasons and any remedial steps in writing. Substantiated errors are corrected. A person may then complain to the Office of the Privacy Commissioner of Canada; mandatory provincial rights remain unaffected.

4. Privacy breaches

Every known loss, unauthorised access or unauthorised disclosure is assessed. Where there is a real risk of significant harm, the Office of the Privacy Commissioner of Canada and affected persons are notified as soon as feasible. Legally required breach records are retained for at least 24 months regardless of severity.

5. Openness and changes

Purposes, recipients, retention periods and safeguards are described in the general Privacy Information. Material changes are published, and fresh consent is obtained before a new purpose that a person would not reasonably expect.

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