Privacy Policy 14th March 2012

This notice describes the privacy policy of Gene Action Ltd, its parents, affiliates, and subsidiaries (collectively, "GeneAction") as it pertains to information collected on the GeneAction website at http://www.Gene-Action.com (the "Website"). We may, from time to time, revise this privacy policy, and the date of last revision will be available at the top of this page, so please be sure to check back periodically.

What information we collect: GeneAction may request personally identifiable information from you in the event that you submit a test request form on our Website, or in certain other areas of the Website. The information requested depends on the purpose for which you provide it, but you may be asked to provide your name, address, phone number, email address, as well as certain health-related information. However, most areas of the Website are accessible without providing personally identifiable information.

GeneAction may combine the information you provide with information we collect from other sources for internal analytical purposes only. For clarity, the information we describe in this policy does not include your personal biological samples. Please see "Your DNA" section below and our policy for "Privacy & Security Concerning You DNA and Biological Samples."

How GeneAction uses your information: GeneAction may use the information we collect on the Website for the following purposes:

• To process and respond to inquiries and orders.
• To contact you about your Respiragene test request form or other requests you may make through the Website.
• For the purposes for which you provided the information.
• To improve the content and navigability of the Website.
• To alert you to new products, services, events, and Website features.
• To customize the advertising and content you see.
• To generate anonymous and/or aggregated reporting.
• To enforce the legal terms that govern your use of the Website.

Persons who assist GeneAction in providing the functions described in the previous section may have authorised access to your personal information.

We may anonymise or aggregate your information for business purposes, including for reporting and research. Anonymous and/or aggregated data does not identify you, and Gene Action may use and disclose such information without limitation.

In the future, we may sell some or all of our assets. In such transactions, non-genetic customer information generally is one of the transferred business assets. In the event of a sale of our assets including our database, customer information may be transferred.

Who GeneAction shares the information with: GeneAction may disclose your personal information, including your health-related information, to non-affiliated third parties when we have your consent to do so, including but not limited to when you ask us to forward a screening test request form to an affiliated Doctor; when we respond to a subpoena, legal order or official request; or when we believe you have acted in violation of the legal terms that govern your use of the Website. In addition, we may disclose non-health related information to selected partners or other third parties who offer products or services we think may be of interest to you, and you will have the opportunity to opt-out of such disclosure.

Other Data Collection: In addition to the information you knowingly provide, GeneAction may collect the domains and IP addresses of its visitors. We also may collect usage statistics such as web browser types and page requests. This data is used to more efficiently operate GeneAction, promote our services and administer the Website.

Your DNA: Neither GeneAction or the performing laboratories which process your test will assert ownership over your DNA. We pledge to use your DNA only for the purposes which you specifically authorise.

GeneAction and the performing laboratories will not store your DNA for any longer than is commercially necessary or for such time as required by applicable law.

Neither Gene Action or the performing laboratories will sell, share or transfer, or hold with the intention of selling, sharing or transferring, your DNA or any data derived from tests or assays performed on it, to any other party for any reason apart from the purposes which you specifically authorised the performance of the Respiragene™ test on your sample.

Gene Action and the performing labs will require you to consent to the processing of your test, and to confirm that the DNA sample which you submit as yours is your own, and does not belong to someone else, as part of the test request process.

Cookies: "Cookies" are small elements of data that a website can send to your browser, which may then store it on your system. For example, some pages on our Website may use cookies so that Gene Action can provide you easier access to certain content, or track your preferences to improve your Website experience. Depending on your browser type, you can probably set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. However, please note that disabling cookies may prevent you from taking advantage of certain features on the Website.

Gene Action may allow ad networks, such as third party ad servers and ad agencies, to serve advertisements within our web pages. We may also place web beacons for these companies within our pages. Because your web browser must request these advertisements and web beacons from the ad network's servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

How we protect information: GeneAction attempts to protect against the loss, misuse and alteration of your personal information. Our servers are protected by reasonable physical and electronic security measures.

How you can update your personal information or preferences: You can update your information at any time by emailing us using the contact page. We will use reasonable efforts to process any change you make, or your request for deletion. Under certain circumstances, we may be unable to delete information for legal or business reasons.

If you no longer wish to receive marketing communications from GeneAction, please email us or click the opt-out link in any marketing email you receive from us. If you wish to change your preference with regard to offers of products and services from third parties, please email us.

Links: The Website may contain links to third-party websites. GeneAction is not responsible for the privacy practices or the content of such websites.

Contacts: If you have any questions, concerns, or suggestions regarding this privacy policy, please contact us at Info@Gene-Action.com.