PRIVACY POLICY

Privacy questions?
[email protected]

Gmax Central, LLC d/b/a Cleverpetz ("Cleverpetz," "we," "us," or "our") is committed to protecting the privacy of our customers and their pets. This Privacy Policy explains how we collect, use, disclose, and safeguard your information — including pet DNA data — when you use our website (cleverpetz.pet), mobile application, or related services (collectively, the "Services"). This policy complies with applicable privacy laws including the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR) for EU/UK customers, and the Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian customers. By using our Services, you consent to the practices described in this Privacy Policy.

We collect the following categories of information: PERSONAL INFORMATION • Name, email address, shipping address, and phone number • Payment information (processed securely by Stripe — we do not store card numbers) • Account credentials (username and password) • Purchase history and order details PET INFORMATION • Pet name, species, breed, age, and weight • Health history and conditions (if voluntarily provided) • Veterinarian contact information (if voluntarily provided) PET GENETIC DATA (DNA DATA) • Raw genetic marker data extracted from your pet's DNA sample • Breed composition analysis results • Genetic health predisposition indicators • AI-generated wellness recommendations based on genetic data USAGE DATA • IP address, browser type, device identifiers • Pages visited, time spent, clicks, and navigation patterns • Search queries within our Services • Cookie and tracking data (see Section 7)

Pet DNA data is treated with the highest level of care under this policy. The following specific provisions apply: PURPOSE LIMITATION We use pet DNA data exclusively for: (a) Generating personalised wellness supplement recommendations (b) Improving the accuracy of our AI recommendation engine using anonymised, aggregated data (c) Providing breed and genetic health reports to you We will NEVER: ✗ Sell your pet's individual genetic data to third parties ✗ Use pet DNA data for insurance underwriting purposes ✗ Share identifiable genetic data with employers, insurers, or government agencies without your explicit consent or a valid legal requirement ✗ Use pet DNA data for purposes unrelated to pet wellness DATA RETENTION • Raw DNA sample data: retained for up to 24 months to allow re-analysis as our AI improves • Processed genetic reports: retained for the lifetime of your account • You may request deletion of your pet's genetic data at any time (see Section 9) LABORATORY PROCESSING DNA samples are processed by certified third-party laboratory partners under strict confidentiality agreements. Laboratory partners are prohibited from retaining or using genetic data beyond the scope of sample analysis. ANONYMISATION AND RESEARCH We may use anonymised, aggregated genetic data (with all personal identifiers removed) for: • Improving breed-specific wellness recommendations • Publishing general research findings about pet health trends • Training and validating our AI models

We use the information we collect to: • Process and fulfil your orders and subscriptions • Generate AI-powered wellness recommendations based on your pet's DNA profile • Send order confirmations, shipping updates, and account notifications • Respond to customer service inquiries • Send marketing communications (with your consent, and you may opt out at any time) • Improve our products, Services, and AI recommendation accuracy • Detect and prevent fraud and security incidents • Comply with legal obligations • Enforce our Terms of Use Legal bases for processing (GDPR): contract performance, legitimate interests, consent, and legal obligation.

We do not sell your personal information. We may share your information with: SERVICE PROVIDERS Trusted third-party vendors who assist us in operating our Services, including: • Stripe (payment processing) • Certified DNA laboratories (sample analysis only) • Shipping carriers (fulfilment) • Email service providers (communications) • Cloud hosting providers (data storage) All service providers are bound by confidentiality agreements and are prohibited from using your data for their own purposes. LEGAL REQUIREMENTS We may disclose your information if required by law, court order, or government authority, or to protect the rights, property, or safety of Cleverpetz, our customers, or the public. BUSINESS TRANSFERS In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you before your information is transferred and becomes subject to a different privacy policy.

We implement industry-standard security measures to protect your information, including: • SSL/TLS encryption for all data transmitted to and from our Services • AES-256 encryption for stored genetic data • Access controls limiting employee access to personal data on a need-to-know basis • Regular security audits and penetration testing • Secure destruction of physical DNA samples after laboratory processing No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

We use cookies and similar tracking technologies to enhance your experience. Types of cookies we use: • Essential cookies: Required for the website to function (login sessions, cart) • Analytics cookies: Help us understand how visitors use our site (Google Analytics) • Marketing cookies: Used to deliver relevant advertisements (with your consent) You can control cookies through your browser settings. Disabling certain cookies may affect website functionality. For EU/UK visitors, we obtain consent before setting non-essential cookies.

Depending on your jurisdiction, you may have the following rights: ALL CUSTOMERS • Right to access: Request a copy of the personal information we hold about you • Right to correction: Request correction of inaccurate data • Right to deletion: Request deletion of your personal information and pet DNA data • Right to opt out: Opt out of marketing communications at any time CALIFORNIA RESIDENTS (CCPA) • Right to know what personal information is collected, used, shared, or sold • Right to delete personal information • Right to opt out of the sale of personal information (we do not sell personal information) • Right to non-discrimination for exercising privacy rights EU/UK RESIDENTS (GDPR/UK GDPR) • Right to data portability • Right to restrict processing • Right to object to processing based on legitimate interests • Right to lodge a complaint with your supervisory authority CANADIAN RESIDENTS (PIPEDA) • Right to access and correct personal information • Right to withdraw consent To exercise any of these rights, contact us at [email protected].

Our Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected such information, please contact us immediately at [email protected].

Cleverpetz is based in the United States. If you are located outside the US, your information may be transferred to and processed in the US, where data protection laws may differ from those in your country. For EU/UK customers, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission for international data transfers.

We may update this Privacy Policy periodically. We will notify you of material changes by email or by posting a prominent notice on our website. The "Effective Date" at the top of this policy indicates when it was last revised. Your continued use of our Services after changes are posted constitutes your acceptance of the updated policy.

For privacy-related inquiries, requests, or complaints: Privacy Officer Gmax Central, LLC d/b/a Cleverpetz 500 Westover Dr #92909 Sanford, NC 27330 Email: [email protected] Phone: 1-800-658-5417 For EU/UK GDPR inquiries, our EU Representative can be contacted at: [email protected]