Important Information

1. About Modulus Bio — 30x Whole Genome Sequencing

Modulus Bio is an optional add-on service available with any Modulus Health Group membership tier. It provides clinical-grade 30x whole genome sequencing (WGS) — a comprehensive analysis of your entire DNA sequence — performed by a CLIA-certified, CAP-accredited laboratory.

Unlike consumer genotyping services that test a limited number of genetic variants using microarray chips, 30x whole genome sequencing reads your complete genome at an average depth of 30 times per base pair. This provides substantially greater coverage and the ability to detect a broader range of genetic variants, including single nucleotide variants (SNVs), insertions and deletions (indels), copy number variants (CNVs), and structural variants.

How Modulus Bio Differs from Consumer Genetic Tests

• Physician-ordered and physician-interpreted. Your genomic sequencing is ordered by a licensed Modulus Health Group physician and results are reviewed, interpreted, and integrated into your clinical care by your Provider. Consumer genetic tests are self-ordered and provide results without physician involvement.
• Clinical-grade laboratory. Sequencing is performed in a CLIA-certified, CAP-accredited laboratory operating under federal and state clinical laboratory regulations.
• Integrated with your medical history. Your genomic results are cross-referenced with your complete medical records — symptoms, conditions, labs, imaging, medications, and family history — to provide clinically actionable insights specific to you.
• Ongoing re-analysis. As medical knowledge evolves, your genome can be re-analyzed against updated variant databases and clinical guidelines without re-sequencing.

2. Genetic Health Risk Findings

Your genomic analysis may identify genetic variants associated with increased risk for certain health conditions, including but not limited to hereditary cancers (e.g., BRCA1/BRCA2-related breast and ovarian cancer), cardiovascular conditions (e.g., familial hypercholesterolemia, hereditary cardiomyopathies), neurological conditions (e.g., late-onset Alzheimer's disease, Parkinson's disease), and other heritable disorders.

What Your Provider Will Do

All genetic health risk findings are reviewed by your Modulus Health Group physician. Clinically significant findings will be discussed with you during a consultation. Your Provider may recommend confirmatory testing through an independent laboratory, additional screening, preventive measures, referral to a specialist, or genetic counseling. You should not take any medical action based on genetic findings without first discussing them with your Provider.

3. Pharmacogenomic Findings

Your genomic analysis may include pharmacogenomic findings — information about how your genetic makeup may affect your body's ability to metabolize, transport, or respond to certain medications. Common pharmacogenomic genes analyzed include CYP2C19, CYP2D6, CYP2C9, CYP3A4, DPYD, SLCO1B1, VKORC1, and others.

How Pharmacogenomic Findings Are Used

Your Modulus Health Group physician will review pharmacogenomic findings as part of your overall care. If a clinically significant drug-gene interaction is identified, your Provider may adjust your medication, dosage, or monitoring plan. Your Provider may also share relevant pharmacogenomic findings with your other treating physicians (with your authorization) to support safe prescribing.

4. Carrier Status Findings

Your genomic analysis may identify whether you are a carrier for certain inherited conditions — meaning you carry one copy of a genetic variant that, if present in two copies, could cause a condition in a child. Common conditions screened include cystic fibrosis, sickle cell disease, Tay-Sachs disease, spinal muscular atrophy, and many others.

What Carrier Status Means

• Being a carrier typically does not mean you have the condition. Most carriers are healthy and have no symptoms. However, for some conditions, carriers may have mild or variable symptoms.
• Carrier status is important for family planning. If both parents are carriers for the same autosomal recessive condition, each pregnancy has approximately a 25% chance of producing a child with the condition.
• Carrier findings may have implications for your relatives. Your parents, siblings, and children may also carry the same variant. Consider discussing your results with family members, keeping in mind that some people may not wish to know their carrier status.
• We do not test for every possible condition. A negative carrier result does not guarantee that you do not carry variants for conditions not covered by the analysis.

Your Provider will discuss any clinically significant carrier findings with you and may recommend genetic counseling, particularly if you are planning a pregnancy or have a family history of inherited conditions.

5. Limitations of Genetic Testing

While 30x whole genome sequencing is comprehensive, it is important to understand its limitations:

• No genetic test detects everything. Certain types of genetic variants, including some repeat expansions, complex structural rearrangements, epigenetic modifications, somatic (non-inherited) mutations, and variants in highly repetitive regions of the genome, may not be reliably detected by current WGS technology.
• Variants of uncertain significance (VUS). Your results may include variants whose clinical meaning is not yet known. These variants may be reclassified over time as scientific understanding improves. Your Provider will not take clinical action based on VUS findings unless supported by other evidence.
• Population data limitations. The clinical significance of many genetic variants has been studied primarily in populations of European descent. Variant databases may be less complete for individuals of other ancestries, which can affect the interpretation of results.
• Not a substitute for other diagnostic tests. Genetic testing does not replace standard medical evaluations, laboratory testing, imaging, or clinical examination. A normal genetic result does not rule out a medical condition.
• Results reflect current knowledge. Genetic science advances rapidly. Findings are interpreted based on current medical literature and variant databases at the time of analysis. Re-analysis at a later date may yield different interpretations.
• Technical limitations. In rare cases, sample quality, laboratory error, or technical factors may produce incomplete or inaccurate results. If your Provider has concerns about result quality, confirmatory testing may be recommended.

6. Emotional Impact and Genetic Counseling

We Recommend Genetic Counseling

We strongly encourage you to speak with a genetic counselor before and after receiving your results. A genetic counselor is a healthcare professional with specialized training in medical genetics and counseling. They can help you:

• Understand what genetic testing can and cannot tell you
• Decide whether testing is right for you
• Prepare for possible results, including unexpected findings
• Interpret your results in the context of your personal and family history
• Make informed decisions about screening, prevention, and treatment
• Discuss results with family members

To find a genetic counselor near you, visit the National Society of Genetic Counselors at www.aboutgeneticcounselors.org or ask your Modulus Health Group Provider for a referral.

Opt-Out Reports

Certain findings — particularly those for serious conditions with limited treatment options — may be excluded from your report at your request. During the Modulus Bio enrollment process, you may choose whether to receive or exclude findings related to specific high-impact conditions, such as late-onset Alzheimer's disease or hereditary cancer syndromes. You can change your preferences at any time by contacting your Provider.

7. Insurance and Employment Protections

Federal Protections — GINA

The Genetic Information Nondiscrimination Act of 2008 ("GINA") is a federal law that prohibits discrimination based on genetic information in two areas:

• Health insurance. GINA prohibits health insurers from using genetic information to make coverage or premium decisions. Health insurers cannot require you to take a genetic test or use your genetic test results against you.
• Employment. GINA prohibits employers with 15 or more employees from using genetic information in hiring, firing, promotion, or other employment decisions.

You should carefully consider these limitations before proceeding with genetic testing, particularly if you are planning to apply for life insurance, disability insurance, or long-term care insurance. Modulus Health Group cannot provide legal advice regarding the impact of genetic testing on your insurance eligibility.

State Protections

Some states provide additional genetic non-discrimination protections that exceed GINA. For example, several states prohibit the use of genetic information in life insurance and/or disability insurance underwriting. The specific protections available to you depend on your state of residence. Consult with an attorney or insurance professional if you have questions about how genetic test results may affect your insurance eligibility in your state.

8. How We Handle Your Genetic Data

We take the privacy and security of your genetic data seriously. This section summarizes how we collect, use, store, and protect your genetic data. For complete details, please review our Privacy Policy and Notice of Privacy Practices.

Collection

• Genetic data is collected only after you provide express, informed consent during the Modulus Bio enrollment process
• Your biological sample (saliva or blood) is collected and shipped to our CLIA-certified, CAP-accredited partner laboratory for sequencing
• Sequencing data (FASTQ, BAM, VCF files) is transmitted to Modulus Health Group via encrypted channels

Use

• Your genetic data is used for the primary purpose of providing your clinical care — analysis, interpretation, diagnosis, treatment planning, and pharmacogenomic guidance
• Genetic data is cross-referenced with your medical records to provide integrated, clinically actionable insights
• With your separate, voluntary consent, de-identified genetic data may be included in our outcomes research registry (see Section 5 of our Notice of Privacy Practices)
• We do not use your genetic data for marketing, advertising, or any purpose unrelated to your healthcare without your specific written consent

Storage and Security

• Genetic data is encrypted in transit (TLS) and at rest (AES-256)
• Stored in HIPAA-compliant cloud infrastructure with signed Business Associate Agreements
• Access is restricted to authorized clinical and technical personnel on a minimum-necessary basis
• All access is logged and audited

Biological Samples

• Your biological sample is used solely for the purpose of sequencing
• After sequencing is complete, your sample is destroyed by the laboratory unless you provide separate, express consent for storage
• You may request destruction of any stored sample at any time

Retention and Deletion

• Genetic data that is part of your medical record is retained for a minimum of ten (10) years in accordance with applicable federal and state law
• You may request deletion of genetic data that is not required to be retained by law
• De-identified genetic data included in the outcomes research registry (with your consent) may be retained indefinitely in de-identified form

Disclosure

• We do not sell your genetic data
• We do not disclose your genetic data to employers, insurers, or any third party for underwriting, employment, or eligibility purposes
• We do not share your genetic data with law enforcement except as required by a valid court order, warrant, or applicable law
• Your genetic data may be disclosed to other treating healthcare providers only with your authorization

9. California Genetic Information Privacy Act (GIPA) Notice

The California Genetic Information Privacy Act (Cal. Civ. Code § 56.18–56.186) ("GIPA") imposes specific transparency, consent, and data protection requirements on companies that collect genetic data from California consumers. Although Modulus Health Group operates as a licensed healthcare provider using genetic testing for diagnosis and treatment — and genetic data collected for clinical purposes is subject to HIPAA and the California Confidentiality of Medical Information Act (CMIA) — we provide this notice to ensure full transparency and compliance with the spirit and requirements of GIPA.

Collection, Use, and Disclosure of Genetic Data

We provide the following information regarding our practices with respect to genetic data collected from California residents:

• What we collect. Whole genome sequencing data (FASTQ, BAM, VCF files), variant analysis results, clinical interpretations, and any associated phenotypic information you provide.
• How we use it. For the primary purpose of providing clinical care: analysis, interpretation, diagnosis, treatment planning, pharmacogenomic guidance, ongoing monitoring, and re-analysis. With your separate consent, de-identified data may be used for outcomes research.
• Who has access. Your Modulus Health Group Provider, authorized clinical staff, and authorized technical personnel operating under our supervision. Our management services organization (Modulus AI, Inc.) processes genetic data as a HIPAA business associate under a Business Associate Agreement.
• How we share it. We do not sell, rent, lease, or trade your genetic data. We do not disclose genetic data to insurers, employers, or any entity for underwriting, employment, or eligibility purposes. We may disclose genetic data to other healthcare providers involved in your care with your authorization, to our CLIA-certified laboratory partner for sequencing, and as otherwise required by law.
• How we secure it. We implement and maintain reasonable security procedures and practices to protect genetic data against unauthorized access, destruction, use, modification, or disclosure, including encryption, access controls, audit logging, and staff training.
• Retention and deletion. Genetic data that is part of your medical record is retained for a minimum of ten (10) years. You may request deletion of genetic data not required to be retained by law. We will honor deletion requests as soon as practicable and no later than thirty (30) days.
• Biological sample destruction. Your biological sample is destroyed after sequencing is complete unless you provide separate, express consent for storage. You may request destruction of any stored sample at any time.

Your Consent Rights Under GIPA

Before we collect, use, or disclose your genetic data, we obtain your separate, express consent for each of the following:

• The collection and primary clinical use of your genetic data
• Storage of your biological sample after initial sequencing (if applicable)
• Any use of your genetic data beyond the primary clinical purpose
• Any disclosure of your genetic data to a third party (other than a service provider operating under contract)

You may revoke any consent at any time by contacting us at privacy@modulus.ai. We will honor your revocation as soon as practicable and no later than thirty (30) days.

Your Rights Under GIPA

• Access. You have the right to access your genetic data in a readily usable format.
• Deletion. You have the right to delete your account and genetic data, subject to our legal retention obligations for medical records.
• Sample destruction. You have the right to request destruction of your biological sample at any time.
• Non-discrimination. We will not discriminate against you for exercising any of your rights under GIPA.

De-Identified Data

With your consent, your de-identified genetic or phenotypic information may be used for research purposes in accordance with 45 C.F.R. Parts 46 and 164. De-identified data has had all HIPAA-defined identifiers removed and cannot reasonably be used to identify you.

Filing a Complaint

If you believe Modulus Health Group has violated your rights under GIPA, you may file a complaint with the California Attorney General or your local district attorney, city attorney, or city prosecutor. You may also contact us directly at privacy@modulus.ai. See Section 12 for complete complaint filing information.

10. Washington Consumer Health Data Privacy Policy

Categories of Consumer Health Data Collected

We may collect the following categories of consumer health data from Washington residents:

• Genetic data, including whole genome sequencing data and variant analysis results
• Health conditions, diagnoses, and symptoms you report to us
• Medication information
• Laboratory and imaging results
• Information about your healthcare providers and treatment history

To the extent that this data constitutes Protected Health Information (PHI) collected or maintained by Modulus Health Group in its capacity as a HIPAA covered entity, it is governed by HIPAA and our Notice of Privacy Practices rather than the MHMDA. For consumer health data not covered by HIPAA, the protections below apply.

Purposes for Collection

We collect consumer health data for the following purposes: providing clinical care, including diagnosis, treatment, and ongoing monitoring; processing and fulfilling your service requests; coordinating with laboratories, pharmacies, and other providers; quality assurance and improvement; and, with your separate consent, de-identified outcomes research.

Sources of Consumer Health Data

We collect consumer health data from: you directly (during enrollment, intake, and consultations); your authorized healthcare providers (via record retrieval); clinical laboratories performing testing on your behalf; and pharmacies and imaging facilities involved in your care.

Sharing and Disclosure

We may share consumer health data with: our affiliated physician entities and management services organization; CLIA-certified laboratories performing your sequencing or other testing; pharmacies for prescription fulfillment; other healthcare providers involved in your care (with your authorization); and service providers operating under contract. We do not sell consumer health data. We do not share consumer health data for advertising purposes.

Your Rights Under the MHMDA

• Consent. We will obtain your consent before collecting or sharing your consumer health data, except as permitted for providing healthcare services you have requested.
• Access. You have the right to confirm whether we are collecting, sharing, or selling your consumer health data and to access that data.
• Deletion. You have the right to request deletion of your consumer health data, subject to legal retention obligations.
• Withdrawal of consent. You may withdraw consent for the collection or sharing of your consumer health data at any time.
• No geofencing. We do not use geofencing technology around healthcare facilities to collect consumer health data.
• Non-retaliation. We will not retaliate against you for exercising your rights under the MHMDA.

For Washington state residents, genetic data consent defaults to off. We will not collect, process, or analyze your genetic data until you provide affirmative opt-in consent.

To exercise your rights under the MHMDA, contact us at privacy@modulus.ai or call +1 (480) 920-3000.

Washington Attorney General

If you believe your rights under the MHMDA have been violated, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint or call 1-800-551-4636.

11. Additional State-Specific Notices

In addition to California and Washington, the following state-specific notices apply to residents of those states:

12. How to File a Complaint

If you believe Modulus Health Group has violated your rights regarding your genetic data, you may:

• Contact us directly. We encourage you to reach out to us first so we can address your concerns. Email privacy@modulus.ai or call +1 (480) 920-3000.
• File a HIPAA complaint with the U.S. Department of Health and Human Services, Office for Civil Rights at www.hhs.gov/hipaa/filing-a-complaint or call 1-877-696-6775.
• File a state complaint:
  • California: California Attorney General at oag.ca.gov, or your local district attorney, county counsel, city attorney, or city prosecutor
  • Virginia: Virginia Attorney General at oag.state.va.us or call 1-800-552-9963
  • Washington: Washington Attorney General at atg.wa.gov/file-complaint or call 1-800-551-4636
  • All other states: Contact your state's Attorney General office

We will not retaliate against you for filing a complaint.

13. Contact Information

If you have questions about the information on this page, your genetic data, or your rights, please contact us: