Privacy Policy

1. Who We Are

Om Therapeutics Inc., 3210 Merryfield Row, San Diego CA 92121 USA ("OMTX," "we," "us") provides software, APIs, and related services that incorporate machine‑learning ("ML") techniques. This Privacy Policy ("Policy") explains our global data‑handling practices.

2. Scope

This Policy governs personal information collected when you:

• visit an OMTX website or app that links to this Policy;
• create an account or subscription;
• interact with the Diligence tool, API, SDKs, plug‑ins, or any other product developed by Om Therapeutics, Inc.;
• purchase products or paid subscription plans that may be offered (including Private Data Generation services); or
• contact us or participate in events, surveys, or promotions.

3. Key Definitions

"Personal information" means any data that identifies, relates to, describes, or can reasonably be linked to an individual.
"Service Data" means text, files, prompts, and other content you submit or generate.
"Model Training" means using Service Data to develop, fine‑tune, or evaluate OMTX ML systems.

4. Information We Collect

5. How & Why We Use Data

*Lawful bases for EU/UK data subjects are detailed in Section 6.

5.1 Model‑Training Policy

We use the protein sequences you submit and the computational outputs we generate to train and improve our ML models as an integral part of the Services.

What we use for model training:

• Protein sequences you submit
• Computational outputs and predictions we generate

What we NEVER use for model training or sale:

• Your personal information (name, email, etc.)
• Payment information
• Any other account data

Note on Support Communications: We may use customer support communications internally to improve product features and support quality. These communications are not used for model training, are never sold to third parties, and are not used for any external purposes.

We apply data‑minimization and de‑identification techniques so that Service Data used for model training is not linked back to individual accounts.

Private Data Generation services provide exclusivity (your outputs won't be sold to others) but still contribute to model improvement.

6. Legal Bases (EU/EEA/UK GDPR & Comparable Laws)

Model training and evaluation are integral to the Services. Users who do not agree to this processing cannot use the Services. This requirement is based on contractual necessity (GDPR Art. 6 (1)(b)), not on separate consent under Art. 6 (1)(a).

7. Disclosures to Third Parties

We do not sell personal information for money. We disclose data only to:

• Service providers (cloud hosting, analytics, customer support) under strict contracts;
• Affiliates & acquirers in corporate transactions;
• Authorities when legally required;
• Others with your explicit direction.

8. Your Rights & Choices

8.1 Account Closure & Model Training

Upon account closure, we will cease using your Service Data for future model training. However, Service Data that has already been incorporated into our models cannot be removed retroactively. This is why we require explicit consent before you use our Services.

8.2 Private Data Generation

When you purchase Private Data Generation services:

• Your results are clearly labeled as confidential/private to you;
• Private Outputs are NOT sold or redistributed via Standard Data Access;
• You receive a minimum 30‑day exclusivity window for your sequences;
• Private Outputs still contribute to ML model training (with your consent);
• After the exclusivity window, substantially similar results may become available ONLY if we independently generate them from non‑confidential third‑party sources;
• In such cases, we will identify the third‑party source (not your private submission).

8.3 Data‑Use Agreement & Account Closure

Because model training is a core feature of the Services, your use of the Services constitutes agreement to this processing. You may close your account at any time; after closure, we will stop using your Service Data in future training runs, but we cannot retroactively remove prior influence from already‑trained models.

9. California Supplement (CPRA)

9.1 Notice at Collection

We collect the categories of personal information listed in Section 4 for the purposes set out in Section 5, except that personal information is NEVER used for ML model training. Only Service Data is used for model training.

9.2 No Sale/Share

We do not sell or share personal information as those terms are defined by CPRA. If this ever changes, we will update this Policy and provide any legally required mechanisms.

9.3 Financial Incentives

We do not offer a financial incentive program under CPRA. Participation in our Services requires the use of Service Data for model training; therefore, withdrawal from that processing means discontinuing use of the Services.

10. Data Security

We implement security measures through trusted third‑party providers including:

• Cloud infrastructure providers for secure data storage and processing
• Authentication services to ensure only authorized users access their data
• Encryption for data in transit and at rest
• Role‑based access controls

No system is perfect, but we follow industry best practices for data security.

11. Data Retention

We retain data as long as needed to provide and improve the Services and for legitimate business and legal purposes. Data incorporated into trained models cannot be removed retroactively.

12. International Transfers

Your data may be processed in the United States where our servers are located. Where applicable, we rely on appropriate safeguards (e.g., Standard Contractual Clauses) for cross‑border transfers.

13. Children

Services are not directed to children under 13 (or under 16 in the EEA). We do not knowingly collect data from children.

14. Changes

We may update this Policy. Material changes will be announced on our site and, where required by law, we will seek renewed consent.

15. Contact