# Terms of Service **Last updated: July 2026** ## 1. What this service is, and what it is not This service is for **information and research only**. This service: * Accepts a genotyping file that you voluntarily upload. * Produces a research-style report summarizing published scientific literature relevant to certain variants in your file. * Offers partial access to the report for free after upload, and unlocks the full report after a single one-time payment (see Section 7). * Is intended for adults who are curious about their own genetic data and want a starting point for further reading or for a conversation with a qualified clinician. This service is **not**: * A medical device, IVD, or clinical diagnostic tool. * A source of medical advice, diagnosis, treatment, prognosis, or prescription. * A substitute for genetic counseling. * A substitute for clinical-grade sequencing or for confirmatory testing. * A source of actionable findings for reproductive, pharmacogenomic, oncological, cardiovascular, neurological, or any other clinical decision. * A forensic identification tool. * An ancestry, ethnicity, or paternity service. * Insurance, employment, or eligibility documentation. This is data assembled and summarized by Large Language Models from public scientific sources. It contains errors. The only correct mental model is: *"interesting starting point for a conversation with a qualified clinician"*. Not *"my report says I have/don't have X, therefore…"*. **Always consult a qualified medical professional** before taking, changing, or stopping any treatment, supplement, diet, exercise, or lifestyle decision on the basis of anything you read here. By using this service you confirm that you have read, understood, and accepted everything in this document. If you do not accept it, do not use the service. --- ## 2. AI-generated content disclosure In line with the EU AI Act transparency principle, we state it plainly: **most of the textual content of your report is generated by Large Language Models**. Our pipeline retrieves, ranks, summarizes, and cross-references scientific sources, and produces prose describing what the literature says about each variant. A human did not write each sentence. A human cannot review every sentence at the scale at which the system operates. LLMs are known to *hallucinate*: produce confident-sounding text that is partially or entirely incorrect. We mitigate this with retrieval grounding, source attribution, multi-stage filtering, and conservative suppression - and we will never eliminate it. Treat every claim in the report as needing independent verification before any decision is made on it. ## 3. Sources we draw from The pipeline draws on, among others: - Freely available scientific papers and pre-prints - General web search results (excluding sites whose licenses forbid such use - e.g. GeneCards, MyHeritage content) - LLM parametric knowledge - [dbSNP @ National Library of Medicine (NLM)](http://www.ncbi.nlm.nih.gov/snp/) - [Get-Evidence](http://evidence.pgp-hms.org/) - [The NHGRI-EBI GWAS Catalog](http://www.ebi.ac.uk/gwas) - PubMed, OMIM, ClinVar - Many other publicly accessible sources **Exclusion of SNPedia.** We do not use SNPedia (snpedia.com) or any SNPedia-derived data, content, or definitions as a source in generating our reports, and we do not reproduce, paraphrase, quote, or cite SNPedia material. SNPedia is designated a prohibited source within our systems: our automated research agents are instructed to reject and disregard any SNPedia-originated content, and we employ domain-level filtering designed to identify and remove SNPedia results from search output before that content is processed or incorporated into any report. This exclusion does not extend to independent primary and authoritative sources (such as peer-reviewed literature, ClinVar, or other cited references) that we rely upon in their own right, even where similar information may coincidentally also appear on SNPedia. We do not claim completeness, currency, or correctness of these sources. Errors and omissions in them propagate into your report. The site is not responsible or liable for the accuracy, usefulness, or availability of any information transmitted or made available, and is not responsible or liable for any error or omission in that information. ## 4. Your responsibilities and acceptable use By using the service you represent, warrant, and agree that: 1. **You are an adult.** You are at least 18 years old (or the age of majority in your jurisdiction, whichever is higher). 2. **The DNA is yours, or you have authority to upload it.** You will only upload genotyping data that belongs to you, or for which you have the explicit, informed consent of the person to whom it belongs. You will not upload the DNA of a minor unless you are their parent or legal guardian and you have considered the long-term implications of doing so. 3. **You will not upload anyone else's DNA without their consent.** In particular: not a partner's, not a family member's, not a stranger's. Uploading another person's genetic data without their consent may violate data-protection law in your jurisdiction (under the GDPR, genetic data is a special category under Article 9 and processing it without an explicit legal basis is prohibited). 4. **You understand DNA is shared.** Even a report about you reveals information about your biological relatives - parents, siblings, children, and more distant kin - who never consented to your decision to use this service. You accept responsibility for that decision. 5. **You will not use the service to diagnose, treat, or make clinical decisions** for yourself or anyone else. 6. **You will not use the report to discriminate.** You will not use this service or any output from it to make decisions about insurance, employment, credit, housing, reproduction, education, or any other matter affecting another person's life or rights. 7. **You will not attempt re-identification of any other user.** 8. **You will not abuse the service.** No automated scraping, no bulk upload, no attempts to overload, probe, reverse-engineer, or circumvent security. No use that violates law in your jurisdiction or ours. 9. **You will check that the service is legal where you are.** Some jurisdictions (e.g. France) restrict or prohibit direct-to-consumer genetic testing. It is your responsibility to know and comply with local law. 10. **You will not share the report as a medical document.** If you choose to show it to a clinician, you will make clear that it is informational LLM output, not a diagnostic result. We may suspend or terminate access for any user who breaches these conditions, with or without notice. ## 5. The service almost certainly contains errors Most of what you read in a report is generated by our custom deep-research LLM pipeline. Because of the algorithmic / LLM nature of the work and the sheer volume of variants and literature involved, errors are *a statistical certainty, not a possibility*. You agree to treat every statement in your report as **potentially wrong** until verified independently with a qualified clinician. You understand and accept that: * **LLMs make mistakes.** Across hundreds of thousands of SNPs, the probability of zero mistakes is zero. The report contains significant errors. * **The underlying science is unsettled.** Most variant–phenotype associations come from frontier research. Effect sizes, directions, and even existence of effects are contested and revised over time. * **Reference databases contain errors.** NCBI dbSNP, ClinVar, GWAS Catalog, OMIM, PubMed-indexed papers, and similar sources contain inaccuracies, retracted results, and outdated classifications. * **Your raw data contains errors.** Consumer genotyping arrays produce miscalled variants. Some positions are systematically unreliable on certain chip versions. * **Strand orientation is a deterministic source of error.** Strand mismatches between data providers, reference builds, and time periods can flip a pathological allele into a benign one and vice versa. We mitigate this; we do not eliminate it. * **The report is incomplete.** Many SNPs have no associated literature. Our pipeline deliberately suppresses output where the risk of error is judged too high. Post-generation filters remove output classified as likely wrong. There is no guarantee we have surfaced the most important data for any given variant, or that we have listed all implications. * **The site and the pipeline have bugs.** As does every piece of software ever written. * **Just like you don't trust Google for medical advice, you should not trust this.** We spend the majority of our development effort on reducing errors. We will never be error-free. We are honest about this because honesty is the only basis on which a tool like this can be used safely. ## 6. Re-identification, family, and downstream risks You acknowledge the following risks inherent to genetic data - which exist independently of how carefully we handle it: * Genetic data is **uniquely identifying** and cannot be revoked, replaced, or rotated like a password. * Sharing or publishing your report, even in part, may enable re-identification, discrimination, or unwanted disclosure. * Information you learn from the report (carrier status, risk variants, non-paternity, etc.) cannot be unlearned and may affect you and your family emotionally, socially, or financially. * Some findings have implications for relatives who have not consented to discovery. We strongly recommend that you do **not** share the report with insurers, employers, advertisers, social platforms, or any party not bound by medical confidentiality. ## 7. Payment **One-time payment, no subscription.** This service operates on a single, one-time payment per user. There is no subscription, no recurring billing, no auto-renewal, no hidden fees. After you upload your data you receive partial access to your report at no cost. If you want the full report, a small one-time payment unlocks it. The price applicable to you is the price displayed at the moment of payment. **Statutory rights - EU consumers and the 14-day withdrawal right.** Under the EU Consumer Rights Directive (Directive 2011/83/EU), consumers entering distance contracts have a 14-day right of withdrawal. For digital content delivered immediately, that right can be waived by the consumer's explicit prior consent and acknowledgment that the right is lost upon performance. By paying to unlock the full report and viewing it, you give that consent and acknowledge that the 14-day statutory right of withdrawal does not apply to the already-delivered content. Nothing in this section affects mandatory consumer rights you may have under the law of your country of residence. **Payment processing.** Payments are handled by **Creem**, operated by **Armitage Labs OÜ** (an Estonian company, registry code 16977866), acting as our **Merchant of Record**. This means Creem is the legal seller and reseller for the payment leg of the transaction: it processes the payment, issues the invoice, and calculates, collects, and remits any applicable VAT, GST, or sales tax. We never see, store, or have access to your card or bank details. Creem's own [Terms](https://www.creem.io/terms) and [Privacy Policy](https://www.creem.io/privacy) govern the payment leg of the transaction. **Taxes.** The displayed price is exclusive of tax. Where applicable, EU VAT (or other local sales tax) is added at checkout by our Merchant of Record and shown before you pay. **Price changes.** We may change pricing for future users at any time. A price change does not affect a payment you have already made. ## 8. Privacy How we handle (and refuse to handle) your data is described in the [Privacy Policy](#privacy). The Privacy Policy is incorporated into these Terms by reference. In summary: we do not store your genetic data, we do not ask for your identity, we keep no analytics, and we have engineered the system to be a worthless target. Read the Privacy Policy for the details. **Provider-specific note on favorites.** For uploads from **Genes for Good** and **WeGene**, favorites you save are **session-only** and are **not persisted across sessions**: they are cleared on exit or after inactivity and are not restored on a later visit. This is a consequence of how identity is derived for these providers (see the Privacy Policy). ## 9. No warranty - provided "AS IS" The service is provided **"AS IS" and "AS AVAILABLE"**, without warranties of any kind, whether express, implied, or statutory, to the maximum extent permitted by applicable law. We expressly disclaim, to that maximum extent, all warranties of merchantability, fitness for a particular purpose, accuracy, completeness, non-infringement, and uninterrupted or error-free operation. Nothing in this section excludes or limits any warranty or right that cannot lawfully be excluded or limited under the law applicable to you as a consumer (including, where applicable, mandatory rights under EU consumer law). ## 10. Limitation of liability To the maximum extent permitted by applicable law: 1. We are not liable for any decision, action, or inaction you take on the basis of the report or any other output of the service. Such decisions are entirely your responsibility, and you agree to make them in consultation with a qualified medical professional. 2. We are not liable for indirect, incidental, consequential, special, punitive, or exemplary damages, including loss of profits, loss of data, loss of goodwill, or distress, arising out of or relating to the service. 3. Our total aggregate liability for all claims arising out of or relating to the service, regardless of the form of action, is limited to the greater of (a) the amount you have paid us in the twelve months preceding the event giving rise to the claim, or (b) one hundred euros (EUR 100). 4. Nothing in this section limits or excludes our liability for death or personal injury caused by our negligence, for fraud, for intentional misconduct, for gross negligence, or for any other liability that cannot be lawfully limited or excluded under the law applicable to you as a consumer (including mandatory rights under EU and Member State consumer protection law). You acknowledge that the candour and stark warnings in Sections 1–6 form part of the bargain: we have priced and structured the service on the assumption that you will not treat the output as clinical truth. ## 11. Indemnity To the extent permitted by applicable law, you agree to indemnify and hold harmless GTCA23 SRL, its members, contributors, and contractors, from and against any third-party claims, losses, costs, and reasonable legal fees arising from: (a) your breach of these Terms; (b) your upload of DNA data you had no right to upload; (c) your use of the report to make decisions affecting another person; or (d) your violation of applicable law in connection with your use of the service. This does not apply to claims caused by our gross negligence or intentional misconduct. ## 12. Intellectual property and license The site, its design, source code, pipeline, templates, and the text of generated reports - to the extent such text is copyrightable - are owned by GTCA23 SRL (contact: [contact@codegen.eu](mailto:contact@codegen.eu)). Source materials retrieved from third parties remain the property of those parties and are used under fair use / scientific quotation principles or under their respective licenses. Your raw genetic data is, and remains, **yours**. We claim no ownership, no license, and no rights to it. As described in the Privacy Policy, we don't keep it. You are granted a personal, non-exclusive, non-transferable, revocable license to use the service for your own informational purposes. You may not resell, republish at scale, scrape, or commercially redistribute the generated content. ## 13. Service availability and changes The service is provided on a best-effort basis. We do not guarantee uptime, continuity, response time, or that any particular feature will remain available. We may modify, suspend, or discontinue any part of the service at any time, including the entire service, with or without notice. ## 14. Changes to these Terms We may update these Terms from time to time - for example, when we add features, when the law changes, or when we tighten language. Material changes will be flagged on this page and on relevant pages of the site. The "Last updated" date at the top reflects the most recent revision. Continued use of the service after a change constitutes acceptance of the revised Terms. If you do not accept a change, stop using the service. ## 15. Governing law and disputes These Terms are governed by the laws of the European Union and, where EU law refers to a Member State's law, by the laws of the Member State in which GTCA23 SRL is established, without regard to its conflict-of-laws rules. Nothing in this clause deprives a consumer of the protection of mandatory provisions of the law of the country in which the consumer is habitually resident. Before bringing any formal claim, you agree to contact us in good faith at [contact@codegen.eu](mailto:contact@codegen.eu) and attempt to resolve the matter for at least 30 days. EU consumers may also use the European Commission's online dispute resolution platform: [https://ec.europa.eu/consumers/odr](https://ec.europa.eu/consumers/odr). Subject to the consumer protections referred to above, any dispute, controversy, or claim arising out of or in connection with these Terms, or the breach, termination, or validity thereof, that cannot be resolved amicably shall be submitted to the exclusive jurisdiction of the competent courts of Romania. ## 16. Severability If any provision of these Terms is held to be unenforceable or invalid by a competent authority, that provision is to be enforced to the maximum extent permitted, and the remaining provisions remain in full force and effect. ## 17. Entire agreement These Terms, together with the Privacy Policy, constitute the entire agreement between you and GTCA23 SRL regarding the service and supersede any prior agreement on the same subject matter. ## 18. Contact Questions about these Terms: [questions@codegen.eu](mailto:questions@codegen.eu). Privacy questions or data-subject requests: see the Privacy Policy. --- > **Final reminder.** This site exists because we believe people should be able to look at their own data without surrendering their privacy or paying a data-broker. It does not exist to replace your doctor. The report you read here is generated by software that makes mistakes. Treat it accordingly.