PRIVACY POLICY

Root Cause Rewire™
Operated by Root Cause Rewire LLC
A subsidiary of JRW Holdings LLC

Effective Date: January 1, 2026


1. Overview

Root Cause Rewire LLC (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, process, store, safeguard, and disclose your information when you use the Root Cause Rewire™ platform and related services.

This policy applies to users located in the United States (and Canada, where applicable). Services are not directed to residents of jurisdictions where prohibited by law.


2. Information We Collect

We may collect the following categories of information:

A. Personal Information

Name

Email address

Billing information

Account login credentials

Customer support communications

B. User-Submitted Content

Consumer-provided genetic data files (if applicable)

Responses to questionnaires

Self-reported pattern information

Written reflections or uploaded materials

C. Biological Sample Information (If Applicable)

If you participate in Reactivity Signal Mapping™, we may collect:

Biological samples (e.g., hair)

Associated coded identifiers used for laboratory processing

D. Technical Information

IP address

Browser type

Device identifiers

Usage analytics

Cookies and tracking technologies (see Section 11)


3. Genetic Data

If you upload genetic data:

Files are temporarily processed for limited marker extraction.

Raw genetic files are deleted after processing.

Selected extracted markers are retained in pseudonymized format.

Pseudonymized data may still be linked to your account through internal identifiers.

Pseudonymized data is not fully anonymized and may be re-associated with your account internally for service delivery.

We do not perform laboratory testing.

We do not validate third-party testing accuracy.

We do not sell, rent, or license genetic data.

We do not use uploaded genetic data to train external AI systems.

We do not use genetic data for marketing personalization or targeted advertising.

We do not share genetic data with third parties for independent use, research, or commercialization.

Genetic data is treated as sensitive personal information and handled with heightened safeguards.

For additional details, please review our Genetic Data Disclosure & Consent.


4. Bioresonance Reactivity Data

If you participate in the "Outer Trigger" or Reactivity Signal Mapping™:

Reactivity outputs are integrated into the Company’s educational framework and are not used as medical or clinical data.

Hair samples are submitted to an independent third-party laboratory for non-clinical screening.

The laboratory may process samples within or outside of the United States.

We share only necessary coded identifiers required for processing.

We do not receive clinical medical records.

Reactivity results are stored as educational data within your account.

We do not interpret reactivity results as allergy testing, intolerance testing, or medical diagnostic results.


5. How We Use Information

We use information to:

- Provide educational reports and digital programs

- Generate AI-assisted educational outputs

- Deliver Reactivity Signal Mapping™ services

- Improve platform functionality

- Process payments

- Respond to customer inquiries

- Maintain security and prevent fraud

- Comply with legal obligations

We do not sell personal information.

We do not authorize third parties to use your information for their own marketing purposes.

We may use aggregated, de-identified data for internal research, analytics, and service improvement.


6. Data Retention

Retention periods may vary depending on the nature of the data and service provided.

We retain personal information only as long as reasonably necessary to:

- Provide Services

- Maintain active user accounts

- Comply with legal or accounting obligations

- Resolve disputes

Raw genetic files are deleted after processing.

Extracted marker data is retained in pseudonymized form unless deletion is requested.

Account data may be retained for as long as your account remains active. If you request deletion, certain information may be retained as required by law.

Deletion requests may be submitted to: [email protected]


7. Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information.

However, no method of transmission or storage can guarantee absolute security. You acknowledge and accept this inherent risk.


8. Third-Party Service Providers

We may share personal information with trusted third-party service providers solely for the purpose of delivering Services, including:

- Payment processors

- Hosting providers

- Cloud storage providers

- Analytics providers

- AI infrastructure providers

Laboratory partners for "Outer Triggers" or Reactivity Signal Mapping™

These providers are contractually obligated to protect your information and may not use it for their own marketing purposes.

We do not sell or license personal information to third parties.


9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States and other jurisdictions where our service providers operate. We take reasonable steps to ensure appropriate safeguards are in place for international data transfers.

This may include transfer of coded identifiers or educational data to third-party laboratory partners.

By using the Services, you acknowledge and consent to such transfers, which may be subject to different data protection laws than those in your jurisdiction.


10. Your Privacy Rights

Depending on your state or province of residence, you may have certain rights regarding your personal information, including:

- The right to request access to your data

- The right to request correction of inaccurate information

- The right to request deletion of your data

- The right to withdraw consent (where applicable)

We will not discriminate against you for exercising your privacy rights.

We may require verification of identity before fulfilling requests.

Requests may be submitted to: [email protected]


11. Cookies & Tracking Technologies

We use cookies and similar technologies to:

- Maintain session functionality

- Analyze platform usage

- Improve user experience

You may adjust cookie preferences in your browser settings.

We do not currently respond to “Do Not Track” browser signals.


12. No Healthcare Relationship

Information collected through the platform is used solely for educational purposes and does not create a healthcare provider–patient relationship.

We are not a “covered entity” or “business associate” under HIPAA.


13. Children’s Privacy

Services are not directed to individuals under eighteen (18). We do not knowingly collect personal information from minors.

14. Sensitive Data Acknowledgement

Certain information collected through the Services, including genetic data and biological sample information, may be considered sensitive personal data. By using the Services, you acknowledge and consent to the collection and processing of such data as described in this Policy.


15. Changes to This Policy

We may update this Privacy Policy from time to time. Continued use of the Services constitutes acceptance of any revisions.


16. Contact

Root Cause Rewire LLC
[email protected]