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# GenomOncology Remote MCP **Privacy Policy** **Version 1.2 – Effective June 18, 2025** ## 1. Data We Collect | Type | Examples | Source | Storage | | ------------------------- | ---------------------------------------- | -------------------- | -------------- | | **Account** | Google user ID, email, display name | From Google OAuth | BigQuery | | **Queries** | Prompts, timestamps | User input | BigQuery | | **Operational** | IP address, user-agent | Automatic | Temporary only | | **Usage** | Token counts, latency, model performance | Derived metrics | Aggregated | | **Third-Party Responses** | API responses from PubMed, bioRxiv, etc. | Third-party services | Not stored | We do **not** collect sensitive health or demographic information. --- ## 2. How We Use It - Authenticate and secure the service - Improve quality, accuracy, and speed of model output - Analyze aggregate usage for insights - Monitor third-party API performance (without storing responses) - Comply with laws --- ## 3. Legal Basis (GDPR/UK) - **Contractual necessity** (Art. 6(1)(b) GDPR) - **Legitimate interests** (Art. 6(1)(f)) - **Consent**, where applicable --- ## 4. Who We Share With - **Google Cloud / Cloudflare** – Hosting & Auth - **API providers** – e.g., PubMed, bioRxiv - Your queries are transmitted to these services - We do not control their data retention practices - We do not store third-party responses - **Analytics tools** – e.g., BigQuery - **Authorities** – if required by law We **do not sell** your personal data. --- ## 5. Third-Party Data Handling When you use the Service: - Your queries may be sent to third-party APIs (PubMed, bioRxiv, TCGA, 1000 Genomes) - These services have their own privacy policies and data practices - We use third-party responses to generate output but do not store them - Third parties may independently retain query data per their policies - Only your username and queries are stored in our systems --- ## 6. Cookies We use only **Google OAuth** session cookies. No additional tracking cookies are set. --- ## 7. Data Retention - **BigQuery storage** (usernames & queries): Retained indefinitely - **Operational data** (IP, user-agent): Not retained - **Third-party responses**: Not stored - **Aggregated metrics**: Retained indefinitely - **Account Username**: Retained until deletion requested --- ## 8. Security - All data encrypted in transit (TLS 1.3) - Least-privilege access enforced via IAM - Username and query data stored in BigQuery with strict access control - Operational data (IP, user-agent) processed but not retained - **Incident Response**: Security incidents investigated within 24 hours - **Breach Notification**: Users notified within 72 hours of confirmed breach - **Security Audits**: Annual third-party security assessments - **Vulnerability Reporting**: See our [SECURITY.md](https://github.com/genomoncology/biomcp/blob/main/docs/biomcp-security.md) --- ## 9. International Transfers Data is stored in **Google Cloud's `us-central1`**. Transfers from the EU/UK rely on **SCCs**. --- ## 10. Your Rights Depending on your location, you may request to: - Access, correct, or delete your data - Restrict or object to processing - Port your data - File a complaint (EEA/UK) - Opt out (California residents) **Data Export**: - Available in JSON or CSV format - Requests fulfilled within 30 days - Includes: account info, queries, timestamps - Excludes: operational data, third-party responses, aggregated metrics Email: **privacy@genomoncology.com** --- ## 11. Children's Privacy The Service is not intended for use by anyone under **16 years old**. --- ## 12. Policy Changes We will update this document at `/privacy` with an updated Effective Date. Material changes will be announced by email. Version history maintained at: [github.com/genomoncology/biomcp/blob/main/docs/biomcp-privacy.md](https://github.com/genomoncology/biomcp/blob/main/docs/biomcp-privacy.md) --- ## 13. Contact **Data Protection Officer** 📧 **dpo@genomoncology.com** 📮 GenomOncology LLC – Privacy Office 1138 West 9th Street, Suite 400 Cleveland, OH 44113 # Security Policy ## Reporting a Vulnerability We take the security of biomcp seriously. If you believe you have found a security vulnerability, please report it to us as described below. ### Please do NOT: - Open a public GitHub issue - Discuss the vulnerability publicly before it has been addressed ### Please DO: - Email us at **security@genomoncology.com** - Include the word "SECURITY" in the subject line - Provide detailed steps to reproduce the vulnerability - Include the impact and potential attack scenarios ### What to expect: - **Acknowledgment**: Within 24 hours - **Initial Assessment**: Within 72 hours - **Status Updates**: At least every 5 business days - **Resolution Target**: Critical issues within 30 days ### Scope Vulnerabilities in the following areas are in scope: - Authentication bypass or privilege escalation - Data exposure or unauthorized access to user queries - Injection vulnerabilities (SQL, command, etc.) - Cross-site scripting (XSS) or request forgery (CSRF) - Denial of service vulnerabilities - Insecure cryptographic implementations - Third-party API key exposure ### Out of Scope: - Vulnerabilities in third-party services (PubMed, bioRxiv, etc.) - Issues in dependencies with existing patches - Social engineering attacks - Physical attacks - Attacks requiring authenticated admin access ## Disclosure Policy - We will work with you to understand and validate the issue - We will prepare a fix and release it as soon as possible - We will publicly disclose the vulnerability after the fix is released - We will credit you for the discovery (unless you prefer to remain anonymous) ## Safe Harbor Any activities conducted in a manner consistent with this policy will be considered authorized conduct, and we will not initiate legal action against you. If legal action is initiated by a third party against you in connection with activities conducted under this policy, we will take steps to make it known that your actions were conducted in compliance with this policy. ## Contact **Security Team Email**: security@genomoncology.com **PGP Key**: Available upon request Thank you for helping keep biomcp and our users safe! # GenomOncology Remote MCP **Terms of Service** **Version 1.2 – Effective June 18, 2025** > This document applies to the **hosted Remote MCP service** (the "Service") provided by **GenomOncology LLC**. > > For use of the **open-source code** available at [https://github.com/genomoncology/biomcp](https://github.com/genomoncology/biomcp), refer to the repository's LICENSE file (e.g., MIT License). --- ## 1. Definitions | Term | Meaning | | --------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | **Service** | The hosted Model Context Protocol (MCP) instance available via Cloudflare and secured by Google OAuth. | | **User Content** | Prompts, messages, files, code, or other material submitted by you. | | **Output** | Model-generated text or data produced in response to your User Content. | | **Personal Data** | Information that identifies or relates to an identifiable individual, including Google account identifiers and query text. | | **Commercial Use** | Any use that directly or indirectly generates revenue, including but not limited to: selling access, integrating into paid products, or using for business operations. | | **Academic Research** | Non-commercial research conducted by accredited educational institutions for scholarly purposes. | --- ## 2. Eligibility & Accounts You must: - Be at least 16 years old - Have a valid Google account - Not be barred from receiving services under applicable law Authentication is handled via **Google OAuth**. Keep your credentials secure. --- ## 3. License & Intellectual Property You are granted a **limited, revocable, non-exclusive, non-transferable** license to use the Service for **internal research and non-commercial evaluation**. **Permitted Uses:** - Personal research and learning - Academic research (with attribution) - Evaluation for potential commercial licensing - Open-source development (non-commercial) **Prohibited Commercial Uses:** - Reselling or redistributing Service access - Integration into commercial products/services - Use in revenue-generating operations - Commercial data analysis or insights For commercial licensing inquiries, contact: **licensing@genomoncology.com** We retain all rights in the Service and its software. You retain ownership of your User Content, but grant us a royalty-free, worldwide license to use it (and the resulting Output) to provide, secure, and improve the Service. --- ## 4. Acceptable Use & Rate Limits You **must not**: 1. Violate any law or regulation 2. Reverse-engineer, scrape, or probe the Service or model weights 3. Exceed rate limits or disrupt the Service **Rate Limits:** - **Standard tier**: 100 requests per hour, 1000 per day - **Burst limit**: 10 requests per minute - **Payload size**: 50KB per request **Exceeding Limits:** - First violation: 1-hour suspension - Repeated violations: Account review and possible termination - Higher limits available upon request: **api-limits@genomoncology.com** --- ## 5. Privacy, Logging & Improvement We store **Google user ID**, **email address**, and **query text** with **timestamps** in **Google BigQuery**. This data is analyzed to: - Operate and secure the Service - Improve system performance and user experience - Tune models and develop features - Generate usage analytics **Note**: We process but do not retain operational data like IP addresses or user-agents. Third-party API responses are used in real-time but not stored. See our [Privacy Policy](https://github.com/genomoncology/biomcp/blob/main/docs/biomcp-privacy.md) for details. --- ## 6. Third‑Party Services The Service queries third-party APIs and knowledge sources (e.g., **PubMed, bioRxiv, TCGA, 1000 Genomes**) to respond to user prompts. **Important:** - Your queries are transmitted to these services - Third-party services have independent terms and privacy policies - We cannot guarantee their availability, accuracy, or uptime - Third parties may retain your query data per their policies - API responses are used to generate output but not stored by us You acknowledge that third-party content is subject to their respective licenses and terms. --- ## 7. Disclaimers - **AI Output:** May be inaccurate or biased. **Do not rely on it for medical or legal decisions.** - **AS‑IS:** The Service is provided _"as is"_ with no warranties or guarantees. - **Third-Party Content:** We are not responsible for accuracy or availability of third-party data. --- ## 8. Limitation of Liability To the extent permitted by law, **GenomOncology** is not liable for indirect, incidental, or consequential damages, including: - Data loss - Business interruption - Inaccurate output - Third-party service failures --- ## 9. Indemnification You agree to indemnify and hold GenomOncology harmless from any claim resulting from your misuse of the Service. --- ## 10. Termination We may suspend or terminate access at any time. Upon termination: - Your license ends immediately - We retain stored data (username & queries) per our Privacy Policy - You may request data export within 30 days --- ## 11. Governing Law & Dispute Resolution These Terms are governed by the laws of **Ohio, USA**. Disputes will be resolved via binding arbitration in **Cuyahoga County, Ohio**, under **JAMS Streamlined Rules**. --- ## 12. Changes We may update these Terms by posting to `/terms`. Material changes will be emailed. Continued use constitutes acceptance. Version history: [github.com/genomoncology/biomcp/blob/main/docs/biomcp-terms.md](https://github.com/genomoncology/biomcp/blob/main/docs/biomcp-terms.md) --- ## 13. Security & Vulnerability Reporting Found a security issue? Please report it responsibly: - Email: **security@genomoncology.com** - See: [SECURITY.md](https://github.com/genomoncology/biomcp/blob/main/SECURITY.md) --- ## 14. Contact GenomOncology LLC 1138 West 9th Street, Suite 400 Cleveland, OH 44113 📧 **legal@genomoncology.com** --- ## Appendix A – Acceptable Use Policy (AUP) - Do not submit illegal, harassing, or hateful content - Do not generate malware, spam, or scrape personal data - Respect copyright and IP laws - Do not attempt to re-identify individuals from model output - Do not use the Service to process protected health information (PHI) - Do not submit personally identifiable genetic data

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