At Bioskryb, Inc., we value your privacy and the protection of your Personal Data. This Privacy Notice (“Notice“) explains how we collect, store, use, share, transfer, delete, and process information collected from or about you (“Personal Data“) by Bioskryb, Inc., or any subsidiary or affiliate (collectively “we,” “our,” or “us”). We conduct business directly and indirectly controlling subsidiaries and affiliates around the world, including, but not limited to, subsidiaries and affiliates incorporated in China, the European Union, the United Kingdom, and the United States. As an international company, Bioskryb has multiple legal entities in different jurisdictions that are responsible for the Personal Data they collect, and we process Personal Data in accordance with these applicable laws and regulations.

PRIVACY STANDARDS

Across all of our business activities we recognize and seek to base our privacy practices on accepted principles used by various regulatory and industry groups (the “Privacy Standards“). In summary, these principles are as follows:

  1. To Obtain Personal Data Properly: To obtain Personal Data in good faith by legitimate, lawful, and fair means and, where appropriate, with the knowledge and consent of the individual about whom we process Personal Data (the “Individual“).
  2. To Maintain Personal Data Accuracy: To process Personal Data that is accurate, adequate, relevant, and limited to what is necessary for the processing purpose, complete, and up-to-date (taking into account the purposes for which it was collected).
  3. To Process Personal Data for Specified Purposes: To specify the purposes for which Personal Data is collected before such collection takes place and to use Personal Data only in accordance with the specified purposes except where the individual has provided their consent or by the authority of law.
  4. To Protect Personal Data: To protect Personal Data using reasonable security safeguards.
  5. To Be Transparent: To be open about privacy practices, policies, developments, and the details of any processing that takes place.
  6. To Comply with Individual’s Privacy Rights: As required by applicable law, to give effect to individuals’ privacy requests.
  7. To Be Accountable: To be accountable for complying with measures that give effect to these Privacy Standards.

SCOPE

  1. This Notice describes the types of Personal Data that Bioskryb may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data. This Notice applies to Personal Data collected or processed by us online (through websites, applications, email, and otherwise) (“Online Services“); when we provide products or services to you; and in other situations where you interact with us, including but not limited to our sites and offices, our events (e.g., tradeshows and conferences) (such products, services, websites, and other systems collectively, the “Products and Services“), or anywhere this Notice is posted or referenced. This Notice also applies to Personal Data that is collected or processed when you interact with us in-person, by telephone, or by mail.
  2. Bioskryb may have other unique privacy notices that apply to certain specific situations, such as privacy notices for specific Products and Services in various specific circumstances, including informed consent forms drafted for our clients for use in interventional and observational medical research. To the extent you were provided with a different privacy notice or policy and those policies or notices apply, those policies or notices will govern our interactions with you, not this one.
  3. If you provide Personal Data of anyone other than yourself, please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Bioskryb (including obtaining consent, if required).
  4. Please carefully review this Notice. To the extent permitted by applicable law, by providing us your Personal Data or otherwise interacting with us, you are agreeing to this Notice.

INFORMATION COLLECTION

Personal Data
  1. Personal Data” is any information—as electronically or otherwise recorded—that can be used to identify an individual or that we can link directly to an individual, such as name, address, email address, telephone number, credit card number, or health or treatment information, as applicable. Personal Data in some jurisdictions can include information that indirectly identifies a person, such as a unique assigned number.
  2. Personal Data may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, medical and health information, financial account information, geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, and other information that, if used in an unauthorized manner, may lead to infringement of the human dignity or rights or freedoms of the Individual or other harm to the Individual or to property of the Individual. Where local law requires, we will obtain your consent to process such sensitive Personal Data.
  3. Some examples of instances where we process Personal Data include if you:
    1. Register for an account for one of our Products or Services for you or the organization for which you work;
    2. Use online social media resources that we may offer from time to time;
    3. Sign up for newsletters or other informational or marketing materials;
    4. Participate in our events, tradeshows, conferences, or trainings, including Product and Service demonstrations;
    5. Ask us a question by contacting us;
    6. Apply for employment with us;
    7. Interact with us as a customer, vendor, supplier, or business partner or an employee or representative of same, including if you provide information about your customers or patients;
    8. Visit our sites and offices;
    9. Respond to our surveys, questionnaires, or feedback requests;
    10. Make a complaint to us or to our customers about us; or
    11. Purchase, use, or receive our Products or Services, including any mobile applications.
  4. We will process any Personal Data we collect in accordance with applicable law and as explained in this Notice (unless, as explained above, one of our other policies or Notices governs). In some circumstances, if you do not want to provide us with your information, certain Products and Services may be unavailable to you.
  5. Below is a summary of how we collect, process, and use Personal Data and the potential recipients of your Personal Data. Some jurisdictions require us to state the legal bases for processing your Personal Data, which is included below, but please note that not all jurisdictions may recognize all legal bases.

Categories of Personal Data We Collect

Examples of Personal Data Processed
Sources of Personal Data
Purpose of Processing Personal Data
Recipients of Your Personal Data

Identity and Contact Information

Examples of Identity and Contact Information: First and last name, organization, email address, postal address, phone number, fax number, job title, account username and password, IP address, biometric data, CCTV images, and National Provider Identifier or state license number.

Sources: Directly from you, your employer; from your devices; from our business partners; from our sites and offices.

Purpose: To provide you with our Products and Services; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for human resources and employment purposes; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance.

Legal Bases: For the purposes of our legitimate interests in developing, testing and promoting our Products and Services, conducting clinical studies efficiently, detecting and preventing fraud and corruption, business efficacy, and protecting our business interests; in the public interest; to comply with a legal obligation; to perform a contract (in some circumstances you may be contractually required to provide certain basic Personal Data, without which we may not be able to provide our Products or Services); to protect vital interests; to ensure high standards of quality; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law.

Recipients: Bioskryb, our affiliates, subsidiaries, and related companies; vendors, and partners that assist us in providing the Products or Services or help us improve our marketing or administration; and otherwise, when required, with your consent.

Demographic Information

Examples of Demographic Information: Your name, age, gender, marital status, disability, and date of birth.

Sources: Directly from you, your employerfrom your devices; from our business partners.

Purpose: To provide you with our Products and Services; to conduct anti-corruption due diligence and periodically renew due diligence; to conduct internal investigation and handle disputes and/or litigation in which you may be directly or indirectly involved; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance.

Legal Bases: For the purposes of our legitimate interests in developing, testing and promoting our Products and Services, detecting and preventing fraud and corruption, business efficacy, and protecting our business interests; to comply with a legal obligation; to perform a contract (in some circumstances you may be contractually required to provide certain basic Personal Data, without which we may not be able to provide our Products or Services); to protect vital interests; to ensure high standards of quality and safety; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law.

Recipients: Bioskryb, our affiliates, subsidiaries, and related companies; business partners; vendors, and partners that assist us in providing the Products or Services or help us improve our marketing or administration; and otherwise, when required, with your consent.

Commercial and Financial Information

Examples of Commercial and Financial Information: Your name, transaction records, Products and Services purchased, obtained, or considered, request documentation, customer service records, audio recordings of service center calls, survey feedback, financial transaction history, and financial account numbers and other payment information.

Sources: Directly from you, your employer, from your devices; from our business partners.

Purpose: To provide you with our Products and Services; ; to conduct anti-corruption due diligence and periodically renew due diligence; to conduct internal investigation and handle disputes and/or litigation in which you may be directly or indirectly involved; to communicate with you; to identify and authenticate you; to customize content for you; to detect security incidents; to protect against malicious or illegal activity; to ensure the appropriate use of our Products and Services; to improve our Products and Services; for short-term, transient use; for administrative purposes; for marketing, internal research, and development; and/or for quality assurance.

Legal Bases: For the purposes of our legitimate interests in developing, testing and promoting our Products and Services, conducting clinical studies efficiently, detecting and preventing fraud and corruption, business efficacy, and protecting our business interests; in the public interest; to comply with a legal obligation; to perform a contract (in some circumstances you may be contractually required to provide certain basic Personal Data, without which we may not be able to provide our Products or Services); to protect vital interests; in circumstances where we have requested and received consent; and for other purposes that may be required or allowed by law.

Recipients: Bioskryb, our affiliates, subsidiaries, and related companies; business partners; service providers, vendors, and partners that assist us in providing the Products or Services or help us improve our marketing or administration; and otherwise, when required, with your consent.

Combination of Data

We may combine information we collect, whether Personal Data or not, with Personal Data that we may obtain from third parties.

Marketing Uses, Cookies, and Other Activities

To the extent permitted by applicable law, including in accordance with your consent where required by applicable law, we may engage in the following activities:

  1. We may use your contact details to contact you to determine whether you would like to initiate a business relationship with us or to send you marketing emails. If you do not wish to receive such marketing emails, you may opt out by declining to receive such emails when registering or in our subsequent communications by following opt-out instructions included in the email or at other information collection points on the Online Services.
  2. We may collect Personal Data about you (e.g., your position, specialty and publications) from publicly available resources, such as company, university, and publications websites, and combine it with Personal Data we have collected about you to enhance our customer profile of you in support of our sales and marketing activities.
  3. We may process recordings of your calls with our customer service representatives to ensure we deliver high-quality service, assist in the training and development of Bioskryb representatives, and generally improve our customer service to you.
  4. We may display advertisements to you regarding Products and Services that we believe are relevant to you based on your activities on the Online Services or on other web or digital properties. Such advertisements may be shown on our Online Services or the online services of others. We achieve this by using, and allowing third parties (e.g., Facebook, LinkedIn) to use, certain cookies, eTags, pixels, web beacons, and other tracking technologies to track your activities on our Online Services and other online services. For more information about these activities and how to manage or opt out of them, please see our contact information below.
  5. We may make customer offers to you based on your activities across different Online Services, including activities on other web or digital properties or your other interactions with Bioskryb that are not via the Online Services (e.g., regional offers based on the location of your office listed on order forms).
  6. We also perform statistical analyses of the users of our Online Services to improve the functionality, content, design, and navigation of the Online Services.

SERVICE PROVIDERS

Service providers acting on our behalf shall be obliged to adhere to agreements including confidentiality requirements no less protective than those described in this Notice and will only process Personal Data as necessary to perform their functions in a manner consistent with this Notice, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations. Our third-party service providers may be located in the United States and other jurisdictions.

INTERACTIVE FEATURES OF OUR WEBSITES

To the extent we offer any public or group forums on our Products or Services, such as newsfeeds, blogs, message boards, or similar tools (“Interactive Features”), the posts or comments you make may be public and viewed by others. You should use care before posting information about yourself, including Personal Data. You acknowledge and understand that you have no expectation of privacy or confidentiality in the content you submit to Interactive Features over the Products and Services. Except when required to do so by applicable law, we assume no obligation to remove Personal Data you post on our Products and Services, and you disclose any Personal Data at your own risk.

Our Products or Services may contain links to other websites, applications, products, or services that are not owned or operated by Bioskryb, such as social media websites and applications like Facebook and Twitter. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.

SAFEGUARDING INFORMATION

Consistent with applicable laws and requirements, Bioskryb has put in place physical, technical, and administrative safeguards to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Online Services.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

  1. Please note that in many circumstances we cannot effectively do business with you without processing some Personal Data about you (e.g., your contact information).
  2. You can use the Online Services without consenting to cookies (unless strictly necessary); the consequence is that some features of the Online Services may be less tailored to you and some functionality may be reduced.
  3. You have the right to opt out of receiving marketing communications. Please use the unsubscribe functionality on such communications.
  4. You can make a request with respect to your Personal Data by contacting us at the address below. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws
  5. Where you contact customer service representatives, we may require you to provide information to authenticate your identity to assist you with your request. If you are unable to provide this information, we may be unable to process your request.
  6. Where we receive your Personal Data from our customers and process your Personal Data on their behalf, we do so in the capacity of a processor. We do not have control over our customers’ privacy and security practices and processes. If your Personal Data has been submitted to us by a Bioskryb customer and you wish to exercise any of the above-mentioned rights, please contact the relevant customer directly, or provide us with the name of the customer so that we can appropriately refer your request to them.
  7. You may also have a right under your jurisdiction’s data protection law to the following with respect to some or all of your Personal Data:
  • To request access to your Personal Data (including under GDPR Article 15);
  • To request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);
  • To request that we restrict or block the processing of your Personal Data (including under GDPR Articles 18, 21 and 22 and to object to the sale or sharing of your Personal Data under other relevant laws);
  • To provide your Personal Data directly to another, i.e., a right to data portability (including under GDPR Article 20);
  • When we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21); and
  • To lodge a complaint with the data protection authority in your jurisdiction.

To exercise these rights, please write to us using our contact information below. We may, after receiving your request, require additional information from you to honor the request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. You may also find additional contact information in the list of data controllers here. If you are concerned about how your Personal Data is being processed, please email us or contact us. You may also have the right to lodge a complaint against us. To do so, contact your local data protection authority (if one exists in your country).

HOW LONG YOUR PERSONAL DATA WILL BE RETAINED

We generally retain Personal Data for as long as needed for the specific business purpose or purposes for which it was collected. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary business purposes. Where possible, we aim to anonymize the information or remove unnecessary identifiers from records that we may need to keep for periods beyond the specified retention period.

CHANGES TO THIS PRIVACY NOTICE

Changes to This Privacy Notice. We reserve the right to change this Notice from time to time. We will alert you when changes have been made by indicating the date this Notice was last updated as the date the Notice became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Notice to learn of any changes.

CONTACT US

If you have questions or comments about this Notice or about how your Personal Data is processed, please contact info@bioskryb.com.