PureTech Scientific LLC Privacy Policy
PRIVACY NOTICE/YOUR PRIVACY RIGHTS
Effective Date: [April 14, 2024]
LAST UPDATED [April 14, 2024]
Table of Contents
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- Sources of Personal Data
- Types of Personal Data We Collect
- How We Use Personal Data
- How We Disclose Personal Data
- Cookies and Other Tracking Technologies
- Data Security and Data Retention
- Children’s Privacy
- External Links
- Contact Information
- Rights Concerning Personal Data
- Supplemental Information for Residents of California
- Supplemental Information for the EEA, Switzerland, and the UK
PureTech Scientific LLC, together with its subsidiaries and affiliates (collectively, “Company,” “us,” “we,” or “our”), is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data about our customers’ and vendors’ employees that we collect through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”), in-person events and promotions and other online and offline interactions (for example, if you negotiate a contract on behalf of one of our customer companies that you represent).
This Privacy Notice does not apply to job applicants or our employees, contractors, or agents.
Whenever you interact with us on behalf of another individual or entity, such as by giving us a reference, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.
Changes: We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Privacy Notice.
1. Sources of Personal Data
We collect Personal Data about you from the following sources:
- Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; interact with us in person; sign up for offers or newsletters; communicate with us; place or customize orders; or sign up for an account or other services.
- Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
- From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies, or other parties who interact with us.
- From publicly available sources. Where permitted by law, we may collect Personal Data that has been made publicly available, such as on public profiles and websites.
We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use and disclose the combined information for the purposes identified below.
2. Types of Personal Data We Collect
We may collect the following types of Personal Data:
- Identifiers, such as your name, email address, physical address, telephone number, other business contact information, and device identifiers (e.g., cookie IDs and IP address).
- Records about you, such as signatures; physical characteristics or a description of you; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments.
- Protected class and demographic information, such as age (including birthdates) and gender.
- Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see our Cookie Policy https://glycleand.com/cookie-policy/.
- Non-precise geolocation data, such as your approximate location as derived from your IP address.
- Audio, electronic, visual, or other sensory information, such as photographs taken at events, call recordings, and audio or video recordings of our premises.
- Professional or employment-related information, such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
- Education information.
- Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and to determine your preferred frequency for receiving offers.
3. How We Use Personal Data
We may use Personal Data for the following purposes:
- To provide you or your company with products and services, such as making our Digital Properties, products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you or the company that you represent requests; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
- For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
- For our internal research and product improvement purposes, such as verifying and maintaining the quality and safety of our products and services; improving our products and services and designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
- For legal, safety, or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing the spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
- In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.
- For marketing or promotional purposes, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe from our email marketing via the link in the email, or by contacting us using the information in Section 9 (Contact Information) below.
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
4. How We Disclose Personal Data
We may disclose Personal Data to third parties, including to the categories of recipients described below:
- Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
- Service providers that work on our behalf to provide products and services, such as IT providers, internet service providers, web hosting providers, software service providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
- Professional consultants, such as accountants, lawyers, financial advisors, and audit firms. Professional consultants may use Personal Data for their own purposes and we are not responsible for their privacy practices.
- Vendors necessary to complete transactions you request
- Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we disclose information to comply with law or legal requirements; to enforce or apply our policies, terms, and agreements; and to protect our, our customers’, or third parties’ safety, property, or rights.
- Other entities in connection with a corporate transaction, such as if we, or some or all of our assets, are acquired by another entity, including through a sale in connection with bankruptcy or other forms of corporate change.
- Business partners that may use Personal Data for their own purposes, such as:
- Advertisers, ad platforms and networks, and social media platforms;
- Third parties whose cookies and tracking tools we use as described in our Cookie Policy https://glycleand.com/cookie-policy/
- Commercial data partners to whom we make information available for their own marketing purposes; and
- Partners who work with us on promotional opportunities, including co-branded products and services.
Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or Personal Data processing policies. You should consult the privacy notices of those parties for details on their practices.
- The public, such as when you have an opportunity to make comments regarding us or our products or services that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
- Entities to which you have consented to the disclosure.
5. Cookies and Other Tracking Technologies
We may collect technical information from and about your device (such as your browser type, operating system, IP address, and domain name) via cookies and other tracking technologies. Please see our Cookie Policy available at https://glycleand.com/cookie-policy/ for further information.
6. Data Security and Data Retention
Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.
Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you or your company with the products or services you have requested and interact with you; maintain our business relationship with you or your company; improve our business over time; ensure the ongoing legality, safety and security of our products and services and relationships; or otherwise in accordance with our internal retention procedures. Once you or your company has terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest. If you would like to know more about the retention periods applicable to your Personal Data, you can contact us using the details provided in Section 9 (Contact Information) below.
7. Children’s Privacy
Our Digital Properties are intended for individuals 18 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at the address in Section 9 (Contact Information) below, and we will take prompt steps to delete the information.
8. External Links
Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third-party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.
9. Contact Information
If you have questions regarding this Privacy Notice or how the Company processes your Personal Data, please contact us at:
10. Rights Concerning Personal Data
Depending on the jurisdiction you are in, you may have some or all of the following privacy rights:
- Right to Know. You may have the right to request confirmation that we process your Personal Data and the specific pieces of information we process. You may also have the right to request information about the categories of Personal Data we have collected about you, the categories of sources from which we collected the Personal Data, the purposes for collecting, selling, or sharing the Personal Data, and to whom we have disclosed Personal Data and why.
- Right to Data Portability. You may have the right to receive Personal Data that you have provided to us in a structured, commonly used and machine-readable format.
- Right to Delete. You may have the right to request that we delete Personal Data that we have collected from you.
- Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
- Right to Object. You may have the right to object to the processing of your Personal Data in certain cases.
- Right to Restrict Processing. You may have the right to request that we restrict the processing of your Personal Data in certain cases.
- Right to Lodge a Complaint. You may have the right to lodge a complaint with a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred.
- Right to Refuse or Withdraw Consent. In case we ask for your consent to process your Personal Data, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.
- Right to Not Be Subject to Automated Decision-making. You may have the right to not be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.
You may request to exercise the rights available to you via our webform https://glycleand.com/contact/ , emailing us at [[email protected]], or by calling us at [1-888-536-9836]. We will not discriminate against you for exercising your privacy rights.
11. Supplemental Information for Residents of California
In addition to the disclosures above, this section provides supplemental information about California privacy rights and how we process Personal Data of California residents.
- Additional Information on Privacy Rights
In order to fully exercise the Right to Opt Out of Sales and Sharing for Targeted Advertising you must undertake both of the following steps:
To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.
Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are, and will inform you if we need such information.
Authorized Agents: Authorized agents may exercise rights on behalf of California residents by submitting a request via webform https://glycleand.com/contact/ and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of the resident by providing signed permission from the resident. We may also require the resident to verify their own identity directly with us or to directly confirm with us that they provided the agent permission to submit the request.
- Additional Data Processing Disclosures
Although we have not “sold” Personal Data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a “sale” of Personal Data or “sharing” of Personal Data for targeted advertising, as those terms are defined under California law. We do not knowingly sell or share for targeted advertising any Personal Data of minors under the age of 16.
Below please find a chart detailing the categories of Personal Data we collected and with whom it was sold, shared, or disclosed for a business purpose in the past 12 months.
Categories of Personal Data We Collect for Targeted Advertising Identifiers (Section 2.A) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Records about you (Section 2.B) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Protected classifications and other demographic information (Section 2.C) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Commercial information (Section 2.D) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Internet or other electronic network activity (Section 2.E) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Geolocation data (Section 2.F) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Audio, electronic, visual, or other sensory information (Section 2.G) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Not sold or shared Professional or employment-related information (Section 2.H) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Vendors necessary to complete transactions you request
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Education information (Section 2.I) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Not sold or shared Inferences (Section 2.J) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Advertisers, ad platforms and networks, and social media platforms · Third parties whose cookies and tracking tools we use as described in Section 5 (Cookies and Other Tracking Technologies)
· Commercial data partners to whom we make information available for their own marketing purposes
· Partners who work with us on promotional opportunities, including co-branded products and services
Sensitive Personal Data (Section 2.K) · Affiliates and subsidiaries · Service providers
· Professional consultants
· Law enforcement, government, agencies, and other recipients for legal, security, or safety purposes
· Other entities in connection with a corporate transaction
· Entities to which you have consented to the disclosure
· Not sold or shared
Sensitive Personal Data: We only use and disclose Sensitive Personal Data for the following purposes: (i) performing services or providing goods reasonably expected by an average person; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.12. Supplemental Information for the EEA, Switzerland, and the UK
The following terms supplement the above disclosures with respect to our processing of EEA, Swiss, and UK Personal Data, and only apply to the extent that EEA, Swiss, or UK data protection laws apply to our processing of your Personal Data. To the extent applicable, in the event of any conflict or inconsistency between the other parts of the Privacy Notice and the terms of this Section 12, this Section 12 shall govern and prevail with regards to the processing of such EEA, Swiss and UK Personal Data.
- Data Controller
Unless otherwise specified, the PureTech Scientific entity responsible for the processing of your Personal Data as the controller is the entity that has the primary relationship with you. This may be the PureTech Scientific group entity whose Digital Property you are viewing or using, that provides services to and accepts payment from you, that markets or provides promotional materials to you, or the primary PureTech Scientific group entity in the region where you interact with us.
In some cases, more than one PureTech Scientific group entity may make decisions on how your Personal Data is processed, such as when two PureTech Scientific group entities co-sign a contract with you or multiple PureTech Scientific group entities organize an event. In these situations, all such entities are jointly responsible for the lawfulness of the specific processing activities as joint controllers.
For further details, please do not hesitate to contact us using the contact details in Section 9 (Contact Information) above.
- Legal Bases for Processing
We process the following categories of Personal Data for the following processing purposes based on the following legal bases:
Processing Purposes To provide you or your company with products and services (Section 3.A) · Identifiers (Section 2.A) · Records about you (Section 2.B)
· Protected class and demographic information (Section 2.C)
· Commercial information (Section 2.D)
· Internet or other electronic network activity information (Section 2.E)
· Non-precise geolocation data (Section 2.F)
· Professional or employment-related information (Section 2.H)
· Inferences (Section 2.J)
· Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract. · Our legitimate interests in providing products and services and maintaining relationships.
· Your consent, when appropriate.
For our internal business purposes (Section 3.B) · Identifiers (Section 2.A) · Records about you (Section 2.B)
· Commercial information (Section 2.D)
· Professional or employment-related information (Section 2.H)
· Inferences (Section 2.J)
· Performance of a contract to which you are a party or taking steps at your request prior to entering into a contract. · Compliance with a legal or statutory obligation to which we are subject.
· Our legitimate interest in operating our business.
· Your consent, when appropriate
For our internal research and product improvement purposes (Section 3.C) · Identifiers (Section 2.A) · Records about you (Section 2.B)
· Commercial information (Section 2.D)
· Internet or other electronic network activity information (Section 2.E)
· Non-precise geolocation data (Section 2.F)
· Professional or employment-related information (Section 2.H)
· Inferences (Section 2.J)
· Our legitimate interest in improving our products and services. · Your consent, when appropriate
For legal, safety, or security reasons (Section 3.D) · Identifiers (Section 2.A) · Records about you (Section 2.B)
· Protected class and demographic information (Section 2.C)
· Commercial information (Section 2.D)
· Internet or other electronic network activity information (Section 2.E)
· Non-precise geolocation data (Section 2.F)
· Audio, electronic, visual, or other sensory information (Section 2.G)
· Professional or employment-related information (Section 2.H)
· Education information (Section 2.I)
· Inferences (Section 2.J)
· Sensitive Personal Data (Section 2.K)
· Performance of a contract to which you are a party or to take steps at your request prior to entering into a contract. · Compliance with a legal or statutory obligation to which we are subject.
· Our legitimate interests in complying with our obligations, enforcing our policies, and protecting the rights, property, and safety of Company and others.
· Establishment, exercise or defense of legal claims.
· Protection of vital interests.
· Your consent, when appropriate.
In connection with a corporate transaction (Section 3.E) · Identifiers (Section 2.A) · Records about you (Section 2.B)
· Protected class and demographic information (Section 2.C)
· Commercial information (Section 2.D)
· Internet or other electronic network activity information (Section 2.E)
· Non-precise geolocation data (Section 2.F)
· Audio, electronic, visual, or other sensory information (Section 2.G)
· Professional or employment-related information (Section 2.H)
· Education information (Section 2.I)
· Inferences (Section 2.J)
· Sensitive Personal Data (Section 2.K)
· The legitimate interest we and other participating entities have in completing corporate transactions. · Your consent, when appropriate.
For marketing or promotional purposes (Section 3.F) · Identifiers (Section 2.A) · Records about you (Section 2.B)
· Commercial information (Section 2.D)
· Professional or employment-related information (Section 2.H)
· Inferences (Section 2.J)
· Our legitimate interest in promoting our brand and products. · Your consent, when appropriate.
Due to the global nature of our operations, some of the recipients mentioned in Section 4 (How We Disclose Personal Data) of this Privacy Notice may be located in countries outside the EEA, Switzerland, or the UK that do not provide an adequate level of data protection as defined by data protection laws in the EEA, Switzerland, and the UK. Certain third countries, such as Canada, the Republic of Korea, and Japan, have been officially recognized by the European Commission, Switzerland, and the UK Secretary of State as providing an adequate level of protection. Transfers within our corporate group or to third parties located in third countries that have not received such recognition take place using an acceptable data transfer mechanism, such as the EU Standard Contractual Clauses (“SCCs”)/UK SCCs Addendum or International Data Transfer Agreement, Binding Corporate Rules, approved Codes of Conduct and Certifications, on the basis of permissible statutory derogations, or any other valid data transfer mechanism issued by the EEA, Swiss, or UK authorities.
Please reach out to us using the contact information in Section 9 (Contact Information) above if you want to receive further information about how we transfer Personal Data or, where available, a copy of the relevant data transfer mechanism.