PRIVACY NOTICE/YOUR PRIVACY RIGHTS
Effective Date: [April 14, 2024]
LAST UPDATED [April 14, 2024]
Table of Contents
1. Sources of Personal Data
2. Types of Personal Data We Collect
3. How We Use Personal Data
4. How We Disclose Personal Data
5 . Cookies and Other Tracking Technologies
6. Data Security and Data Retention
7. Children’s Privacy
8. External Links
9. Contact Information
10. Rights Concerning Personal Data
11. Supplemental Information for Residents of California
12. 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.
We collect Personal Data about you from the following sources:
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.
We may collect the following types of Personal Data:
We may use Personal Data for the following purposes:
We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.
We may disclose Personal Data to third parties, including to the categories of recipients described below:
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.
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 for further information.
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.
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.
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.
If you have questions regarding this Privacy Notice or how the Company processes your Personal Data, please contact us at:
info@puretechscientific.com
Depending on the jurisdiction you are in, you may have some or all of the following privacy rights:
You may request to exercise the rights available to you via our webform [hyperlink to Contact Us Page], emailing us at [orders.na@puretechscientific.com], or by calling us at [1-888-536-9836]. We will not discriminate against you for exercising your privacy rights.
In addition to the disclosures above, this section provides supplemental information about California privacy rights and how we process Personal Data of California residents.
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 [LINK to Contact Us page] 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.
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 | Categories of Third Parties With Whom We Disclose Personal Data for a Business Purpose | Categories of Third Parties to Whom Personal Data is Sold or Shared for Targeted Advertising |
Identifiers (Section 2.A) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Records about you (Section 2.B) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Protected classifications and other demographic information (Section 2.C) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Commercial information (Section 2.D) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Internet or other electronic network activity (Section 2.E) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Geolocation data (Section 2.F) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners 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 subsidiariesService providersProfessional consultantsLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Not sold or shared |
Professional or employment-related information (Section 2.H) | Affiliates and subsidiariesService providersProfessional consultantsVendors necessary to complete transactions you requestLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Education information (Section 2.I) | Affiliates and subsidiariesService providersProfessional consultantsLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Not sold or shared |
Inferences (Section 2.J) | Affiliates and subsidiariesService providersProfessional consultantsLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities to which you have consented to the disclosure | Advertisers, ad platforms and networks, and social media platformsThird 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 purposesPartners who work with us on promotional opportunities, including co-branded products and services |
Sensitive Personal Data (Section 2.K) | Affiliates and subsidiariesService providersProfessional consultantsLaw enforcement, government, agencies, and other recipients for legal, security, or safety purposesOther entities in connection with a corporate transactionEntities 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.
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.
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.
In other cases, different PureTech Scientific group entities may independently determine how your Personal Data is processed as independent controllers, such as when one PureTech Scientific group entity uses Personal Data received from another PureTech Scientific group entity to market to you.
For further details, please do not hesitate to contact us using the contact details in Section 9 (Contact Information) above.
We process the following categories of Personal Data for the following processing purposes based on the following legal bases:
Processing Purposes | Categories of Personal Data | Legal Bases |
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.