PRIVACY & COOKIE POLICY

This Privacy and Cookies Policy (the “Privacy Policy”) describes how Lifebit Biotech Ltd and/or its subsidiaries (as applicable) ("Lifebit," "we" or "us") treat information you provide to us or that we collect, including how we use such information, how we protect the security of such information and how you may change or request that we amend such information from our systems. This includes any information associated with you (such as your name, title, email address or phone number) that is supplied to us in conjunction with your use or potential use of our website and/or Platform (collectively, the “Service”), as well as information we generate regarding your use of the website or the Service, in either case, information that does, or can be used to, identify you ("Personal Information").

Except as described in this Privacy Policy we will not, without your consent, sell or rent to any third party any Personal Information collected through this website or the Service.

Please note our website includes hyperlinks to other websites neither owned nor managed by us. Lifebit is not associated with these third-party websites and does not review their privacy policies. We cannot guarantee the privacy of any information that may be obtained by third parties at these other websites. We strongly encourage you to review the privacy policies of any website you visit before supplying Personal Information through that website.

Based on your location, you may have rights under privacy laws related to your personal data. You may choose to exercise those rights by emailing us at privacy@lifebit.ai

What information does Lifebit collect through its public website, or other interactions, and how is this information used?

Anyone Who Contacts Us through Our Website

Lifebit collects certain Personal Information through its website when you choose to submit such information to us through email, an online form or other method (such as contacting us through our "Contact Us" or "Lifebit Support" website functions). This includes Personal Information you provide to Lifebit in order to request additional information about the Service, employment opportunities, for press inquiries or for other purposes. We use information collected through our website to respond to specific requests for information about our Service and other inquiries.

You do not need to provide this information to us but if you don't, we will not be able to respond to your communication. We use this information to answer any issues or concerns and to monitor customer/potential customer communications for quality and training purposes. We also use this information to develop new services and to improve or personalise existing services. We use this information because we have a legitimate business interest in understanding customer/potential customer feedback and in responding to your communications in a consistent way. We will keep this information for as long as you have a relationship with us or, if you do not have a relationship with us beyond this communication, for a reasonable length of time that lets us understand how people use our website.

Visitors to Our Website

Lifebit also maintains a log of certain information concerning visitors to our website, including but not limited to a visitor's IP address (a computer's numerical Internet address), the websites from which visitors access our website, the type of web browsers used to access our website, the device used to access our website and the pages viewed. Such information may be treated as Personal Information about the visitor in accordance with applicable local law.

You do not need to provide this information to us and can, in certain circumstances, stop us from collecting it by contacting us at privacy@lifebit.ai. Lifebit uses this information to monitor the way our website is used and identify issues with the website and users' experience of it. We use this information because we have a legitimate business interest in understanding how our website is accessed, how it is used and any problems users have with it across multiple devices. We will keep this information for a reasonable length of time that lets us understand how people use our website and any technical issues they have.

Marketing

If we have collected your Personal Information through our website or through other channels (such as if you have exchanged contact information with one of our Sales representatives or partner constituents, or have included your Personal Information in an event registration form), and we have a permission to do so, we will  use your Personal Information to inform you about other Lifebit services and products that might be of interest to you and to gather feedback from you on our website and our Service.  We use this information because Lifebit has a legitimate business interest to promote its products and services. We will keep your Personal Information for a reasonable length of time that lets us understand how people use our Service and the impact of any marketing offers that we make.

Cookies

We also collect information about website users through “cookies.” Cookies are small pieces of information sent by a web server to a web browser which allow the server to uniquely identify the browser on each page. For further information about Cookies, please see our "Cookies" section below.

What information does Lifebit collect about users of its Service and how is this information used?

This section applies to users of the Lifebit Service. If you only use our public website, this section does not apply to you. If you, your employer or a third party decide to purchase our Service, we will use your Personal Information for purposes of providing the Service to you. We will also provide your Personal Information to trusted partners and our affiliates who work on behalf of Lifebit and use your Personal Information to help Lifebit provide the Service. Such partners include database providers, data analytics providers (such as Amazon Web Services) and other suppliers who assist with providing technical support. We use this information because we have a legitimate business interest in performing the contract that we have entered into with you, your employer or a third party and in providing, managing and administering our Service.

Setting Up the Service

In this Privacy Notice, a “Trusted Research Environment” (also known as a “TRE”) or a Workspace is a portion of the Service configured to permit authorized users to access and share information. The manager of an TRE, the owner of a Workspace, your employer or an affiliate or partner of your employer, who is using the Service, may add you as a participant in one or more TREs or Workspaces. The person adding you for the first time to an TRE or Workspace will provide certain Personal Information about you, such as your name, company name, work email address and work telephone number. We will provide you with a user ID (an email address) and account activation email to access the Service and create a user “profile” for use as described below.

When you first sign onto the Service, you will be presented with your “profile,” which contains the information supplied to us. You will be able to update or correct any of the Personal Information in your profile. As the Service is intended for business purposes only, unless your place of work is also your home, you should only enter business contact information. We use this information to provide the Service and to identify how you'd like to use your account. We use this information because it is necessary to provide you with an account and because we have a legitimate business interest in enabling you to update your preferences and settings online.

Once your Personal Information has been entered into your profile, this information is added to the participant list for each TRE or Workspace you have been authorized to access. Other participants of your TRE(s) or Workspace(s) may then have access to your Personal Information. You may receive certain emails relating to your use of the Service, such as email alerts related to TREs or Workspaces on which you are a participant and other email communications relating to the Service. Emails will be sent to the email address(es) listed in your profile.

Your Personal Information is also added to Lifebit' global directory of current and former users of the Service (the “User Directory”). If you are selected to join another TRE or Workspace in the future, your user ID will be authorized to access that TRE, and your Personal Information will be added to the participant list for that TRE or Workspace. Our clients also have the ability to maintain one or more “user groups,” which are contact lists comprised of all users that have used the TREs or Workspaces that they have managed. Your Personal Information may be added to one or more of these business groups.

We use your Personal Information as set forth above to provide, manage and facilitate your use of the Service, whether now or in the future. We use this information because we have a legitimate business interest in performing the contract that we have entered into with your employer, or with the affiliate or partner of your employer (as applicable). We will keep this information for as long as you remain a Lifebit account holder.

Reports and Analytics

As a function of the Service and in order to conduct internal analysis of use of the Service, Lifebit also will maintain a history of your access to the Service, and certain actions taken by you while accessing the Service (e.g. access to TREs, Workspaces and documents, including time, date and length of access). This includes maintaining a log of users' IP addresses, the websites from which users access the Service, the type of web browsers used to access the Service and the browser's settings that may affect Service performance. The information described in this paragraph is referred to as “Usage Log Information.” It may also be combined with Usage Log Information about other users of an TRE or Workspace you are permissioned into to provide an overall view of how the TRE or Workspace is used. 

Usage Log Information will be recorded and used internally within Lifebit and may also be made available to managers of TREs, owners of Workspaces, Service licensees or to your employer or entity on whose behalf you are accessing the Service.

We use this information because we have a legitimate business interest in understanding how our Service is accessed, how it is used and whether there are any potential security issues arising from such use.  We will keep this information for a reasonable length of time that allows us to provide the Service, to perform the contract that we have entered into with your employer, or with the affiliate or partner of your employer (as applicable) and to understand how people use our Service.

Support

We share Usage Log Information, as well as information about your browser and other local computer settings, with TRE managers and Workspace owners in order to troubleshoot or avoid potential access problems. We also use this information (in addition to your contact information) to contact you in relation to providing you with support, including where you have already contacted us via telephone, email or our "Lifebit Support" function. Where necessary, we disclose this information to trusted support providers who will undertake this role on our behalf.

We need this information to provide you with support requested. We use and disclose this information to provide the Service and provide relevant support services. We use this information because we have a legitimate business interest in ensuring that you receive an effective Service from us. We will keep this information for a reasonable length of time that lets us understand any technical issues that users have with our Service.

TRE Managers and Workspace Owners

If you have been designated by your organisation as an TRE manager or Workspace owner, we will use your Personal Information when we are undertaking work on behalf of your organisation, for example adding participants for the first time to an TRE or Workspace. We use your Personal Information because it is necessary for our contract with your organisation that we interact with you in order to comply with your organisation's instructions. We may also notify you when your service is about to be suspended, in the event where your organisation has an overdue balance and we have not been able to reach out to, or get a response from, your organisation’s billing department. We will keep this information for as long as your organisation has a relationship with us.

Marketing

If you are a user of the Service and we have permission to send you marketing messages, we will use your Personal Information to contact you about our services and products. We will contact you either by email or phone. We also use Usage Log Information to better tailor these communications to you by identifying those features and aspects of our services that are most relevant to you based on your historic usage.

You may decline to receive mail or email from us by selecting the opt-out link which will be contained in any such email that you receive, or by contacting us at privacy@lifebit.ai

Sale or Merger of Lifebit

Subject to applicable law, as the our user Directory is a business asset of Lifebit, if Lifebit were sold to or merged with another company, the User Directory (which includes your Personal Information) may be transferred to a successor of the company, or to a subsidiary or affiliate of Lifebit, who will agree to abide by the terms of this Privacy Notice. You have the right to request that your Personal Information be removed from the User Directory at any time (see below).

Legal Requirements

We will also disclose personal information (1) in response to lawful requests by public authorities (including to meet national security or law enforcement requirements) and, where applicable, in accordance with our internal policy on access by government or regulatory authorities and (2) in our sole discretion if we believe that such disclosure is appropriate in connection with an official government or regulatory investigation or in response to a perceived significant threat to a person's health or property. 

Lifebit may also process your Personal Information if necessary in the defence of a legal claim. We will not delete Personal Information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

What information could Lifebit otherwise collect about me?

Billing

If you have been designated by your organisation as being a contact for billing or payment purposes, we will use your Personal Information to process your organisation's order, issue invoices to your organisation and take payment from, or make payment to, you (including refunds if applicable). We use this information because it is necessary for our contract with your organisation that we collect information from its representatives to process payments or give or receive refunds. We will keep information relating to payments for the length of the contract between us and for ten (10) years afterwards.

Reviews and Feedback

If you are a user of an TRE or Workspace and you contact Lifebit to provide feedback or reviews of your experience, we will use your Personal Information (as well as your feedback/review) to understand and respond to customer feedback. We use this information because we have a legitimate business interest in understanding customer feedback and in responding to your communications in a consistent way. We will keep this information for a reasonable length of time that lets us understand and assess people’s experience of our Service.

How does Lifebit protect the security of my Personal Information?

Lifebit has implemented and currently maintains an effective written information security program that includes administrative, technical, and physical safeguards and other security measures necessary to (a) ensure the security, confidentiality, and integrity of your Personal Information; (b) protect against any anticipated threats or hazards to the security, confidentiality, and integrity of your Personal Information; (c) protect against unauthorized access to, destruction, modification, disclosure or use of your Personal Information; and (d) detect and respond to security incidents involving your Personal Information. We permit persons working for us to access and use your Personal Information only to serve our legitimate business and our customers’ service needs, in accordance with this Privacy Notice.

Notwithstanding any other provision of this Privacy Notice, Lifebit will disclose your Personal Information (1) in response to a subpoena, search warrant, court order, exchange rule, other legal process or where Lifebit is otherwise required to do so in accordance with locally applicable law and where applicable, our internal policy on access by government or regulatory authorities; and (2) in its sole discretion if it believes such disclosure is appropriate in connection with an official government or regulatory investigation, or under exigent circumstances in response to a perceived significant threat to a person's health or property.

What about the transfer of my Personal Information to other countries?

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, including to countries outside of the location(s) of your business, such as the United States and countries within Europe, Latin America and the Asia-Pacific region. Where such transfers of your Personal Information are made they will be made in accordance with applicable law.

Transfer of Information to Other Countries – Users in European Economic Area (EEA)

We store your Personal Information on cloud servers located in various global locations depending on the services provided and the technologies used. The Personal Information for the Lifebit Platform is stored in the EU data servers. Transfers of information are governed by contracts including standard contractual clauses (SCCs) approved by the European Commission.

How can I change, update or delete my Personal Information, or request that I not be contacted for non-support purposes?

You can change or update your Personal Information at any time, regardless of whether you are a current or former user of the Service, by logging into the Service with your user ID and password and accessing your profile. All Personal Information except your name, company name, and email address can be changed by you through your profile. If you wish to change your name, company name, or email address as listed in your profile, you must message privacy@lifebit.ai

You may request that we remove your Personal Information from Lifebit’s User Directory. However, by doing so, you will automatically lose all access rights to the Service. You may have your Personal Information removed from Lifebit’s User Directory by emailing privacy@lifebit.ai. Please note that your Personal Information may be re-added to Lifebit’s User Directory in the future if you are asked to participate in another TRE or Workspace, as described above.

You also may decline to receive mail or email from us that does not relate directly to your access to or use of the Service or a particular TRE. If you wish to receive “support-only” contact at any time, please contact privacy@lifebit.ai

What rights do I have about the use of my Personal Information?

If you are a resident of the EEA, you have certain rights regarding Lifebit’s use of your Personal Information.

Some of these rights, e.g., the right to be forgotten or the right to request that we transfer your information to another company, will only apply in certain circumstances. Generally, these rights will not be available if there are outstanding contracts between us, if we are required by law to keep the information or if the information is relevant to a legal dispute.

We have listed the rights you have over your Personal Information and how you can use them below. These rights are subject to restrictions under European data protection law and, subject to the exemptions in that law, may only apply to certain types of information or processing.

  1. We need your consent for some of the ways we use your Personal Information, e.g., for marketing or processing special categories of information about you. You can remove that consent at any time.
  2. You can ask us to confirm if we are processing your Personal Information and if we are, you can ask for access to that information and details regarding:
     
    1. why we are using your information;
    2. what information are we using;
    3. who we have shared the information with;
    4. the period for which your information will be stored, or how we determine that period;
    5. your right to object to our processing of your information, your right to have your information erased or the processing of your information restricted;
    6. your right to lodge a complaint with a data protection supervisory authority;
    7. the source of your information where it has not been provided by you;
    8. the existence of any automated decision-making processes using your data or any profiling;
    9. the transfers of your information to countries outside of EEA and the safeguards in place; and
    10. your right to a copy of the information about you which is being processed by us.
  3. You can ask us to correct your information if it's wrong.
  4. You can ask us to delete some of your information.
  5. You can ask us to restrict how we use your information.
  6. You can ask us to help you move some of your information to other companies.
  7. You have a right to ask that we provide your information in an easily readable format to another company.
  8. You can ask us to stop using your information, but only in certain cases.
  9. You have the right to complain to the relevant supervisory authority.

You also have a right to object to us processing your information in certain circumstances.  You can ask us to stop processing your information at any time. In certain circumstances we may not be able to do this or may not be required to do this. For example, if there are outstanding contracts between us, if we are required by law to keep the information or if the information is relevant to a legal dispute then we may not stop processing your information.

If you would like to exercise, or discuss, any of these rights, please contact privacy@lifebit.ai.

Does Lifebit use "cookies"?

Our website uses cookies to distinguish you from other users of our website and to collect information about your online preferences. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies. These cookies collect information about how you use our website. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics.
  • Functionality cookies. These cookies remember choices you make and are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies collect information about your browsing habits such as the pages you have visited and the links you have followed. We will use this information to make our website more relevant to your interests. They are also used to make advertising more relevant to you, as well as to limit the number of times you see an advert. These cookies are usually placed by third-party advertising networks. They remember the other websites that you visit and this information is shared with third-party organisations, for example advertisers.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

We use Google Analytics. For information on how Google processes and collects your information in regard to this product and how you can opt-out, please see here.

We also use Google Ads to publish advertisements. When you view or click on an advert a cookie will be set to help better provide advertisements that may be of interest to you on this and other websites.  You may opt-out of the use of this cookie by visiting Google’s Advertising and Privacy page.

We also use Hubspot to understand your browsing habits such as the pages you have visited and the links you have followed, through targeting cookies analysis. For information on how Hubspot processes and collects your information in regard to this product and how you can opt-out, please see Hubspot’s Privacy Policy.

Most internet browsers are automatically set up to accept cookies. However, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

For more information on managing cookies, please go to www.allaboutcookies.org, or visit www.youronlinechoices.com which has further information about behavioural advertising and online privacy.

How will I be notified of changes to this Privacy Notice?

From time to time, we may change and/or update this Privacy Notice. We recommend you regularly review this page.

How can I contact Lifebit about this Privacy Notice?

If you have questions, or would like to complain about this Privacy Notice and our information practices, please contact us by email at privacy@lifebit.ai

You also have the right to complain to the local data protection authority within the EEA (DPA). You can find the details of your local DPA here

Types of personal data collected and purposes for collection and use 

Lifebit processes certain personal data for two purposes: 

(1) firstly it processes certain personal data on its own behalf for its internal business purposes; and 

(2) it also processes certain personal data it receives or has had access provided to on behalf of its customers. In processing each of these categories of personal data, it acts as a data controller (in relation to the first purpose) and a data processor (in relation to the second purpose) respectively. 

Disclosures in response to lawful requests by public authorities

Lifebit may also disclose personal data (1) in response to lawful requests by public authorities (including to meet national security or law enforcement requirements) and, where applicable, in accordance with our internal policy on access by government or regulatory authorities and (2) in our sole discretion if we believe that such disclosure is appropriate in connection with an official government or regulatory investigation or in response to a perceived significant threat to a person's health or property. 

Choice 

If you do not wish Lifebit to pass your personal data that is processed by Lifebit as a Data Controller to a third party who subsequently uses your data for its own purposes (such as one of our marketing partners), you can make such requests by emailing privacy@lifebit.ai

Data integrity and purpose limitation 

When Lifebit is acting as a data processor, Lifebit will process personal data solely in compliance with the instructions of its customers, who act as data controllers in respect of such data and will be responsible for ensuring that the personal data is appropriate and only processed for limited purposes. In addition, when its provision of services to a customer ceases, Lifebit will, as agreed with the customer, comply with Lifebit' policy for the secure deletion of personal data processed on behalf of that customer. 

Access 

You have certain rights under the Principles to access personal data about you that Lifebit processes as a data controller. To access such personal information please contact us at privacy@lifebit.ai. We will respond to your request in accordance with the Principles. 

Where Lifebit is acting as a data processor, we will pass each request that we receive from an individual to access, correct, amend or delete personal data relating to them (Request) to the relevant data controller and will not respond to the Request itself. Lifebit, to the extent instructed by a data controller and in accordance with its customer agreements and applicable law, will assist a customer in complying with Requests by providing relevant information and support to the relevant customer to enable it to comply with the Request. 

Complaints 

If you have any complaint regarding Lifebit' compliance with the Principles please contact us by email at privacy@lifebit.ai. We will respond to your complaint within 30 calendar days of receipt of your email. 

Where your complaint relates to personal data that we process on behalf of our one of our customers, we may pass your complaint to the relevant customer and will tell you we have done so. 

Independent dispute resolution body 

If you feel that Lifebit has not satisfactorily resolved your complaint or has failed to respond to your complaint within 45 days, you may bring your complaint to the attention of your local data protection authority within the EEA (DPA). Lifebit commits to cooperate with this panel as an independent body to resolve disputes relating to its compliance with the Principles. Lifebit will comply with any advice given by DPAs where they take the view that specific action is necessary to comply with the Principles and will provide the DPAs with written confirmation that such action has been taken. 

You can find the details of your local DPA here

Arbitration 

If you are located in the EEA and have not been able to resolve your complaint by any other mechanism, you may, in certain circumstances, be able to seek resolution via binding arbitration. For additional information about the arbitration process, please visit the Privacy Shield website. 

You can find the details of your local DPA here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Contact us 

If you have a question about our adherence to the Principles please contact us at privacy@lifebit.ai

 

Last Updated: 2022