Lifebit Privacy Policy

This privacy policy describes how the Lifebit group of companies ("Lifebit," "we" or "us") treat personal information you provide to us or that we collect about you.

This includes any information that identifies you personally (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(s) and / or the Platforms and services we provide (collectively, the “Service”), as well as information we generate regarding your use of the website or the Service,  in either case, including information that can be linked with such information to identify you directly or indirectly ("Personal Information"). 

This notice describes our practices in connection with Personal Information that we collect from you through the website(s) and / or Services that link to this notice.

This notice applies to the Lifebit group globally. 

If you are a California resident, please see the relevant section below for our California Privacy Policy which will apply along with this notice and also addresses the privacy rights applicable to you under the California Consumer Privacy Act (CCPA).

Lifebit complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Click on the link for our EU-US and SWISS-US Data Privacy Framework Policy which supplements and adds to this Privacy Policy. 

Our clients, customers and partners (and our target market) are businesses and research institutions rather than individual consumers. However, we note that individuals will access our website(s) and Service on behalf of our clients. 

Please note that our website(s) and the Service are  not directed to individuals under the age of 16, and we request that such individuals do not provide Personal Information through the website or the Service.

This notice covers:

1. Who is the controller(s) of your Personal Information?
2. What information does Lifebit collect and how is this information used?
3. Does Lifebit share Personal Information with any third parties?
4. Is Personal Information transferred to other countries?
5. What rights do I have regarding the use of my Personal Information?
6. Contacts, Notices and Revisions
7. California Consumer Privacy Act (CCPA) Notice
8. EU-US Data Privacy Framework
   
   

 1. Who is the controller of your Personal Information?

Lifebit Biotech Limited, a company incorporated and registered in England and Wales whose registered office is at Office 4, 219 Kensington High Street, London, England, W8 6BD, United Kingdom,is the controller of your Personal Information. 

This Privacy Notice covers the information that Lifebit collects as the Controller.

 2.  What Personal Information does Lifebit Collect and how is this used?

Links to third party websites

Please note our website includes hyperlinks to other websites neither owned nor managed by us. Lifebit is not associated with these third-party websites. 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.

Collecting personal data

We collect Personal Information in three main ways: 

•  Information provided directly by you;

•  Information we collect automatically or generate based on your activities on our website or when using our services; or

• Information we may collect where we have lawfully obtained it from third parties or public sources.

Information provided by you

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 or requesting a Demo). You do not need to provide this information to us but, if you don't, we may not be able to respond to your communication.  

If you are a job applicant or candidate for a job we may collect your name, surname, email address, telephone contact, educational background, employment history  and name of references. Personal Information of job applicants will also be used in accordance with our internal Staff privacy policy if their job application is progressed. 

The table below provides more details about the Personal Information we collect, how we use it and retention period.

Information we collect automatically or generate based on your activities on our website

Visitors to our website. We also collect information that you passively submit during your use and navigation of the Sites.  Information collected in this manner includes the URL of the site you came from, the browser software you use, your Internet Protocol (IP) address, IP ports, date/time of access, data transferred, pages visited, the amount of time you spend on the Sites, transactions conducted on the Sites and other “clickstream” data.

Log Files on our website. Lifebit also collects and maintains a log of certain information as you navigate around our website (s) including the URL of the site you came from, the browser software you used, Internet Service Provider (ISP),your Internet Protocol (IP) address, date/time of access,  the amount of time you spent on our website, the pages of our website that you visited and any other information your browser may send to us.   

Analytics. Our website(s) also use Google Analytics. Google Analytics collects and stores data via cookies, such as time of visit, pages visited, time spent on each page of the Site, the IP address, and the type of operating system used in the devices used to access the Site. You can opt out of Google Analytics via this link http://www.google.com/ads/preferences/plugin/.

Cookies. Our website (s) use cookies which are small text files that are sent to or accessed from your web browser or your device’s memory. Cookies help to distinguish you from other users of our website and also allows us to improve our site. A cookie typically contains certain information including a randomly generated unique number, user settings, browsing history and activities conducted while using our Services. Some of the information collected by cookies may include Personal Information.   See the table below for details of how we use cookies. For further information on how we use cookies on our website and how you can manage the information we collect, see our cookie banner, Cookie Settings and Cookie Policy. We may also carry out marketing and analytics based on the information we have collected.  Please see the section on Marketing, below. 

Marketing

If we have collected your Personal Information through our website or through other channels (such as if you have exchanged contact details with one of our Sales representatives or partner constituents, or you have included your Personal Information in an event registration form or we have sourced this via a lead generation tool), we may use this for marketing purposes (in line with applicable marketing rules).  

We may contact you either by email or phone (where you have provided your number directly to us).  We also use search and social media advertising and may contact you solely in your job capacity through social media platforms. As our clients, customers and partners are businesses and research institutions rather than individual consumers, our marketing is targeted at B2B.

You may decline to receive email marketing from us by selecting the opt-out link which will be contained in any such email you receive. If you do not wish to be contacted on LinkedIn, you may decline by responding to any messages received from us asking to not be contacted in the future.  

To opt out of telemarketing, please inform one of our Sales representatives. Alternatively, you can contact us at privacy@lifebit.ai.

You can refuse cookies or configure your cookie settings via our cookie management tool on our website – see also our Cookie Policy.  You can also disable ad tracking on your devices using your device settings and configure your cookie settings and ad preferences via the various social media platforms.  See also ‘What rights do I have regarding my Personal Information” section below regarding your right to object.

Information we may collect where we have lawfully obtained it from third parties or public sources. 

We may receive information about you from other sources such as publicly held records , for example, for due diligence or anti-money laundering checks, if applicable.  We may also receive information about you from other sources, including public sources, third-party services and organisations.  For example, if you access third-party services, such as Facebook, Google, or Twitter, through our websites or visit our websites from third party services,  depending on your settings, we may collect information from these third-party services.

Lifebit Platform and Services

This section applies to users of the Lifebit Platform and Services. If you only use our public website, this section does not apply to you. 

When  you, your employer or a third party decide to purchase our Service as a Data Consumer, Data Custodian or other third party with whom we have collaborated in connection with our Service (Customer), we will generally act as a processor and our Customer will be the controller.  In this case, we will enter into a Data Processing Addendum with the Customer as required under applicable laws.  Please contact privacy@lifebit.ai to request a copy of the Data Processing Addendum.   

However, there are limited scenarios in which we process personal data  as a controller in connection with the Lifebit Service.  These are set out below: 

We have explained the key aspects of Lifebit’s use of Personal Information related to the Service in more detail below.

How we use your Personal Information 

We may use your Personal Information for the following purposes: 

• To provide the Services including the public website(s);

• To contact you and communicate with you in connection with the website(s), the Lifebit Platform, our Services, and notifications, services, programs or offerings for which you may have registered;

• To set up the Platform and Service access
  
  

Set up the Platform and Service access

In this 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 a 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 a 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 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 to enable 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. (See “Marketing” sections of this privacy policy regarding marketing communications.)

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.

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.

To configure your access as a TRE Manager or  Workspace Owner

If you have been designated by your organisation as a TRE manager or Workspace owner, we will use your Personal Information to configure your access and that of other users to a TRE or Workspace. We use your Personal Information or contract management purposes, such as to 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. 

Administrative and Billing purposes

 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. 

Reviews and Feedback

If you are a user of a 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 and also for service improvement purposes.  

Marketing

If you are a user of the Service, we may use your Personal Information to contact you for marketing purposes about our services and products (in line with applicable marketing permissions). We will contact you either by email or phone (where you have provided your number to us directly). We also use search and social media advertising and may contact you solely in your job capacity through social media platforms.  In addition, we 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. As our clients, customers and partners are businesses and research institutions rather than individual consumers, our marketing is targeted at B2B.

You may decline to receive email marketing from us by selecting the opt-out link which will be contained in any such email you receive.  If you do not wish to be contacted on LinkedIn, you may decline by responding to any messages received from us asking to not be contacted in the future.  

To opt out of telemarketing, please inform one of our sales representatives. Alternatively, you can contact us at privacy@lifebit.ai.

You can refuse or configure your cookie settings via our cookie management tool on our website – see also our Cookie Policy.  You can also disable ad tracking on your devices using your device settings and configure your cookie settings and ad preferences via the various social media platforms.  

Compliance with applicable laws 

For example we may be required to collect and retain personal information to comply with applicable laws and for:

• Our legitimate purposes of protecting our legal rights

• Fraud prevention and detection

• Compliance, regulatory, and investigative purposes. 

• We may sometimes be required by law to share Personal Information with third parties, such as governmental authorities or law enforcement officials, subject to applicable law.
  
  
  

 3. Does Lifebit share Personal Information with any third parties?

From time to time, Lifebit may share Personal Information with the following categories of third parties for the following purposes (which will generally be pursuant to Lifebit’s legitimate interests):

• Our group companies and affiliates listed above for legitimate reasons related to the running of our business.
• Third parties who perform services on our behalf (and in some cases, our affiliates), to enable them to support the services we provide to you, including consultants, professional advisors, digital marketing agencies, social media partners for advertising purposes, service providers involved in hosting (cloud providers such as AWS), providers of industry-specific tools (such as for genomic data analysis), marketing technology (such as for email campaign creation, email automation, managing opt-outs etc), data analysis (such as website traffic analytics and data annotation), payment processing, infrastructure provision (such as website and application development), auditing, insurers, IT services, customer service, email delivery, and other similar services.
• Our social media partners when we use social media plug-ins on our website(s).
• Credit reference agencies, debt collection agencies, courts and others in order to enforce our contracts we have with you or your business, defend any claims and to allow us to pursue available remedies or limit the damages that we may sustain in any action.
  
  

Business transactions

We may share your Personal Information in connection with a sale or prospective sale of Lifebit or business transaction relevant to Lifebit. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such assets may include databases such as our User Directory or marketing database. Such third parties may include, for example, an acquiring entity or investor and its advisors, who will be required to keep such information confidential.  Such transfers will generally be pursuant to Lifebit’s or a third party’s legitimate interests.

Legal Requirements

We will also disclose personal information: (1) if we are under a duty to do so; (2) 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 (3) 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 for the purpose of bringing or defending legal claims or responding to regulatory investigations. We will not delete Personal Information if relevant to an ongoing investigation or a dispute. 

 4. Is Personal Information transferred 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) / UK

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. We engage service providers in a number of countries outside the EEA and the UK.

For transfers of Personal Information to countries that are not recognised as “adequate” by the European Commission or the UK Secretary of State, we put in place appropriate contracts that include standard contractual clauses (SCCs) approved by the European Commission / UK Information Commissioner.  To access a copy, please contact privacy@lifebit.ai.

  5. What rights do I have regarding the use of my Personal Information?

Individuals located in UK and the EEA, have certain rights regarding their Personal Information, as set out in more detail below. 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. Most rights are also subject to certain exceptions and exemptions that may mean that we are not always legally required to comply with your request in part or in full.

If your request relates to Personal Information that Lifebit processes as a processor on behalf of a customer (controller), we will pass each request that we receive from an individual to the relevant controller to respond to you. However, your request will be responded to more quickly if you direct it to the controller in the first instance (e.g. your employer or the Data Custodian and / or the Data Consumer that is using our Service).

You have the right to object to us using your Personal Information where we rely on “legitimate interests” as a lawful basis for processing your Personal Information or where we use your Personal Information for direct marketing purposes (i.e. if you no longer want to receive direct marketing communications from us).

Updating your Platform user profile

You can change or update your Personal Information at any time, as 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. Please note that your email address must be restricted to a business email address.

Deleting your Personal Information from the Platform

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.

Non-Service emails

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. (See also the “Marketing” sections above and “What rights do I have about the use of the Personal Information?” below.)

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

6. Contacts, Notices and Revisions

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 and its processing of my Personal Information? 

If you have questions about the handling of your Personal Information or this notice, or would like to exercise any of your rights in relation to your Personal Information, please contact us by email at privacy@lifebit.ai. 

• Do you have a Data Protection Officer (DPO)?

Our DPO can be contacted at privacy@lifebit.ai.

• What if I have a complaint about Lifebit’s handling of my Personal Information that Lifebit hasn’t been able to resolve?

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

The UK ICO’s details are:

Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Phone number: 0303 123 1113.

Website: https://ico.org.uk/make-a-complaint/  

7. California Consumer Privacy Act (CCPA) Notice

This California Consumer Privacy Act Notice, in conjunction with the other portions of this Privacy Notice, provides information for certain California residents in connection with the California Consumer Privacy Act of 2018 (“CCPA”).  This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Under the CCPA, and for purposes of this California Consumer Privacy Act Notice portion of this Privacy Notice, “Personal Information” generally means information that identifies, relates to, or describes a California resident or household and includes the categories listed below.  Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months. 

Information Collected. We collect the following categories of Personal Information: 

1. Identifiers, such as (but not limited to) name and online identifiers;
2. Personal information, as defined in the California customer records law, such as (but not limited to) contact information and financial information; 
3. Characteristics of protected classifications under California or federal law, such as (but not limited to) age, gender, and marital status; 
4. Commercial information, such as transaction information;
5. Internet or network activity information, such as browsing history and interactions with our websites;
6. Geolocation data, such as device location;
7. Audio, electronic, visual and similar information, such as call and video recordings;
8. Professional or employment-related information, such as work history, prior employer and reference contact information; and
9. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
   
   

Depending on a California consumer’s particular interactions and relationship with us, we may not collect each of the above categories of Personal Information about each consumer.

Sources of Personal Information. We collect this Personal Information directly from California residents themselves, as well as from other sources, such as public databases, your employer and its employees, our affiliates, third-party sources of demographic information, and social media platforms.

Purposes. We use this Personal Information to operate, manage, and maintain our business, to provide our products and services, to communicate with our customers, prospective customers, vendors, employees and other associated entities and persons, and to otherwise accomplish our business purposes and objectives.  Our business purposes and objectives include, for example, developing, improving, supporting, servicing and maintaining our products, services, customer relationships and employee relationships; personalizing, advertising, and marketing our products and services; conducting research, analytics, and data analysis; maintaining our facilities and infrastructure; undertaking quality and safety assurance measures; conducting risk and security controls and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies (including responding to requests from California residents under the CCPA); maintaining records; and exercising and defending legal claims.

Disclosures of Personal Information. We may disclose the categories of Personal Information listed above to our affiliates and to third parties, such as our service providers, for our operational business purposes.

Depending on a California consumer’s particular interactions and relationship with us, we may not have disclosed each of the above categories of Personal Information about each consumer.

Sales of Personal Information. We have not “sold” Personal Information for purposes of the CCPA. 

For purposes of this CCPA Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

Children's Privacy

Lifebit does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers. If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Do Not Track (“DNT”)

Lifebit website does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. Lifebit website uses cookies and other tracking technologies to distinguish you from other users of our website, please check our cookies policy here.

You may stop or restrict the placement of cookies and other tracking technologies on your device or remove them by adjusting your preferences as your browser or device permits. 

Links to Other Websites 

Lifebit website may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

If you are a California resident, you have the following rights:

1. Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:
   • The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   • The specific pieces of Personal Information we collected about you;
   • The business or commercial purpose for collecting Personal Information about you; and
   • The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.
     
     
2. Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.
   • To make a request for the disclosures or deletion described above, please contact us at privacy@lifebit.ai.
     
     
3. Right to Be Free from Discrimination.

8.EU-US and Swiss-US Data Privacy Framework Policy

Lifebit complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Click on the link for our EU-US and SWISS-US Data Privacy Framework Policy which supplements and adds to this Privacy Policy. 

Last Updated: 19 June 2024