Privacy Policy

This policy describes how Venn Biosciences Corporation dba InterVenn BioSciences, together with its wholly owned subsidiaries (together, “InterVenn”) collects and processes personal information in relation to all websites. InterVenn is committed to protecting and respecting your privacy and ensuring that your personal information is processed fairly and lawfully with relevant privacy legislation. This Privacy Policy sets forth the principles governing our use of personal information that we may obtain about you through one or more of our websites at which this Privacy Policy is posted (our “Sites”) and in connection with our business (the “Business”).

For your convenience, our Sites may contain links to a number of other websites. The privacy policies and procedures described here do not apply to those sites; we suggest contacting those sites directly for information on their data collection and distribution policies. Any reference to a linked site or any specific third-party product or service by name does not constitute or imply its endorsement by us, and you assume all risk with respect to its use.

Please note that our collection or use of your personal information may be governed by a separate privacy notice. Our uses and disclosures of protected health information governed by the Health Information Insurance Portability and Accountability Act. If you receive a different notice at the time we collect your personal information, that privacy notice will govern how we use that personal information.

PERSONAL INFORMATION THAT WE COLLECT

We may collect, use, store and transfer the following information to provide, improve and protect our Sites and in connection with our Business.

The data we collect and process. We may collect personal information when you visit or interact with our Sites, fill in forms on our Sites, interact with our Business, correspond with us by phone, e-mail, or otherwise, or when you enquire about or apply for employment opportunities at InterVenn or its subsidiary. This personal information generally refers to information that relates to an identified or identifiable individual or household, such as a name, contact details, or address, and includes the following information which are referred to in this Privacy Policy as “personal information” generally, or “personal data”:

• Information You Provide Us. When you interact with our Sites, for example when you complete one of our online forms such as a job application form, you may provide us with information that we collect, including:
• Contact Information such as your name, title, company, mailing address, email address, phone number, password, resume information, professional credentials, institutional affiliations, feedback and any other information you choose to provide to us;
• Biographical and demographic information such as date of birth, age, gender, marital status, and information regarding any parents or legal guardians;
• Testimonials such as any information you provide related to your experiences with our products and services;
• Marketing and communication data, which tells us your preference in receiving marketing from us and our third parties and your communication preferences;
• Sensitive personal information such as your race or ethnicity, physical or mental health condition, sexual orientation, or criminal offenses.; and
• Payment-related information such as credit card and financial account information.
• Information that we collect automatically when you visit our Sites. When you visit our Sites, we automatically collect the following information:
• Technical data such as your internet protocol (“IP”) address, your login data, the web page you visited before visiting our Sites, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Sites; and
• Usage data which tells us how you use our Sites.

Purposes for which we will use your data

We will only use your personal information when the law allows us to use the information. Most commonly, we will use your personal information in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• To process your registration on our Sites; and
• To send you information about changes to our Terms of Service and other policies.
• To communicate with you and respond to your service-related requests, questions and feedback.
• To facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
• Where we need to comply with a legal or regulatory obligation.
• Where you have given your consent. Where it is necessary for our legitimate interests (or those of a third party) and, where consistent with applicable laws.
• Providing you with access to content and features on our Sites and developing our Business and our Sites;
• Monitoring the use of our Sites and using personal information to help us evaluate, improve and protect our Sites and our products, both online and offline;
• Ensuring the security of our Sites, by preventing unauthorized or malicious activities;
• Investigating any complaints received from you or from others about our Sites or our Business;
• Enforcing compliance with our Terms of Service and other policies and to help other organizations (such as copyright owners) enforce their rights;
• Protecting our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); and
• Investigating and deterring against fraudulent, harmful, unauthorized, unethical or illegal activity.

The ways we plan to use your personal information are as follows

• Business. We collect data in connection with developing our Business and our Sites.
• Usage. We also use your data, especially usage data and technical data, including the actions you take in your account (such as visits to our Sites, page interaction information, and search history), to evaluate and improve our Sites and our products.
• Cookies and other technologies. We use technologies like cookies to provide, improve, protect, and promote our Sites and our products.
• Marketing. We also use your data to provide you with information about our Business we feel may interest you. If you do not want us to use your data in this way, select the ‘unsubscribe’ link in any email communication from us.
• Relationship. We will also use your data to manage our relationship with you.

Sharing your data

We may share information as discussed below, but we will not sell it to advertisers or third parties.

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Others working for InterVenn. InterVenn uses trusted third parties (e.g., IT services, analytics services, etc.) to help us provide, improve, protect, promote our Sites and our Business, and to perform business operations, such as determining eligibility for our products.

Other applications and third-party links. The Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Sites, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.

The public. We may make available functionality that enables you to disclose information to the public; for example, when you submit or permit us to post testimonials on our Sites and/or social media channels. We do not control how other individuals or third parties use any personal information that you make available to the public.

Advertising partners. We may share personal information with third party advertising companies that collect information about your activity on our Sites and other online services for advertising purposes.

For compliance, fraud prevention and safety. We may share personal information for the compliance, fraud prevention and safety purposes described above and to comply with legal requirements and processes.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Protecting your data

We implement measures and procedures that protect the privacy of individuals and help ensure that data protection is integral to all processing activities, such as pseudonymization, anonymization, information security controls, and a data retention protocol. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

Where we store and transfer your data

The Sites may be controlled by InterVenn from any of its office locations. InterVenn may store and use information in the United States, the UK and other jurisdictions; any personal information provided to InterVenn will be transmitted to or within those jurisdictions. InterVenn also may transfer information and personal information to other jurisdictions to facilitate InterVenn’s third party processors’ access to and/or processing of information and/or personal information. Such jurisdictions may have privacy laws not as protective as those in your jurisdiction.

InterVenn makes no representation that materials on our Sites are appropriate or available for use in other locations, and access to them from territories where their contents are illegal is prohibited. Those who choose to access our Sites from other locations do so on their own initiative and are responsible for compliance with applicable local laws.

Your choices

If you have questions or concerns regarding the way in which your personal information has been used, please contact us at privacy@venn.bio.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority of your country of residence.

Use of cookies and other technologies

Our Sites use “cookies” to gather general information about the browsing activities of visitors to our Sites. This allows us to constantly improve our Sites’ design by arranging the content in the most user-friendly manner and to continually meet the users’ needs. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. (Nevertheless, we cannot guarantee that cookies will not be accessed by other persons.)

We use Google Analytics, which collects information about usage of our Sites and allows us to receive information about general usage statistics.

In order for Google Analytics to function, when you use our Sites, Google will place cookies on your device. Google Analytics may also collect information through other methods in addition to cookies. Information collected by Google Analytics when you use our Sites, and the way it is used, is described in the applicable Google Privacy Policy and Google Terms of Service

We use a marketing automation system to place cookies on your device to collect information to improve the overall user experience between marketing emails and our Sites. We practice permission-based email marketing where you have the option to opt-out of any future marketing communications.

California Privacy Rights

In addition to the rights already described, California law permits California residents to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing.

We do not share or sell your personal information about you collected by us for direct marketing purposes.

Contact

Have questions or concerns about our Privacy Policy?

Contact us at:
Venn Biosciences Corporation dba InterVenn BioSciences (“InterVenn”)
Attention: Legal Department
2 Tower Place
South San Francisco, CA 94080
By email: privacy@venn.bio

CHANGES TO THIS POLICY

If we update this Policy, we will notify you by posting a new privacy policy on this page. If we make any changes that materially change the ways we process or protect your information, we will provide additional notification of the changes.

INTERNATIONAL DATA PROCESSING & TRANSFER

We process information collected from or about you in any country in which InterVenn BioSciences operates, as permitted by applicable law. In some cases, your information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for information under applicable laws (such as those in the European Union). When we conduct such transfers, we put in place appropriate safeguards (such as standard contractual clauses) in accordance with applicable legal requirements. Information located outside of your home country may be subject to access by that country’s government or its agencies under a lawful order. For more information on the appropriate safeguards in place or to obtain a copy of the standard contractual clauses, please contact us at by post at 2 Tower Place, South San Francisco, CA 94080 (Attn: Legal Department), by email at privacy@venn.bio.

Effective Date: April 4, 2022