Privacy Policy

This privacy policy (“Policy”) describes how Reflection Biotechnologies and its affiliated companies (“Company”) collect, use and share personal information in connection with Company’s websites and mobile applications that display this Privacy Policy (including www.ReflectionBio.com) (the “Site”). This Policy does not apply to websites or mobile applications that post a different privacy policy.

You must be at least 18 years old to use this Site.

WHAT WE COLLECT
In connection with the Site, we collect information about you in a range of ways: 

Information You Give Us. You may voluntarily submit to us a variety of information, including your‎ personal and business contact information (such as first and last name, email address, and phone number), government issued identifier, financial information, medical or health information that you choose to provide to us (such as information about your medical conditions or treatments), age, gender, marital status, biometric information, commercial information (such as transaction information and purchase history), electronic information (such as audio, video or similar information), and information provided in connection with a job application (such as work experience, education, salary, languages spoken, and other details an applicant may choose to provide). Healthcare professionals may also provide information about their work and research (such as specialty, state of practice, and professional affiliations). Additionally, you may choose to select an option to describe the type of user you are, such as a healthcare practitioner, employee of an advocacy organization, or caregiver.

Information We Collect From Others. We may collect information about you from other sources. For example, we may collect information on healthcare professionals from organizers of professional conferences. We may add this to information we collect via this Site. We may also collect information from marketing partners, public databases, providers of demographic data, publications, professional organizations, social media platforms, people with whom you are connected on social media platforms, caregivers, companies and other third parties that help us screen and onboard individuals for hiring purposes, and other third parties. 

Information Automatically Collected. We, our service providers, and business partners may collect information about the use of our Site by automated means, including via cookies, web beacons, and other technologies. For example, when visiting our Site, we may collect information about your IP address, geolocation data, device operating system type, browser type, browser language, the website that referred you to our Site (if any), and information about how you use the Site, such as pages you viewed or aspects of our mobile application that you use, how you navigate between pages on our website or screens in our mobile app, how long you spent on a page or within any portion of our mobile application, access times and actions you take on our Site.

A “cookie” is a small data file stored on your device by a website that may uniquely identify your browser or be used to store information or settings in your browser. We may use both session cookies (which expire once you fully close your web browser) and persistent cookies (which stay on your device until you delete them or they expire) to provide you with a more personal and interactive experience on our Site. A “web beacon,” also known as an Internet tag, pixel tag, or clear GIF, is used to transmit information back to a web server. We, our service providers, and business partners may collect information about your online activities over time and across third-party websites and mobile apps when you use our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.

USE OF PERSONAL INFORMATION
We may use your personal information as follows:

• To operate, manage, and maintain our business.
• To provide our products and services.
• To respond to comments and questions and provide customer service.
• To send information including confirmations, technical notices, updates, security alerts, and support and administrative messages.
• To communicate about upcoming events and other news about products and services offered by us and our selected partners.
• To tailor the content we display to you in our communications, and in connection with your use of the Site.
• Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read).
• Process employment applications, as described in the “Careers” section below.
• To be shared with technical support providers only to the extent such information is necessary for trouble shooting.
• To identify, investigate, and respond claims and other liabilities, including by enforcing the terms and conditions that govern the use of the Site.
• To otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, for example, in addition to the above, developing, improving, repairing, and maintaining our products and services; 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; maintaining records; and exercising and defending legal claims.

We may also aggregate and/or de-identify any information that we collect in connection with the Site, such that the information no longer identifies any specific individual. We may use, disclose, and otherwise process such information for our own legitimate business purposes, including historical and statistical analysis and business planning – without restriction.

SHARING OF PERSONAL INFORMATION
We may share personal information as follows:

• We may share personal information with your consent. For example, you may request that we share your personal information with third parties for their own marketing uses. Those uses will be subject to the third parties’ privacy practices.
• We may share personal information with our affiliates and subsidiaries, for the purposes described in this Policy.
• We may transfer the personal information we maintain in the event we sell or transfer all of or a part of our business or assets, such as via a merger, financing, acquisition, or bankruptcy transaction or proceeding. If we engage in such a sale or transfer, we will, where required by law, make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Policy.
• We may share personal information for legal, protection, and safety purposes.
  • We may share information to comply with legal requirements.
  • We may share information to respond to lawful requests and legal processes.
  • We may share information to protect the rights and property of Reflection Biotechnologies, our agents, customers, and others. This includes identifying, investigating, and responding to fraud, illegal activity (such as incidents of hacking or misuse of the Site), and claims and other liabilities, such as by enforcing our agreements, policies, and terms of use.
  • We may share personal information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

We may share personal information with our service providers that perform services on our behalf. We do not authorize our service providers to use or share your personal information for their own purposes.

We may also share aggregated and/or anonymized data with others for their own uses.

We may store personal information on the server or other storage devices/services provided by third-party service providers.

CAREERS
If you submit your information in connection with job opportunities at Reflection Biotechnologies via the Site, we will use and disclose the information to process your application (including to contact you and/or your references and former employers, if appropriate), to monitor recruitment statistics, and to comply with government reporting requirements. We also retain statistical information about applicants to help inform our recruitment activities.

INTERNATIONAL DATA TRANSFERS
Use of the internet may result in international data transfers. Further, we may transfer your personal information to countries/regions other than the country/regions in which the data is originally collected for the purposes described in this Policy. The countries/regions to which we transfer personal information may not have the same data protection laws as the country/regions in which you initially provided the personal information.

HOW WE PROTECT PERSONAL INFORMATION
We and our service providers maintains administrative and technical safeguards designed to protect the personal information we maintain against unlawful or unauthorized access, disclosure, or use. However, we cannot guarantee that these measures will ensure the security of the personal information. There is a risk that personal information may be stolen, hacked, altered or lost during transmission to or while stored at Reflection Biotechnologies or our third-party service providers.

LINKS TO WEBSITES, MOBILE APPLICATIONS, AND THIRD-PARTY CONTENT
For your convenience and information, we may provide links to websites, mobile applications, and other third-party content that is not owned or operated by Reflection Biotechnologies. The websites, mobile applications, and third-party content to which we link may have separate privacy notices or policies. Reflection Biotechnologies is not responsible for the privacy practices of any entity that it does not own or control.

COOKIES
What is a Cookie?
Cookies are small text files that are sent to your computer when you visit a website. Cookies on the Site may do lots of different jobs, like letting you navigate between pages efficiently, storing your preferences and generally improving your experience of a website.

How to control cookies
If you don’t want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; the Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. However, if you do not accept our cookies, you may not be able to use all functionalities of your browser software or our website.

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy. If we make any changes, we will change the Last Updated date above and notify you of changes that are deemed material under applicable legal requirements by providing notification as required by applicable law.