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This Privacy Notice was last updated on March 6, 2023.
This Privacy Notice applies to all UBC online, digital services activities, and the Personal Information (defined below) that United BioSource, LLC (“UBC”, “we”, “us” or “our”) obtains from individuals (“you” or “your”) through our website, www.ubc.com (the “Site”), mobile apps (applications), and digital services activities (collectively, “Services”).
UBC is committed to protecting the privacy, integrity, and security of those who provide us with their Personal Information. Please read this Privacy Notice to understand the information we collect, how we collect it, how we use it, who we may disclose it to, and how you can manage your Personal Information.
We are committed to protecting the confidentiality of your Personal Information. When providing you with Services, information you request, or so that we can facilitate commercial engagements with our clients, we may need to collect your Personal Information. If you do not provide Personal Information, we may not be able to provide Services or enter commercial engagements with you or our clients.
We only collect Personal Information about you that is necessary to support our Services, for our legitimate business purposes, or is required by law.
The term “Personal Information” refers to many types of information that can identify, relate to, or describe a person, and can therefore link the information directly to a person or household. Personal Information may include “protected health information” (“PHI”) as defined under the Health Insurance Portability and Accountability Act of 1996, (“HIPAA”), “Personal Data,” as defined under the European Union (“EU”) General Data Protection Regulation 2016/679 (“GDPR”) and the UK Data Protection Act 2018, and “Personal Information,” as defined under the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et. seq., as amended (“CCPA”) (collectively “Data Protection Laws”).
When you visit our Site, or in performance of our Services, we may collect the following types of Personal Information:
*Usage Data” is information about an individual’s activity (on or through the Services) that, by itself, does not identify the individual, such as browser type, operating system, and webpages visited. Usage Data is not considered Personal Information, unless it can (with other information) identify an individual, as outlined under certain Data Protection Laws. In those limited scenarios, Usage Data may be considered Personal Information.
Information You Voluntarily Provide When Using or Receiving Services:
Legal Basis: We use Personal Information only for the purpose of fulfilling your request, and as consented to when you provided the relevant information.
Legal Basis: We use Personal Information only for providing the services you’ve requested or to fulfill your request, as consented to when you signed up for the correspondence.
Legal Basis: We use Personal Information related to Providers only for the purpose of performing the Services as agreed to under a contract, or for any legitimate interest in fulfilling the services or legal requirement.
Legal Basis: This Personal Information is used only to perform the Services that UBC was contracted for, any as otherwise consented to within the project specific informed consent.
Wherever we rely on consent, you will be able to withdraw that consent, although we may have other legal grounds for using your Personal Information for other purposes, such as compliance relevant Data Protection Laws. You have the right to opt-out of our direct marketing at any time. You can do this by; (i) following the instructions in the communication where this is an electronic message; or (ii) contacting us using the methods noted below at “Exercising Your Rights.”
To Perform Services: We will share your Personal Information with other UBC group companies (such as UBC Late Stage (UK) Limited – for more details about UBC group companies visit: http://www.ubc.com/contact/locations), as necessary to provide the Services you have requested or to fulfill any of the other purposes set out above.
With Third-Party Service Providers: We may also share your Personal Information with our third-party service providers, who may perform functions for UBC, such as processing and analyzing data, designing and maintaining systems, customer service, marketing (i.e. Hubspot and Salesforce) and promotions, and any other relevant Services.
These third parties include, but are not limited to: UBC customers, research consultants, Information Technology service providers (including customer relationship management suppliers), payment providers, expense management suppliers, credit and background check companies, banks, and email providers.
For Legal Reasons or Requirements: In certain circumstances, we may be legally obligated to share your Personal Information with government authorities or law enforcement officials for the purposes (i.e., Services) above, if mandated by law (for example, in response to a court order, subpoena, search warrant, law, or regulation) or if required for the legal protection of our legitimate interests in compliance with relevant laws.
For Necessary Data Transfers: If you are in the European Economic Area (“EEA”), we may transfer your Personal Information outside the EEA to countries that do not offer the same level of protection as required by the EEA (e.g., to a UBC group company or other third-party service provider (as outlined above) in the U.S.).
To protect your Personal Information, we will only perform data transfers based on: (i) an adequacy decision by the European Union Commission (“EU Commission”); (ii) subject to the EU Commission approved standard contractual clauses; or (iii) any other legally, allowable data transfer method.
If you would like to receive additional information about the relevant transfer method used or receive a copy, you may send a request to: email@example.com.
Data Retention (how long we keep Personal Information): Except where restricted by law and subject to this Privacy Notice, we will retain and use your Personal Information for as long as it is needed to perform or provide you with the Services.
We will also keep your Personal Information, and access to our Site and Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our Service contracts.
When we use Personal Information for marketing purposes, as provided with your consent (where required) we use this information until you make us aware by unsubscribing to future contact. We also keep a record of the fact that you have asked us not to send you direct marketing or to use your Personal Information so that we can respect your request in the future.
When we use Personal Information to meet relevant legal requirements, we hold this information for as long as the law requires (for example, we may hold records to help prevent fraud and other restricted or illegal activities).
Data Storage: UBC uses data collection, storage, data minimization practices, and security measures to protect your Personal Information against unauthorized access, alteration, disclosure, or destruction.
Where it is appropriate, UBC uses firewalls and limits who can access databases that store Personal Information.
Please keep in mind that it is not possible to achieve a perfect state of data security. Although we use reasonable security measures to protect your Personal Information from unauthorized access, we can’t absolutely guarantee the security of your Personal Information or that your Personal Information will not be accessed, disclosed, altered, or destroyed. Where relevant, we will notify you of any disclosure of a breach of your unencrypted, electronically stored Personal Information, as required by relevant Data Protection Laws. If the country in which you reside allows us to notify you of a breach, either by email or a clear posting on our Site, you agree to accept the notice in that format.
We do not knowingly collect Personal Information from children under the age of thirteen (13) in through our Site.
If you believe UBC may have any information from (or about) a child under the age of thirteen (13), please contact our Data Privacy office at: firstname.lastname@example.org.
UBC offers you choices concerning the Personal Information you share with us. We will provide you with the following options related to disclosing your Personal Information:
You will be asked to choose to opt-in to provide requested Personal Information for a particular use. If you choose to not opt-in, you may not be able to use our Site (as intended) or receive relevant Services.
Correct or Update your Personal Information: You can correct or update your Personal Information that you provide us. You can do this by completing this https://forms.office.com/r/mcZjAun0Rh, or by submitting a request to email@example.com, or calling UBC’s toll-free phone number at: +1-866-244-9625. Requests can also come from social media (e.g., Twitter or Facebook), from a complaint email, or as one of a few issues raised in a single communication. UBC will treat these requests as if they were submitted properly or provide you with additional instructions.
Receive Marketing Information: When you agree to use our Site or receive Services, you may ask to receive emails containing information about UBC that we think may be useful to you, such as newsletters about certain health topics, announcements about new services or products, and promotions. You may at any point unsubscribe from our email list by clicking the unsubscribe button in the email or send an opt-out request to firstname.lastname@example.org.
Based on the European General Data Protection Regulation (“GDPR”), and where allowed by law in other countries (e.g., Switzerland, China, Brazil, etc.), you have the right to:
Ask for a copy of your Personal Information collected by us (UBC).
Correct, Delete, or Restrict (stop any active) use of your Personal Information.
Obtain the Personal Information you provide us (UBC) for a contract or with your consent in a structured, machine-readable format.
Additionally, you may also object to the use of your Personal Information in some circumstances, including the data we are using for direct marketing.
If you are an EEA resident, or a resident of a country that allows the rights mentioned here and would like to submit a request, please send your request through any of the methods noted above at “Exercising Your Rights.”
Limitations To These Rights: These rights may be limited if fulfilling your request would reveal Personal Information about another person, or if you ask us to delete information which we are required by law to keep.
If you are in the EEA, or another country that allows the rights mentioned here and you have unresolved concerns, or at any time you do not believe that we have complied with this Privacy Notice, you have the right to file a complaint with your local data protection authority.
If you are a California resident, you may be entitled to additional rights as defined under the California Consumer Privacy Act of 2018 (the “CCPA”) and the California Privacy Rights Act (“CPRA”) (effective January 1, 2023).
In addition to the rights identified in the other sections of this Privacy Notice, you have the right, subject to certain exceptions under the CCPA, and other relevant laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information.
This includes the following:
The Right to Know: You have the right to know how your Personal Information is used, disclosed, or managed, including:
|The categories of Personal Information we collect about you||Categories of Personal Information UBC collects are available here: Personal Information We Collect / Categories of Personal Information We Collect.|
|The categories or sources for the Personal Information we collect about you||Sources of Personal Information UBC collects is available here: How We Collect and Use Your Personal Information.|
|UBC’s business or commercial purpose(s) for collecting your Personal Information||We may use or disclose Personal Information we collect for “business purposes” or “commercial purposes,” as mentioned here: How We Collect and Use Your Personal Information.|
|The categories of third parties with whom we share your Personal Information||Personal Information may be shared with third parties, as defined under the “With Third-Party Service Providers” section, located here: How Personal Information is Shared or Disclosed.|
|The categories of Personal Information that each recipient received||The categories of Personal Information shared with certain third parties are located here: How Personal Information is Shared or Disclosed.|
|The specific pieces of Personal Information we collect about you||The specific Personal Information collected about you are listed here: Personal Information We Collect / Categories of Personal Information We Collect. Additionally, you may exercise a specific request to access your Personal Information by following the steps listed here: VII. Exercising Your Rights.|
Right to Delete: California residents have the right to request that we delete your Personal Information that we collected from you and retain, subject to certain exceptions. This right can be exercised by following the steps within the VII. Exercising Your Rights.
Right to Opt-Out of Sale: California residents have the right to opt-out of the sale of their Personal Information by businesses that sell their Personal Information. The CCPA defines a “sale” as the disclosure of Personal Information for monetary or other valuable consideration. We are not currently selling your Personal Information. For any questions you have about this section, please contact email@example.com.
Exercising Your Rights: If you are a California resident and wish to request for us to provide you with your “Right to Know” or “Right to Delete,” please send your request through any of the methods noted above at “Exercising Your Rights.”
Authorized Agent: The CCPA permits California residents to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California resident’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California resident. An authorized agent must follow the process described above to make a request (i.e., under “Exercising Your Rights”). The authorized agent must also verify his or her own identity. We will confirm the agent’s authority with the relevant California resident related to the request that was made.
Information Exempt from the CCPA: Please note that certain information that is governed under the California Confidentiality of Medical Information Act (“CMIA”), HIPAA, or is subject to the Federal Policy for the Protection of Human Subjects, also known as the “Common Rule,” under good clinical practice guidelines (issued by the International Counsel for Harmonisation) or under human subject protection requirements of the United States Food and Drug Administration, is not considered Personal Information with respect to the rights of California residents noted above. However, additional rights might be available under those laws and standards. Please contact firstname.lastname@example.org for more information.
No Sharing of Personal Information for Direct Marketing Purposes: We do not share Personal Information with other people or non-affiliated businesses for their direct marketing purposes.
Non-Discrimination: UBC does not discriminate against any relevant treatment for exercising any of your rights.
Right to Notice of Financial Incentives: California residents have the right to information on how businesses may offer financial incentives, including payments to consumers as compensation, for the collection of Personal Information, the sale of Personal Information, or the deletion of Personal Information. Where relevant, any incentives to collect or share your Personal Information will be outlined in an informed consent or project-specific privacy notice or terms of service associated with the relevant Services offered.
Nevada Residents: Although UBC does not sell Personal Information, Nevada residents have the right to submit a verified request directing UBC not to sell their Personal Information. If you are a Nevada resident and would like to submit such a request, please send your request through any of the methods noted above at “Exercising Your Rights.”
We use “Cookies” and similar tracking technologies to track the activity on our Site (and relevant Services) and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Site, applications, and relevant Services.
“Cookies:” are small files that are placed on your computer, mobile devices, or any other device by a website, containing the details of your web browsing history (on that website) among its many uses. Our Site is then able to recognize repeat users and track usage patterns to better serve visitors when they return to our Site. The Cookie does not extract Personal Information, and most web browsers provide a simple procedure that enables users to control whether they want to receive Cookies or notifies them when a website is about to deposit a Cookie file. You can instruct your web browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some portions of our Site or relevant Services.
Cookies can be “persistent” or “session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while session Cookies are deleted as soon as you close your web browser. Session Cookies are used to personalize your user experience, to determine ways to improve the Site, used for Site content, and the Services we offer. These Cookies are deleted when you close your web browser session. Persistent cookies are used to collect information, such as IP addresses, browser type, Internet Service Provider (“ISP”), referring/exit pages, platform type, date/time stamp, and the number of clicks.
Adjusting Your Preferences: When you first visit our Site, you can set preferences for which Cookies you would like to enable. If you would like to modify these settings, you may do so at any time by using the icon in the bottom left.
Alternatively, most web browsers allow some control of most Cookies through the web browser settings. To find out more about Cookies, including how to see what Cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.
UBC.Com does respond to Do-Not-Track signals. To find out more about “Do-Not-Track,” please visit: http://www.allaboutdnt.com.
We use the following general Cookies categories, which shall be specified within the Cookie Notice generated by Cookiebot:
Additional Information about Necessary Cookies: Some of the Cookies and tracking technologies that we use on our Site are strictly necessary and they are there to technically enable our Site and its components, as well as to enable relevant security measures. Necessary Cookies are activated without a user’s consent because these are necessary for the Site to work properly and in a secure way. All other Cookies and tracking technologies not classified as strictly necessary are subject to your consent when visiting our Site.
Be aware that even if you accept only “necessary cookies,” you still may see third-party trackers that are enabled by our relevant Services we use in our Site. Third-party trackers are enabled because these third-party services may also have Cookies or trackers that they have classified as strictly necessary to perform the relevant services that we requested.
Another reason for seeing third-party trackers on your web browser is that you have already used or accessed a third-party service before visiting our Site. For example, if you landed on our Site using a search engine, such as “Google Search,” it is likely that Google’s search engine may have enabled trackers on your web browser (e.g., related to your preferences regarding Google’s own tracking technologies). You can read more details about how Google may use your Personal Information in this context by visiting Google’s Privacy Terms.
Additionally, Necessary Cookies by third parties, such as LinkedIn and Ceros may be stored to capture a user’s cookie consent for the current website domain.
Analytics: In addition to the above Cookies, we use certain third-party services on our Site to organize, monitor, and analyze log data. Third-party services include the following:
To opt-out of being tracked by Google Analytics across all websites, you may download the Google Analytics opt-out browser, here: http://tools.google.com/dlpage/gaoptout.
More Information: If you have additional questions about Cookies or how they work, we suggest consulting the “Help” section of your web browser or review the following website: https://www.aboutcookies.org, which offers guidance for all modern web browsers.
We use Personal Information as outlined and described in this Privacy Notice. However, from time-to-time, we may, at our discretion, modify this Privacy Notice, indicated by a new revision date at the top of the notice. It is important that you check this Privacy Notice when you visit our Site. Your use of our Site, and your continued use of our Site after this Privacy Notice has been updated, indicates your agreement and acceptance of this Privacy Notice, including the modifications made as of the date of your use.
If you have a question about this Privacy Notice, UBC’s data protection practices/procedures, Personal Information use, or would like to access this Privacy Notice in an alternative format, you can contact our Data Privacy office at: email@example.com.