Privacy Policy

Last updated: September 1, 2020

Thank you for your interest in subsidiary Seed Therapeutics, Inc., (collectively, the “Company,” “we,” or “us”). Your privacy is important to us, and this Privacy Policy describes how we process personal information as part of our business operations, including the types of personal information that we collect, the purposes for which we use it, the types of third parties to whom we share it, and the rights and responsibilities you may have with respect to such personal information. This Privacy Policy applies to the personal information provided to us through any type of engagement or interaction with the Company, such as when contact us by telephone or email, use our online services, or visit any of our websites (collectively, the “Site”), including the following: https://www.seedtherapeutics.com/.
By accessing or using the Site or otherwise providing us with personal information, you are agreeing to the terms and conditions set forth in this Privacy Policy.

1. Whose Personal Information Do We Collect
The Company collects personal information from a range of individuals in the context of our business activities, including from the following: customers; individuals that use, or otherwise access, our Site, individuals who visit our premises or facilities; representatives of our suppliers, customers and other business contacts; contractors and similar types of workers, individuals related to, or otherwise affiliated with, our Company’s employees; and, individuals who contact us by any means.

2. The Types and Categories of Personal Information We Collect
The type of personal information that the Company collects depends on our relationship with the particular individual. Generally, we collect the following types and categories of personal information:

Identity data, such as name, physical or shipping address, e-mail address, telephone and fax numbers, professional title, and your company or organization’s name.
Registration data, such as information provided by you when you register for an account to use our Site, including user names and passwords.
Business contact data, such as information related to employees, owners, directors, officers, or contractors of a third-party organization (e.g., business, partnership, sole proprietorship, nonprofit, or government agency) with whom the Company may conduct, or possibly conduct, business activities.
Recruitment data, including information derived from employment applications or submitted in connection with a job posting or inquiry.
Marketing and communications data, including your marketing preferences and your subscriptions to our publications or marketing materials.
Transaction data, including orders for our products and services and details of payments to and from you, including purchase history and preferences and (limited) payment card information.
Your feedback and comments, including comments or any statements you provide to us through the Site.
Usage data, such as data we automatically collect from individuals who visit or access our Site, including a user’s Internet Protocol (“IP”) address, browser and computer type, access time, the webpage from which you came, and the specific webpage(s) that you access during your visit to our Site. For more information pertaining to our use of cookies, see below.

When you do not provide personal information that the Company requests, we may not be able to provide you the requested service or complete a transaction, and you agree that the Company will not be liable or otherwise responsible for any damages or loss arising from such circumstances.

3. How We Collect Personal Information
Most often, the Company obtains personal information directly from the individual. For example, when an individual undertakes the following activities, we generally collect their personal information:

Use or access our Site and/or complete one of our web forms.
Contact our customer service centers or request information from us in any other way.
Visit one of our locations or premises.
Apply to a job posting or otherwise submit an employment application.
Provide us personal or business contact information via a business card or through similar communications.
Complete a survey or otherwise provide us feedback.
Communicate with us via social networking websites, third-party applications, or similar technologies.
Visit one of our trade counters at an exhibition.
Submit an order to, or engage with, the Company related to its products and services.

In accordance with applicable law, we may collect personal information about you from third parties, such as social media websites/applications, former employers, background check providers, and others, which we may combine with the information we already hold about you in order to promote our legal or business interests, such as to help us improve and customize our Site. We may also collect your business contact information from your employer or other third parties, which we will use to facilitate or otherwise engage in traditional business activities and similar administrative matters. We may also ask you to provide personal information about third parties to use as references, answer questions about your employment, or for other reasons. If you provide personal information about a third-party you expressly represent and warrant to the Company that you have the full right and lawful authority to provide the Company with the information.

4. How We Use Your Information
The Company may use personal information for several business and administrative purposes, or to further our legal or other business interests. Generally, we use personal information for the following reasons:

Services and transactions. We may use your personal information to deliver services to you or carry out transactions that you have requested, including by providing you information on the Company’s products or services, answering customer service requests, and facilitating the use of our Site. We also use personal information to satisfy our orders, such as to send information to customers about the status of orders they placed with us, to process and collect payments, and to share phone numbers, shipping address, and item descriptions (including but not limited to, model number and brand) with delivery partners to facilitate prompt and efficient delivery. We also use personal information to facilitate order confirmations, invoices, technical notices, updates and security alerts, and support and administrative messages.
Improving our business. We may use your personal information to perform business analyses or for other purposes that help us to develop and improve the quality of our business, Site, and products and services. We may use your personal information to conduct research and analysis to help us better understand your purchasing preferences, identify the products and services that best meet your requirements, and measure the effectiveness of our advertising and marketing. Where permitted by law, we may combine the information that we collect via our Site with other information we hold about you (such as information about your use of our products and services) in order to offer you an improved and consistent customer experience or for other purposes set forth in this Privacy Policy.
Marketing. In accordance with applicable laws and regulations, we may use your personal information to inform you of our products or services which may be of interest to you, and to otherwise communicate with you about offerings, events, news, surveys, special offers, and related topics. You are able to opt-out from marketing communications sent via e-mail at any time, free of charge, by using the “unsubscribe” link in any e-mail marketing materials you receive from us.
Recruitment data. In connection with a job application or inquiry, you may provide us with information about yourself, such as a resume/curriculum vitae, professional references, information about education and employment experience, and information about professional training and certifications. The Company may use this information for the purpose of employment consideration, background checks and employment eligibility, and as otherwise set forth in any separate privacy statement or other notice made available to in connection with your application. We may use a third-party (e.g., job recruiter) or social media platform to solicit, collect, and retain employment applications and inquiries.
Enforcement and business interests. We may use the personal information we collect in order to detect, prevent and respond to fraud, intellectual property infringement, violations of our terms and conditions, violations of law or other misuse of our Site, products, or facilities. We may use personal information to administer and protect our business and our Site, including system maintenance, support, reporting and hosting of data. We may use personal information to protect the health and safety of our employees, contractors, customers, and others in our community. We may use personal information to promote, defend or protect our legal, regulatory, or business interests, including enforcing contracts and other agreements.

5. Sharing Information and Third-Party Disclosures
We may share your personal information with selected third parties in accordance with applicable law, including as set forth below.

Service providers. We may share your personal information with other companies with whom we have contracted to provide services on our behalf, such as hosting our Sites, conducting surveys, processing transactions, facilitating our marketing activities, performing analyses to improve the quality and security of our business, Site, products and services. We may also disclose your personal information to our designated agents, or third-party service providers, who require such information to assist us with administering our employment application and recruitment process, including, but not limited to, obtaining employment verification and background checks.
Delivery services, marketing and business partners. We may share your personal information with third parties to deliver our products and other items and to engage in similar routine business functions. We also use third parties to disseminate our email and marketing, assist with our research, evaluation, and surveys, and manage aspects of our Rewards programs.
Business restructuring. Circumstances may arise where the Company decides to sell, buy, divest, merge or otherwise reorganize our business. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition, bankruptcy, divestiture, or sale of all or a portion of the Company’s assets.
Disclosure for other reasons. We may disclose personal information (i) if required by law, regulation or government order, or with a legal process, (ii) to protect and defend our rights or property, or (iii) in urgent circumstances, to protect the health and personal safety of any individual. In addition the Company may share your personal information with any third-party when we believe such disclosure is necessary to defend or protect our legal, regulatory, and business interests. We may also disclose your information upon your express consent.

In the event that you facilitate a transaction with the Company, or request information from, or otherwise engage with us, and such activities require the Company (in our sole judgment) to share your personal information with a service provider or other third-party, you hereby direct the Company to intentionally disclose your personal information to the service provider or third-party as described herein provided the service provider or third-party does not, in its reasonable judgment, sell the personal information.

6. Links to Other Websites
The Company may include on our Site certain links to other websites, including websites operated by unaffiliated third parties. Each such third-party website has its own privacy policies and practices, which may be different than the policies and practices described herein; we urge you to read any privacy policy posted on a third-party website carefully. Additionally, to the extent that you follow a link to a website operated by an independent third-party, please be aware that the Company exercises no authority or control over that third-party and we cannot be, and are not, responsible for any information that you may submit at that website or how it is used.

7. Data Retention and Localization
The period during which the Company’s retains your personal information varies depending on the purpose for the data processing. For example, we retain personal information needed to provide you with products and services, to facilitate transactions you have requested, or to engage in marketing activities, in accordance with applicable law and for so long as necessary to defend our legal or business interests. In all other cases, we retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy.

The Company is based in, and has regional offices across, the United States. The information that the Company collects and processes is retained and stored in the United States, and the Company does not participate in the U.S. Privacy Shield Frameworks. In some circumstances, the Company uses third-party service providers that retain information and data on behalf of the Company in the United States and in other third countries. Please be aware that information you provide to the Company may be transferred to the United States or a third country, and that the United States and other third countries may not provide the same level of data protection as the laws in your country. By continuing to provide us such information you hereby consent to your personal information being transferred to, and stored in, the United States or any other third country outside your country of residence.

8. Security
We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, no information system can be fully secure, so we cannot guarantee the absolute security of your personal information. Moreover, we are not responsible for the security of information you transmit to the Site over networks that we do not control, including the Internet and wireless networks, and you provide us with any information and data at your own risk. To the extent permitted by law, the Company shall not be liable or otherwise responsible for any data incidents that may compromise the confidentiality, integrity, or security of your personal information. The safety and security of your personal information also depends on you. Where we have given you (or where you have chosen) a user name and password to access the Site, you are responsible for maintaining the security and confidentiality of those log-on credentials and not revealing them to others. You must contact us immediately if you have to reason to believe that your user names or password to our Site have been compromised.

9. No Data Collected from Children
Our Site is not directed at, nor intended for use by, children. As a result, we will not knowingly collect information from children under eighteen years of age with or without consent from their parents or guardians. If you are under the age of eighteen you are hereby prohibited from using our Site or with providing us with your personal information, unless you can demonstrate affirmative authorization from your parent or legal guardian to do so and thereafter we grant you written consent.

10. Cookies, Analytics, and Ads
When you visit this Site, we use cookies and similar technologies to collect information and enhance your experience online through web browsers and applications. This Site may only function properly if cookies are enabled. The Company uses cookies to authenticate that you have visited the Site before and display content that is relevant and specific to you. Cookies are very small files that store information about your visit to and use of this Site. Cookies allow us to provide information that is more meaningful to you without asking you the same questions every time you visit us. Accepting nonessential cookies through your web browser is your personal choice. You can set your browser to disable such cookies. However, if you choose not to accept cookies, we may not be able to provide you with as good of an experience as one that is specifically tailored to your needs by utilizing the cookie and you may not be able to utilize some features of the Site. We may also use our own cookies to provide you with personalized online display advertising tailored to your interests. In particular, the Sites use tools and programs from the following sources:

Google Analytics. We employ Google Analytics, which uses cookies to enable an analysis of your use of the Sites. The information collected through this tool (e.g., IP address, browsing activities, referring site details, type of web browser and operating system, clicks on external links, interaction with site specific widgets) is usually transferred to, and stored in, a Google server in the United States. To see how you can opt-out of certain Google features and to better understand Google privacy practices, visit: Google Analytics Opt Out Link.

You can find more information about cookies and behavioral advertising at https://www.allaboutcookies.org/.

11. Your Rights and Responsibilities
You are permitted, and hereby agree, to only provide personal information to the Company if such personal information is accurate, reliable, and relevant to our relationship and only to the extent such disclosure will not violate any applicable data protection law, statute, or regulation or infringe upon any individual’s data privacy rights or privileges. If you provide the Company with any personal information about a third-party, you expressly represent that you have the full right and authority to submit the personal information to the Company and are in compliance with the requirements set forth in this Privacy Policy. You also agree to fully reimburse the Company for any damages, losses, or expenses that arise based on your violation of your warranties and responsibilities set forth in this Privacy Policy.

Depending on the jurisdiction in which you reside or the Company operates, you may have certain data protection rights. To exercise any of these data privacy rights, please contact us, or have your authorized agent contact us, in accordance with the “Contact Us” section listed below. We will respond to any data requests within the timeframes required by law, and we may charge a fee to facilitate your request, where permitted by law. The rights afforded under data protection laws are not absolute, and the Company may be permitted to refrain from undertaking any action or changing its data processing activities, in response to a data request you submit to us.

You may always contact us to remove or update personally identifiable information from our database by sending an e-mail to privacy@seedtherapeutics.com. If you have any questions or comments about the way your personally identifiable information is collected via our Site is used and handled, please e-mail us at privacy@seedtherapeutics.com.

Email marketing. You have the right to opt-out of receiving electronic direct marketing communications from us. All electronic direct marketing communications that you may receive from us, such as e-mail messages, will give you an “unsubscribe” option of not receiving such communications from us in the future.
Text message/SMS marketing. If you agree to receive text messages from the Company or our service providers to receive marketing and similar alerts, your hereby consent to the sending and receipt of such text messages to the mobile number provided using an automatic telephone dialing system. In providing this consent, you understand that (i) you are not required to grant consent as a condition of making purchases or receiving services from us, (ii) you may revoke your consent at any time by replying to any the text alert or message with the word “STOP” or by contacting us in accordance with the “Contact Us” section listed below, and (iii) standard message and/or data rates apply to such alerts and messages. You further agree to immediately contact the Company (in accordance with the “Contact Us” section listed below) in the event the mobile number you provided us to receive text messages is no longer active or under an account in which you have the authority to consent to receiving such text messages and will indemnify and hold harmless the Company for any losses or damages due to breaches of any of the foregoing.
California privacy rights. California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties with whom we have reason to believe use such information for their own direct marketing purposes.
Do not track. Some web browsers may transmit “Do Not Track” signals to the website with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Persons with disabilities. The Company strives to ensure that every person has access to information related to our products and services, including this Privacy Policy. Please contact us if you would like this Privacy Policy provided in an alternative format and we will seek to meet your needs.
We do not sell data. The Company does not sell, lease, or rent personal information on any individual, including minors, to a third-party for profit or other valuable consideration.

12. Changes to the Policy
We reserve the right to change or update this Privacy Policy at any time and please see the Effective and Amendment date to determine whether there have been changes made to this Privacy Policy since the last time you visited our Site or engaged with the Company.

13. Contact Us
If you have questions regarding this Privacy Policy or our handling of your personal information, would like to request more information from us, or would like to exercise a data privacy right, please contact us at:

Email: privacy@seedtherapeutics.com (Please write “Privacy Request” in the subject line).

14. Effective and Amendment Date
This Privacy Policy was last amended September 1, 2020.