Privacy Policy for California Residents
Effective: May 12, 2023
This Privacy Policy for California Residents (“CCPA Privacy Policy”) applies to Flagship Biosciences, Inc. and its affiliates (collectively, (“Flagship,” “we,” “us,” or “our”) processing of personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”). For example, this privacy policy does not apply to personal information collected pursuant to (i) the federal Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act; or (ii) certain medical and health information covered by HIPAA.
Personal Information We Collect, Use, Disclose, Share, or Sell
Categories of Personal Information We Collect, Categories of Sources of Personal Information, Business or Commercial Purposes for Which Personal Information Will Be Used, and Third Parties with Whom Personal Information is Sold, Shared, or Disclosed.
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The chart below includes information collected for various types of individuals, such as our customers, employees, and others. As a result, not all of the categories of collected personal information described below may be applicable to you. Within the last twelve (12) months, we may have collected the following categories of personal information from the sources identified below for the business and commercial purposes indicated, and disclosed, shared, or sold (as indicated) such categories of personal information with the specified categories of third parties:
Category of Personal Information | Examples of Personal Information Collected | Categories of Sources of Personal Information Collected | Business or Commercial Purpose(s) for Which Collected or Disclosed | Categories of Third Parties to Which Personal Information is Disclosed |
Identifiers | A real name, alias, postal address, unique personal identifier, social security number, driver’s license number, online identifier, Internet Protocol address, email address, account name or other similar identifiers. | Directly from you, for example when you apply to work for us or in your duties as our personnel, or as a customer when you fill out our forms, or from your transactions with us. From third-parties that interact with us in relation to hiring or human resources operations and in connection with the products and/or services that we provide. |
We use this personal information for performance of our services and for our business operations or for human resources purposes. For example:
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With our affiliates, and service providers, in connection with our business operations and human resources functions including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Personal Information Categories Listed in the California Customer Records statue (Cal. Civ. Code 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | See above. |
We use this personal information for performance of our services and for our business operations or human resources functions. For example:
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With our affiliates, and service providers, in connection with our business operations and human resources functions including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Characteristics of protected classifications under California or federal law | Age, national origin, religion, citizenship, marital status, physical or mental disability, genetic information or ancestry, sex, veteran or military status. | Directly from you, for example when you apply to work for us or in your duties as our personnel. From third-parties that interact with us in relation to hiring or human resources operations. |
We use Personnel’s personal information for our business operations or human resource functions, including:
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With our affiliates, and service providers, in connection with our business operations and human resources functions including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Directly from you, for example when you fill out our forms, or from your transactions with us. From third-parties that interact with us in connection with the products and/or services that we provide |
We use this personal information for performance of our services and for our business operations. For example:
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Biometric Information | We do not collect this category of personal information. | |||
Internet or other electronic network activity information | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements. Network traffic and other electronic or internet activity performed when acting as our personnel through our systems. |
As the result of your use of our online services, such as our website, consumer portals or mobile applications (if any), including through the use of cookies, Web beacons, embedded scripts, and other recognition and/or tracking technologies. Directly from you, for example when you apply to work for us or in your duties as our personnel. From third-parties that interact with us in relation to hiring or human resources operations. |
We use this personal information for performance of our services and for our business operations or human resource functions. For example:
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With our affiliates, and service providers, in connection with our business operations and human resources function including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Geolocation data | Geographic tracking data, physical location and movements. | Directly from you, for example when you use our applications or applicable services. From third-parties that interact with us in connection with the products and/or services that we provide. |
We use this personal information for performance of our services and for our business operations. For example:
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With our affiliates, and service providers, in connection with our business operations functions including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Sensory Data | Images and audio, video or call recordings created in connection with our business activities | Directly from you, for example when you apply to work for us or in your duties as our personnel. From third-parties that interact with us in relation to hiring or human resources operations. |
We collect this information as the result of Personnel’s use of other systems to facilitate the security of our offices and information systems and use it for our internal business operations. | |
Professional or employment related information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply to work with us. Current and/or past employment history, payroll records, benefits records, leave documentation, or medical records. |
Directly from you, for example when you apply to work for us or in your duties as our personnel. From third-parties that interact with us in relation to hiring or human resources operations. |
We use Personnel’s personal information for our business operations, including:
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We may share personal information in connection with performance of our services, and for our business operations or human resources functions, including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. 1232g, 34 C.F.R. Part 99)) | Student records and directory information. | Directly from you, for example when you apply to work for us or in your duties as our personnel. From third-parties that interact with us in relation to hiring or human resources operations. |
While we may collect information about your education history directly from you for the same purpose described above, we do not otherwise collect information directly from education agencies or institutions. |
We may share personal information in connection with performance of our services, and for our business operations or human resources functions, including: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Inferences drawn from other personal information | A person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes. | Directly from you, for example when you apply to work for us or in your duties as our personnel. From third-parties that interact with us in relation to hiring or human resources operations. |
We use this personal information for performance of our services, and for our business operations or human resource functions. For example:
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We may share personal information in connection with performance of our services, and for our business operations or human resources functions, including with: Service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Outside companies or organizations, in connection with routine or required reporting, including consumer reporting agencies and other parties; and Affiliates. |
Sensitive Personal Information | Personal information that reveals: a Social Security number or other government identifier; account login information or a financial account number with associated credentials; contents of mail, email, or text messages. The collection and analysis of information that concerns a consumer’s health information. |
Employees, contractors, and job applicants who seek employment or a contacting relationship. From third-parties that interact with us in relation to hiring or human resources operations. |
We use this personal information for performance of our human resource functions. For example:
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We may share personal information in connection with performance of our services, and for our business operations or human resources functions, including: Service providers; Government agencies when required by law including to support regulatory and legal requirements; and Affiliates. |
Information about our Personal Information Processing Activities
Additional details of how we process personal information is set forth in the chart above.
We do not sell consumers’ personal information.
We do not sell or share the personal information of minors under 18 years of age.
We do not use or disclose sensitive personal information for purposes other than the following:
- To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
- To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information,
- To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
- To ensure the physical safety of natural persons.
- For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
- To perform services on behalf of the business.
- To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
Your Privacy Rights
Right to Notice
You have the right to receive notice at or before the point of collection about our collection and retention practices. Please review our notice at collection linked here https://Flagshipbio.com/privacy-policy/ for more information.
Submitting Consumer Requests
You may submit a consumer request to us by email at privacy@Flagshipbio.com, or phone at (866) 280-4013 (toll free) to make a consumer request. You may make up to two disclosure requests in any 12-month period. Please review the consumer request forms below.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
Making a verifiable consumer request does not require you to create an account with us.
When you submit a verifiable consumer request, we will take steps to verify your request by email or telephone call. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Right to Know and Access Your Information
You have the right to request that we disclose to you certain descriptions and categories of the personal information we collect, use, disclose, share, or sell about you. For example, you may request the following:
- The categories of personal information we have collected about you.
- The categories of sources from which personal information is collected.
- The business or commercial purpose for collecting, selling, or sharing personal information.
- The categories of third parties to whom The Company discloses the personal information.
- The specific pieces of personal information we have collected about you.
You may make up to two disclosure requests in any 12-month period.
We do not share your personal information for the purposes of cross-context behavioral advertising.
Right to Request Deletion
You have the right to request that we delete your personal information. See above for additional details about how to submit a consumer request.
You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.
Right to Request Correction
You have the right to request that we correct your personal information. See above for additional details about how to submit a consumer request.
Right to Opt-Out of the Sharing of Personal Information
We do not share or sell the personal information we collect about you.
Right to Non-Discrimination for Exercise of Consumer Privacy Rights
We will not discriminate against you because you have chosen to exercise any of your privacy rights provided by the CCPA.
Using an Authorized Agent
You may use an authorized agent to submit a consumer request. To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.
Contact Us
Please read this Policy carefully to understand our practices regarding how we process CCPA personal information. If you should have any questions regarding this Privacy Policy please contact us at privacy@Flagshipbio.com, or phone at 303-325-5894 to make a consumer request or ask a question about this Privacy Policy