This Policy applies to Personal Information that is Processed by Onovo Pharma in the course of our business, including on Onovo Pharma websites (each a “Site”), mobile applications, and other online, offline or in-store offerings (together with any and all future online and offline offerings operated by or on behalf of Onovo Pharma, the “Services”). “Personal Information” is any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable natural person or device.
All individuals whose responsibilities include the Processing of Personal Information on behalf of Onovo Pharma are expected to protect that data by adherence to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
- TRANSPARENCY/NOTICE–TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Onovo Pharma and the requirements of applicable law. Some of the ways that Onovo
pharma may collect Personal Information include:
You may provide Personal Information directly to Onovo Pharma
throughinteracting with the Services, participating in surveys, during
events, and requesting products, Services, or information.
As you navigate the Services, certain passive information may also
be collected about your visit, including through cookies and similar
technologies as described below.
We endeavor to collect only that information which is relevant for
the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 TYPES OF PERSONAL INFORMATION WE COLLECT
Onovo Pharma collects Personal Information regarding its current,
prospective, and former clients, customers, users, visitors, guests,
and Employees (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Onovo Pharma, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Purchases. When you purchase products or services from Onovo Pharma, you must provide us with Personal Information, such as your name, email address, address that are associated with your debit/credit card. Please note that we do not store credit/debit card numbers.
Communications with Us. We may also collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our products and Services, register for a newsletter or loyalty program that we may offer from time to time, contact customer service or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys or in-person interviews and focus groups. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys or interviews is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein. Posting on the Site. We collect information you post through the Site. For example, when you interact with other users or the Site by posting a review or other materials, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections
set forth herein.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that areautomatically assigned to your computer or device when you access the Internet, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. To the extent
devices transmit location data through GPS, Bluetooth, or WiFi signals, we may also collect this data.
Promotion and Giveaways. Occasionally we will partner with Third Parties on social media and online channels to sponsor giveaways
and promotions. Terms and conditions will accompany each give
Onovo Pharma and promotion, and it is the responsibility of all
entrants to read the terms and conditions and privacy policies
carefully. If you choose to share your information in order to
participate in a give Onovo Pharma or promotion, your entry
information may be shared with such Third Parties.
Information from Other Sources. We may receive information about
you from other sources, including through Third-Party services and
organizations, which may supplement information provided by you.
This supplemental information can allow us to verify information that
you have provided to Onovo Pharma and enhances our ability to
provide you with information about our business, products, and
Services. For example, if you access Third-Party services, such as
Facebook or Twitter, to login to the Services or to share information
about your experience with Onovo Pharma, we may collect
information from these Third-Party services.
3.2 HOW ONOVO PHARMA USES YOUR PERSONAL
We acquire, hold, use, and Process Personal Information about
Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested: Onovo
Pharma may use information about you to fulfill requests for
products, Services, or information, including information about
potential or future Services, including to:
Generally manage Individual information and accounts;
Respond to questions, comments, and other requests;
Support the tracking and recovery of your Onovo Pharma and/or
Provide access to certain areas, functionalities, and features of
Onovo Pharma’s Services;
Allow you to register for events.
Administrative Purposes: Onovo Pharma may use Personal
Information about you for its administrative purposes, including to:
Measure interest in Onovo Pharma’s Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual accounts and activities on Onovo
Pharma’s Services and systems, and, in Onovo Pharma’s
discretion, changes to any Onovo Pharma policy;
Send email to the email address you provide to us to verify your
account and for informational and operational purposes, such as
account management, customer service, or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Comply with regulatory requirements, including collecting and using
information relating to adverse effects you have experienced when
using our products;
Prevent potentially prohibited or illegal activities;
Marketing Onovo Pharma Products and Services: Onovo Pharma
may use Personal Information to provide you with materials about
offers, products, and Services that may be of interest, including new
content or Services. Onovo Pharma may provide you with these
materials via online social platforms, websites, phone, text/SMS,
postal mail, facsimile, or email, as permitted by applicable law. Such
uses include: To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of
interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide
or Otherwise with your consent.
You may contact us at any time to opt-out of the use of your
Personal Information for marketing purposes, as further described
in Section 6 below.
Research and Development: Onovo Pharma may use Personal
Information to create non-identifiable information that we may use
alone or in the aggregate with information obtained from other
sources, in order to help us to optimally deliver our existing
products and Services or develop new products and Services. From
time to time, Onovo Pharma may perform research (online and
offline) via surveys. We may engage Third-Party service providers
to conduct such surveys on our behalf. All survey responses are
voluntary, and the information collected will be used for research
and reporting purposes to help us better serve Individuals by
learning more about their needs and the quality of the products and
services we provide. The survey responses may be utilized to
determine the effectiveness of our Services, various types of
communications, advertising campaigns, and/or promotional
activities. If an Individual participates in a survey, the information
given will be used along with that of other study participants. We
may share anonymous Individual and aggregate data for research
and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who
provide us with Personal Information, or whose Personal
Information we obtain from Third Parties, may receive periodic
emails, referral offers, newsletters, mailings, or phone calls from us
with information on Onovo Pharma’s or our business partners’
products and services or upcoming special offers/events we believe
may be of interest. We offer the option to decline these
communications at no cost to the Individual by following the
instructions in Section 6 below.
Mobile Devices. From time to time, Onovo Pharma may provide
Services that are specifically designed to be compatible and used
on mobile devices. Onovo Pharma will collect certain information
that your mobile device sends when you use such Services, like a
device identifier, user settings and the operating system of your
device. Mobile versions of Onovo Pharma’s Services may require
that users log in with an account. In such cases, information about
use of mobile versions of the Services may be associated with user
accounts. In addition, Onovo Pharma may enable Individuals to
download an application, widget, or other tool that can be used on
mobile or other computing devices. Some of these tools may store
information on mobile or other devices. These tools may transmit
Personal Information to Onovo Pharma to enable Individuals to
access user accounts and to enable Onovo Pharma to track use of
these tools. Some of these tools may enable users to email reports
and other information from the tool. Onovo Pharma may use
personal or non-identifiable information transmitted to Onovo
Pharma to enhance these tools, to develop new tools, for quality
improvement and as otherwise described in this Policy or in other
notices Onovo Pharma provides.
Anonymous and Aggregated Information. Onovo Pharma may use
Personal Information and other information about you to create
anonymized and aggregated information, such as de-identified
demographic information, de-identified location information,
information about the computer or device from which you access
Onovo Pharma’s Services, or other analyses we create.
Anonymized and aggregated information is used for a variety of
functions, including the measurement of visitors’ interest in and use
of various portions or features of the Services. Anonymized or
aggregated information is not Personal Information, and Onovo
Pharma may use such information in a number of ways, including
research, internal analysis, analytics, and any other legally
permissible purposes. We may share this information within Onovo
Pharma and with Third Parties for our or their purposes in an
anonymized or aggregated form that is designed to prevent anyone
from identifying you. Information Submitted Via Services. You agree
that Onovo Pharma is free to use the content of any
communications submitted by you via the Services, including any
ideas, inventions, concepts, techniques, or know-how disclosed
therein, for any purpose including developing, manufacturing, and/
or marketing goods or Services. Onovo Pharma will not release
your name or otherwise publicize the fact that you submitted
materials or other information to us unless: (a) you grant us
permission to do so; (b) we first send notice to you that the
materials or other information you submit to a particular part of a
Service will be published or otherwise used with your name on it; or
(c) we are required to do so by law.
Sharing Content with Friends or Colleagues. Onovo Pharma’s
Services may offer various tools and functionality. For example,
Onovo Pharma may provide functionality on its Services that will
allow you to forward or share certain content with a friend or
colleague. Email addresses that you may provide for a friend or
colleague will be used to send your friend or colleague the content
or link you request, but will not be collected or otherwise used by
Onovo Pharma or any other Third Parties for any other purpose.
Other Uses. Onovo Pharma may use Personal Information for
which we have a legitimate interest, such as direct marketing,
individual or market research, anti-fraud protection, or any other
purpose disclosed to you at the time you provide Personal
Information or with your consent.
3.3 COOKIES, PIXEL TAGS/WEB BEACONS, AND ANALYTICS
We, as well as Third Parties that provide content, advertising, or
local storage, and other technologies (“Technologies”) to
automatically collect information through the Services. We use
Technologies that are essentially small data files placed on your
computer, tablet, mobile phone, or other devices (referred to
collectively as a “device”) that allow us to record certain pieces of
information whenever you visit or interact with our sites, services,
applications, messaging, and tools, and to recognize you across
devices to automatically collect information through the Services.
Cookies. Cookies are small text files placed in visitors’ computer
browsers to store their preferences. Most browsers allow you to
block and delete cookies. However, if you do that, the Site may not
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon)
is a piece of code embedded on the Site that collects information
about users’ engagement on that web page. The use of a pixel
allows us to record, for example, that a user has visited a particular
web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and Google Analytics
Demographics and Interest Reporting and other providers to collect
information regarding visitor behavior and visitor demographics on
some of our Services, and to develop website content. Google
Analytics data is not tied to any Personal Information. For more
information about Google Analytics, please visit www.google.com/
policies/privacy/partners/. You can opt out of Google’s collection
and Processing of data generated by your use of the Services by
going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general
beacons, or other similar technologies that are necessary to the
operation of our sites, services, applications, and tools. This
includes technologies that allow you access to our sites, services,
applications, and tools; that are required to identify irregular site
behavior, prevent fraudulent activity and improve security; or that
allow you to make use of our functions such as shopping-carts,
saved search, or similar functions; Performance Related. We may
the performance of our websites, applications, services, and tools,
including as part of our analytic practices to help us understand how
our visitors use our websites, determine if you have interacted with
our messaging, determine whether you have viewed an item or link,
or to improve our website content, applications, services, or tools;
similar technologies that allow us to offer you enhanced functionality
when accessing or using our sites, services, applications, or tools.
This may include identifying you when you sign into our sites or
keeping track of your specified preferences, interests, or past items
viewed so that we may enhance the presentation of content on our
Advertising or Targeting Related. We may use first-party or thirdparty
cookies and web beacons to deliver content, including ads
relevant to your interests, on our sites or on third party sites. This
includes using technologies to understand the usefulness to you of
the advertisements and content that has been delivered to you,
such as whether you have clicked on an advertisement. If you
would like to opt-out of the Technologies we employ on our sites,
services, applications, or tools, you may do so by blocking, deleting,
or disabling them as your browser or device permits.
3.4 THIRD-PARTY SITES AND SOCIAL MEDIA PLATFORMS
The Site may contain links to other websites and other websites
may reference or link to our Site or other Services. These other
domains and websites are not controlled by us, and Onovo Pharma
does not endorse or make any representations about Third-Party
websites or social media platforms. We encourage our users to
read the privacy policies of each and every website and application
that they interact with. We do not endorse, screen or approve, and
are not responsible for the privacy practices or content of such
other websites or applications. Visiting these other websites or
applications is at your own risk.
The Site and our other Services may also contains links and
interactive features with various social media platforms. If you
already use these platforms, their cookies may be set on your
device when using our Site or other Services. You should be aware
that Personal Information which you voluntarily include and transmit
online in a publicly accessible blog, chat room, social media
platform or otherwise online, or that you share in an open forum
may be viewed and used by others without any restrictions. We are
unable to control such uses of your information when interacting
with a social media platform, and by using such services you
assume the risk that the Personal Information provided by you may
be viewed and used by Third Parties for any number of purposes.
- ONWARD TRANSFER – ONOVO PHARMA MAY DISCLOSE
YOUR PERSONAL INFORMATION; SHARING OF PERSONAL
4.1 PERSONAL INFORMATION WE SHARE
We may share your information as described in this Policy (e.g.,
with our Third-Party service providers; to comply with legal
obligations; to protect and defend our rights and property) or with
We Use Vendors and Service Providers. We may share any
information we receive with vendors and service providers. The
types of service providers (processors) to whom we entrust
Personal Information include service providers for: (i) provision of IT
and related services; (ii) provision of information and services you
have requested; (iii) payment processing; (iv) customer service
activities; and (v) in connection with the provision of the Site. Onovo
Pharma has executed appropriate contracts with the service
providers that prohibit them from using or sharing Personal
Information except as necessary to perform the contracted services
on our behalf or to comply with applicable legal requirements.
Business Partners. Onovo Pharma may share Personal Information
with our business partners, and affiliates for our and our affiliates’
internal business purposes or to provide you with a product or
service that you have requested Onovo Pharma may also provide
Personal Information to business partners with whom we may jointly
offer products or services, or whose products or services we believe
may be of interest to you. In such cases, our business partner’s
name will appear, along with Onovo Pharma’s name. Onovo
Pharma requires our affiliates and business partners to agree in
writing to maintain the confidentiality and security of Personal
Information they maintain on our behalf and not to use it for any
purpose other than the purpose for which Onovo Pharma provided
Displaying to Other Users. The content you post to the Site may be
displayed on the Site. Other users of the Site may be able to see
some information about you, such as your name if you submit a
review. We are not responsible for privacy practices of the other
users who will view and use the posted information.
Marketing. Interest-Based Advertising and Third Party Marketing.
Through our Services, Onovo Pharma may allow Third-Party
advertising partners to set tracking tools (e.g., cookies) to collect
information regarding your activities (e.g., your IP address, page(s)
visited, time of day). We may also share such de-identified
information as well as selected Personal Information (such as
demographic information and past purchase history) we have
collected with Third-Party advertising partners. These advertising
partners may use this information (and similar information collected
from other websites) for purposes of delivering targeted
advertisements to you when you visit non-Onovo Pharma related
websites within their networks. This practice is commonly referred
to as “interest-based advertising” or “online behavioral advertising”.
We may allow access to other data collected by the Site to facilitate
transmittal of information that may be useful, relevant, valuable or
otherwise of interest to you. If you prefer that we do not share your
Personal Information with Third-Party advertising partners, you may
opt-out of such sharing at no cost by following the instructions in
Section 6 below.
Disclosures to Protect Us or Others (e.g., As Required by Law and
Similar Disclosures). We may access, preserve, and disclose your
Personal Information, other account information, and content if we
believe doing so is required or appropriate to: (i) comply with law
enforcement or national security requests and legal process, such
as a court order or subpoena; (ii) respond to your requests; (iii)
protect yours’, ours’ or others’ rights, property, or safety; (iv) to
enforce Onovo Pharma policies or contracts; (v) to collect amounts
owed to Away; (vi) when we believe disclosure is necessary or
appropriate to prevent physical harm or financial loss or in
connection with an investigation or prosecution of suspected or
actual illegal activity; or (vii) if we, in good faith, believe that
disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for
security purposes – e.g., to detect unauthorized activity on the
Services. In such cases, server log data containing IP addresses
may be shared with law enforcement bodies in order that they may
identify users in connection with their investigation of the
Merger, Sale, or Other Asset Transfers. If we are involved in a
merger, acquisition, financing due diligence, reorganization,
bankruptcy, receivership, sale of company assets, or transition of
service to another provider, then your information may be sold or
transferred as part of such a transaction as permitted by law and/or
contract. Should such an event occur, Onovo Pharma will endeavor
to direct the transferee to use Personal Information in a manner that
is consistent with the Policy in effect at the time such Personal
Information was collected.
In the preceding twelve (12) months, we have not sold any Personal
4.2 DATA TRANSFERS
All Personal Information collected via or by Onovo Pharma may be
stored anywhere in the world, including but not limited to, in the
United States, in the cloud, on our servers, on the servers of our
affiliates or the servers of our service providers. Your Personal
Information may be accessible to law enforcement or other
authorities pursuant to a lawful request. By providing information to
Onovo Pharma, you consent to the storage of your Personal
Information in these locations.
5.OPT-OUT (RIGHT TO RESTRICT PROCESSING)
You have the right to opt out of certain uses and disclosures of your
Personal Information. Where you have consented to Onovo
Pharma’s Processing of your Personal Information or Sensitive
Personal Information, you may withdraw that consent at any time
and opt-out to further Processing by contacting
firstname.lastname@example.org. Even if you opt-out, we may still collect
and use non-Personal Information regarding your activities on our
Sites and/or information from the advertisements on Third-Party
websites for non-interest based advertising purposes, such as to
determine the effectiveness of the advertisements.
5.2 E-MAIL AND TELEPHONE COMMUNICATIONS
If you receive an unwanted email from us, you can use the
unsubscribe link found at the bottom of the email to opt-out of
receiving future emails. We will process your request within a
reasonable time after receipt. Note that you will continue to receive
transaction-related emails regarding products or services you have
purchased. We may also send you certain communications
regarding Onovo Pharma and our Services and you will not be able
to opt out of those communications (e.g., communications regarding
updates to our Terms of Service or this Policy). We will provide optout
notices to third parties who may contact you on our behalf in
accordance with this Policy. While we will endeavor to ensure that
you are removed from any such contact lists, we cannot guarantee
that this will occur (for example, if your Information is provided to
the third party through another advertiser whose communications
you have elected to receive and not opted out).
We maintain telephone “do-not-call” and “do-not-mail” lists as
mandated by law. We process requests to be placed on do-not-mail,
do-not-phone and do-not-contact lists within 60 days after receipt,
or such shorter time as may be required by law.
5.4 DO NOT TRACK
Do Not Track (“DNT”) is a privacy preference that users can set in
certain web browsers. DNT is a way for users to inform websites
and services that they do not want certain information about their
webpage visits collected over time and across websites or online
services. Please note that we do not respond to or honor DNT
signals or similar mechanisms transmitted by web browsers.
5.5 COOKIES AND INTEREST-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies
on your computer or remove them from your browser by adjusting
your web browser preferences. Please note that cookie-based optouts
are not effective on mobile applications. However, on many
mobile devices, application users may opt out of certain mobile ads
via their device settings.
The online advertising industry also provides websites from which
you may opt-out of receiving targeted ads from our data partners
and our other advertising partners that participate in self-regulatory
programs. You can access these, and also learn more about
targeted advertising and consumer choice and privacy, at
www.networkadvertising.org/managing/opt_out.asp, or http://
www.youronlinechoices.eu/ and www.aboutads.info/choices/. You
can also choose not to be included in Google Analytics here.
To be clear, whether you are using our opt-out or an online industry
opt-out, these cookie-based opt-outs must be performed on each
device and browser that you wish to have opted-out. For example, if
you have opted-out on your computer browser, that opt-out will not
be effective on your mobile device. You must separately opt-out on
each device. Advertisements on Third-Party websites that contain
been directed to you based on anonymous, non-Personal
Information collected by advertising partners over time and across
websites. These advertisements provide a mechanism to opt-out of
the advertising partners’ use of this information for interest-based
6.RIGHTS OF ACCESS, RECTIFICATION, AND ERASURE
You may inquire as to whether Onovo Pharma is Processing
Personal Information about you, request access to Personal
Information, and ask that we correct, amend or delete your
Personal Information where it is inaccurate. Where otherwise
permitted by applicable law, you may send an e-mail to
email@example.com or use any of the methods set out in this
Policy to request access to, receive (port), seek rectification, or
request erasure of Personal Information held about you by Onovo
Pharma. Such requests will be processed in line with local laws.
Although Onovo Pharma makes good faith efforts to provide
Individuals with access to their Personal Information, there may be
circumstances in which Onovo Pharma is unable to provide access,
including but not limited to: where the information contains legal
privilege, would compromise others’ privacy or other legitimate
rights, where the burden or expense of providing access would be
disproportionate to the risks to the Individual’s privacy in the case in
question or where it is commercially proprietary. If Onovo Pharma
determines that access should be restricted in any particular
instance, we will provide you with an explanation of why that
determination has been made and a contact point for any further
inquiries. To protect your privacy, Onovo Pharma will take
commercially reasonable steps to verify your identity before
granting access to or making any changes to your Personal
You may request that we delete your Personal Information as well
as request that we make your Personal Information available for
7.SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely
Internet cannot be guaranteed to be 100% secure, and we cannot
ensure or warrant the security of any information you provide to us.
We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree
that we may communicate with you electronically regarding security,
privacy, and administrative issues relating to your use of the Site. If
we learn of a security system’s breach, we may attempt to notify
you electronically by posting a notice on the Site or sending an
email to you. You may have a legal right to receive this notice in
Onovo Pharma retains the Personal Information we receive as
described in this Policy for as long as you use our Services or as
necessary to fulfill the purpose(s) for which it was collected, provide
our products and services, resolve disputes, establish legal
defenses, conduct audits, pursue legitimate business purposes,
enforce our agreements, and comply with applicable laws.
We do not knowingly collect, maintain, or use Personal Information
from children under 13 (and in certain jurisdictions under the age of
16) years of age, and no part of the Site is directed to children
under the age of 13 (and in certain jurisdictions under the age of
16). If you learn that your child has provided us with Personal
Information without your consent, you may alert us at
firstname.lastname@example.org. If we learn that we have collected any
Personal Information from children under 13 (and in certain
jurisdictions under the age of 16), we will promptly take steps to
delete such information and terminate the child’s account.
By using the Site, you will transfer data to the United States. By
choosing to visit the Site, utilize the Services or otherwise provide
information to us, you agree that any dispute over privacy or the
the State of California and the adjudication of any disputes arising
in connection with Onovo Pharma or the Site will be in accordance
with the Terms.
If you are visiting from the European Union or other regions with
laws governing data collection and use, please note that you are
agreeing to the transfer of your information to the United States and
processing globally. By providing your Personal Information, you
consent to any transfer and processing in accordance with this
11.REDRESS/COMPLIANCE AND ACCOUNTABILITY
If after reviewing this Policy, you would like to submit a request or
you have any questions or privacy concerns, please send an e-mail
to email@example.com or contact us at:
Onovo Pharma will address your concerns and attempt to resolve
any privacy issues in a timely manner.
12.OTHER RIGHTS AND IMPORTANT INFORMATION
our sole discretion, so review it periodically. If you continue to visit
this Site and use the services made available to you after such
changes have been made, you hereby provide your consent to the
to this Policy, Onovo Pharma will notify you by email or as otherwise
required by applicable law. We will post any adjustments to the
effective immediately when it is posted (or upon notice as
applicable). If you are concerned about how your information is
New Uses of Personal Information. Additionally, before we collect
additional categories of Personal Information or use Personal
Information for any new purpose materially different, unrelated,
incompatible, or not originally authorized by you, we will endeavor
to provide information regarding the new purpose and give you the
opportunity to opt-out. Where consent of the Individual for the
Processing of Personal Information is otherwise required by law or
contract, Onovo Pharma will endeavor to comply with the law or
12.2 CALIFORNIA PRIVACY RIGHTS/CALIFORNIA CONSUMER
California law permits users who are California residents to request
and obtain from us once a year, free of charge, a list of the Third
Parties to whom we have disclosed their Personal Information (if
any) for their direct marketing purposes in the prior calendar year,
as well as the type of Personal Information disclosed to those
Any terms defined in the California Consumer Privacy Act of 2018
(“CCPA”) have the same meaning when used in this Policy. Onovo
Pharma only shares Personal Information with Third Parties for their
own marketing purposes as described herein or as you may
In the past 12 months we have collected the following categories of
Personal Information does not include:
• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
• health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the California
Confidentiality of Medical Information Act (CMIA) or clinical trial
• personal information covered by certain sector-specific privacy
laws, including the Fair Credit Reporting Act (FRCA), the Gramm-
A. Identifiers YES
B. Personal Information categories listed in the California
Customer Records statute (Cal. Code Section
C. Protected classification characteristics under
California or federal law.
D. Commercial information YES
E. Biometric information NO
F. Internet or other similar network activity YES
G. Geolocation data YES
H. Sensory data YES
I. Professional or employment-related information NO
J. Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section
1232g. 34 C.F.R. Part 99))
K. Inferences drawn from other Personal Information YES
Leach-Bliley Act (GLBA) or California Financial Information Privacy
Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific
rights regarding their Personal Information. This section describes
your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to
you about our collection and use of your Personal Information over
the past 12 months. Once we receive and confirm your verifiable
consumer request, we will disclose to you:
• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we
collected about you.
• Our business or commercial purpose for collecting or selling that
• The categories of third parties with whom we share that Personal
• The specific pieces of Personal Information we collected about
you (also called a data portability request).
• If we sold or disclosed your Personal Information for a business
purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each
category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal
Information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal
Information that we collected from you and retained, subject to
certain exceptions. Once we receive and confirm your verifiable
consumer request, we will delete (and direct our service providers
to delete) your Personal Information from our records, unless an
We may deny your deletion request if retaining the information is
necessary for us or our service providers to:
• Complete the transaction for which we collected the Personal
Information, provide a good or service that you requested, take
actions reasonably anticipated within the context of our ongoing
business relationship with you, or otherwise perform our contract
• Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for such
• Debug products to identify and repair errors that impair existing
• Exercise free speech, ensure the right of another consumer to
exercise their free speech rights, or exercise another right provided
for by law.
• Comply with the California Electronic Communications Privacy Act
(Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or
statistical research in the public interest that adheres to all other
applicable ethics and privacy laws, when the information’s deletion
may likely render impossible or seriously impair the research’s
achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with
consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are
compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights
described above, please submit a verifiable consumer request to us
• Calling us at (866) 736 1220
• Emailing us at firstname.lastname@example.org
Only you or a person registered with the California Secretary of
State that you authorize 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
You may only make a verifiable consumer request for access or
data portability twice within a 12-month period. The verifiable
consumer request must:
• Provide sufficient information that allows us to reasonably verify
you are the person about whom we collected Personal Information
or an authorized representative.
• Describe your request with sufficient detail that allows us to
properly understand, evaluate, and respond to it.
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. Making
a verifiable consumer request does not require you to create an
account with us. We will only use Personal Information provided in a
verifiable consumer request to verify the requestor’s identity or
authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45
days of its receipt. If we require more time (up to 90 days), we will
inform you of the reason and extension period in writing. If you have
an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our
written response by mail or electronically, at your option. Any
disclosures we provide will only cover the 12-month period
preceding the verifiable consumer request’s receipt. The response
we provide will also explain the reasons we cannot comply with a
request, if applicable. For data portability requests, we will select a
format to provide your personal information that is readily useable
and should allow you to transmit the information from one entity to
another entity without hindrance.
We do not charge a fee to process or respond to your verifiable
consumer request unless it is excessive, repetitive, or manifestly
unfounded. If we determine that the request warrants a fee, we will
tell you why we made that decision and provide you with a cost
estimate before completing your request.
We will not discriminate against you for exercising any of your
CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services,
including through granting discounts or other benefits, or imposing
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or
services or a different level or quality of goods or services.
The following capitalized terms shall have the meanings herein as
set forth below. “Agent” means any Third Party that Processes
Personal Information pursuant to the instructions of, and solely for,
Onovo Pharma or to which Onovo Pharma discloses Personal
Information for use on its behalf.
“Employee” refers to any current, temporary, permanent,
prospective or former employee, director, contractor, worker, or
retiree of Onovo Pharma or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or
identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed
upon Personal Information, whether or not by automatic means,
such as collection, recording, organization, structuring, storage,
adaptation or alteration, retrieval, consultation, use, disclosure by
transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of
Personal Information which, due to its nature, has been classified
by law or by policy as deserving additional privacy and security
protections. Sensitive Personal Information includes Personal
Information regarding EU residents that is classified as a “Special
Category of Personal Data” under EU law, which consists of the
following data elements: (1) race or ethnic origin; (2) political
opinions; (3) religious or philosophical beliefs; (4) trade union
membership; (5) genetic data; (6) biometric data where Processed
to uniquely identify a person; (6) health information; (7) sexual
orientation or information about the Individual’s sex life; or (8)
information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public
authority, agency, or body other than the Individual, Onovo Pharma
or Onovo Pharma’s Agents.