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
email@example.com. 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
firstname.lastname@example.org 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
email@example.com. 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 firstname.lastname@example.org 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 email@example.com
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.
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