WEBSITE PRIVACY POLICY

DATE LAST UPDATED: JULY 25, 2023


What does this Website Privacy Policy apply to?

This Website Privacy Policy (“Privacy Policy”) applies to your interactions with Belay Diagnostics, Inc. (“us” or “we”) through our Website (as defined below). We are providing you with this Privacy Policy to help you better understand why and how we collect certain information, the care with which we treat that information, and how we use that information. 

What information do we collect about you?

We collect limited types of personal information through our website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last 12 months are further described in the chart below after the heading “Who do we disclose your information to?”.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. [At this time, we do not currently respond to DNT Signals, nor does our website use cookies or other tracking technologies.]

How do we obtain your personal information?

In connection with forming and operating our Website, we collect and maintain your personal information from the following sources:

  • Information from your communications with us in connection with this Website, including through emails.
  • Information you provide to us through our Website, including your name, phone number, job title, and email address.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. 

How do we use your personal information?

We will use your personal information for one or more of the following business or commercial purposes:

  • To perform services for you. 
  • To provide, support, personalize, develop and improve our Website and the products and services that we offer.
  • To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
  • To keep a record of your relationship with us.
  • To conduct ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
  • To maintain the safety, security and integrity of our Website, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
  • As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

Additionally, we may use your personal information to keep you informed of business updates or our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in any forms of marketing at any time, by contacting us. You may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

We retain the categories of personal information set forth above in “What information do we collect about you?” section of this Privacy Policy only as long as is reasonably necessary for those purposes set forth above in “How do we use your personal information?”, except as may be required under applicable law, court order or government regulations. Information may persist in copies made for backup and business continuity purposes for additional time.

Who do we disclose your personal information to?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA (defined below) any of the personal information we collect about you to third parties.

We may disclose your information with third parties who perform services on our behalf, including without limitation, marketing, customer support, data storage, data analysis and processing, and legal services.

We may disclose your information with current or future affiliated companies. As we continue to develop our business, we may engage in certain business transactions, such as a merger, divesture, restructuring, reorganisation, dissolution or the transfer or sale of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. In such transactions, (including in contemplation of such transactions) your information may be disclosed or transferred. If any of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.

We may disclose your information to any third parties based on your consent to do so. We may disclose de-identified and/or aggregated data for any purpose to third parties.

Within the last 12 months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information CategoryExamplesCollectedCategory of Third-Party Recipients
A. IdentifiersName, contact details and addresses (including physical address, email address and Internet Protocol address).YesN/A
B. Personal information categoriesName, telephone number, physical characteristics or description, education, financial information, medical information, health insurance information, and other identifying information. YesN/A
C. Protected classification characteristics under state or federal lawDate of birth, citizenship and birthplace.NoN/A
D. Commercial informationAccount data and other information contained in any document provided by users (whether directly or indirectly), transaction history.YesN/A
E. Biometric informationImagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings, and sleep, health, or exercise data that contains identifying information.NoN/A
F. Internet or other similar network activityUse of our website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.YesN/A
G. Geolocation dataPhysical location or movements.NoN/A
H. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.NoN/A
I. Professional or employment-related informationCurrent or past job history or performance evaluations.NoN/A
J. Non-public education information Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.NoN/A
K. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NoN/A
L. Sensitive Personal InformationSocial security number, driver’s license, state identification card, or passport numbers; account log-in, financial account number in combination with any required security or access code, password, or credentials; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.NoN/A

How do we keep your personal information secure?

We consider the protection of personal information to be a sound business practice, and to that end we employ reasonable organizational, physical, technical, and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Further Information.

We reserve the right to change our privacy policies and this Privacy Policy at any time. The examples contained within this notice are illustrations only and are not intended to be exclusive. You may have additional rights under other foreign or domestic laws that apply to you, including as set forth further below. 

Specific Rights

Children

Use of the Website is intended for persons over the age of 18 and are not directed at children under the age of 16. We do not knowingly collect personal information from children under the age of 16. If we become aware that we have collected personal information from children, we will take reasonable steps to delete it as soon as practicable.

EU/UK Data Subject Rights

Individuals in the European Economic Area (“EEA”) and other jurisdictions, including the UK, may have certain legal rights (subject to applicable exceptions and limitations) to obtain confirmation from us about information we may have about them, to access such information, and to obtain its correction or deletion in certain circumstances. If you are a resident of such a jurisdiction, you may have the right to object to our handling of your information, restrict our processing of your information, and to withdraw any consent you have provided. To exercise these rights, please contact us, as described below, with the nature of your request.


U.S. State Privacy Rights

General

Various U.S. state consumer privacy laws may provide their residents with rights regarding our use of their personal information. For example, residents of certain states may have rights to: (i) confirm whether we process their personal information; (ii) access and delete certain personal information; (iii) data portability; and (iv) opt-out of personal data processing for targeted advertising and sales, (v) correct inaccuracies in their personal information, taking into account the information’s nature processing purpose; or (vi) opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. Not all of the above rights are applicable to our collection and use of your personal information.  To exercise any of these rights set forth in this section, please contact us, as described below, with the nature of your request.

California Specific Rights

Natural person California residents are granted specific knowledge, access, correction, and deletion rights under the California Consumer Privacy Act of 2018, as amended (“CCPA”). Such California consumers also have a right to opt out of the sale or sharing of their personal information and a right not to be discriminated against for exercising rights granted under the CCPA. The remainder of this section is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth below is otherwise set forth above.

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules, and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

  • the categories of personal information we collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting such personal information;
  • the categories of third parties with whom we disclose the personal information;
  • the specific pieces of personal information we have collected about you; and
  • whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.


Contact us

For any requests relating to the exercise of your rights in connection with this Privacy Policy, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

We will contact you to confirm receipt of your request and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

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