Supplemental Privacy Policy for U.S. Residents

1. Scope

This Supplemental U.S. Privacy Policy (this “US Privacy Policy”) describes how the Antylia Scientific Group (collectively “Antylia Scientific” “we“, “our” or “us“) collects, uses and discloses your personal information (further referred to herein as “Personal Information”) pursuant to the following U.S. state privacy laws:

  • the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA);
  • the Virginia Consumer Data Protection Act (VCDPA);
  • the Colorado Privacy Act (CPA);
  • the Connecticut Data Privacy Act (CDPA); and
  • the Utah Consumer Privacy Act (UCPA).

In each instance the controller or business of the Personal Information is the legal entity associated with the specific Website each of which is a member of the Antylia Scientific group of companies.

Since the rules and regulations implementing some of these laws have not yet been finalized, we will continue to update our processes and disclosures as well as this US Privacy Policy once these implementing rules and regulations are finalized. Certain terms used in this US Privacy Policy have the meanings given to them in the respective state privacy laws.

This US Privacy Policy is incorporated into and supplements Antylia Scientific’s Privacy Policy, and applies only if you live in the US states of California, Colorado, Connecticut, Virginia or Utah (“Consumers” or “you”). This US Privacy Policy also describes the rights you have with regard to your Personal Information, which apply when these laws take effect in these states. This US Privacy Policy does not apply to any of our employees, owners, directors, officers, or contractors.

 

2. Personal Information that we Collect, Use and Disclose

i. Categories of Personal Information that We Collect

The categories of Personal Information that we have collected about you in the preceding 12 months and the third parties to whom we disclose such Personal Information for a business purpose are set forth below:

Categories of Personal Information We Collect Examples
Identifiers Name, email address, phone number, IP address and unique personal identifiers associated with devices and browsers
Customer Records / Account Information Name, address, phone number, organizational affiliation, position and billing information
Financial information Debit or credit card number and other financial information that you provide to us for billing / payment
Characteristics which may be protected classifications under California or Federal Law Age, ethnicity, race, languages spoken and gender, to the extent such characteristics are voluntarily disclosed to us or contained in any content transmitted across or stored on our network
Commercial Information Records and history of products or services purchased or considered by you
Internet or other electronic network activity information Interaction with our Websites, products and services
Geolocation Data Approximate physical location derived from an IP address or information you provide on our Websites
Audio, electronic, visual, thermal, olfactory, or similar information Audio recordings of your marketing or customer relationship calls with us
Professional or employment-related information Organizational affiliation and position and other information you may provide us as an applicant
Education Information Information you may provide us as an applicant regarding your education
Inferences drawn to create a profile about a consumer Information about your interests or preferences as can be inferred from the information you provide through our Websites
Sensitive Personal Information under the CCPA Information that you may provide to us in the course of your interactions with us, or as an applicant, or otherwise information that is contained in data provided by a customer of us, which includes (as defined in the CCPA):

• Social Security number, driver’s license, state identification card, or passport number;
• Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
• Racial or ethnic origin, religious or philosophical beliefs, citizenship, or immigration status;
• The contents of mail, email, and text messages unless we are the intended recipient of the communication;
• Precise geolocation;
• Biometric information; and
• Health information and sexual orientation.

 

We collect sensitive Personal Information for various purposes, including:

  • to uniquely identify you and for tax reporting purposes;
  • to comply with our legal obligations pursuant to applicable federal and state employment laws and regulations, including collecting and disclosing Personal Information as required by law (e.g., for minimum wage, payroll tax, as well as to comply with equal opportunity and anti-discrimination laws);
  • to facilitate and provide reasonable accommodations; and
  • to facilitate other business purposes as enumerated under the CCPA.

As defined by the CCPA, sensitive Personal Information shall be treated as Personal Information, except where it is collected or processed for “the purpose of inferring characteristics about a consumer.” We do not collect or process sensitive Personal Information for the purpose of inferring characteristics about individuals.

ii. Sources of Personal Information

The sources from which we collect Personal Information depend on, among other things, our relationship or interaction with a specific Consumer. The information below lists the categories of sources from which we collect Personal Information in different contexts:

  • From Consumers directly or indirectly through automated means (i.e. from Consumer's devices);
  • Public records or widely available sources and other records and information that are made available by federal, state, and local government entities;
  • Organizations from whom we collect Personal Information as part of providing our products and services, completing transactions, supporting our everyday operations, or business management and development;
  • Social media platforms; and
  • Organizations from whom we collect Personal Information to support human resources and workforce management activities.

Further information can be found in the Section titled "Personal information we collect and process" of our Antylia Scientific Privacy Policy.

iii. Why we Collect Personal Information

The business and commercial purposes for which we collect and use Personal Information depend on, among other things, our relationship or interaction with a specific Consumer.

Further information can be found in the Section titled "How we use your personal information (our purposes) and our legal basis for processing" of our Antylia Scientific Privacy Policy.

iv. Our Disclosure of Personal Information

The categories of recipients to whom we disclosed Personal Information for our business purposes during the preceding 12 months include:

  • our group companies (companies owned or operated by us);
  • third party service providers and partners who need to have access to the information for the purpose of providing services to us only (and not for such third parties’ commercial use in any way);
  • third party services when you use third party services linked through our Websites and Apps;
  • any competent law enforcement body, regulatory, government agency, court or other third party (our professional advisers) where we believe disclosure is necessary;
  • a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business; or
  • any other person if we have your permission to do so.

When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and use it only for performance of the contract, and not for any other purpose.

Further information can be found in the Section titled "Who we share your personal information with" of our Antylia Scientific Privacy Policy.

While Antylia Scientific does not sell Personal Information in exchange for any monetary consideration, we may share Personal Information for cross-context behavioral advertising purposes as defined by certain state privacy laws, such as the CCPA under Cal. Civ. Code 1798.140(ad)(2). Some of our processing activities may also constitute “targeted advertising” as that term is defined under certain state laws.

We have shared in the preceding 12 months Personal Information as necessary for business purposes, as defined by Cal. Civ. Code 1798.140. This includes sharing personal identifiers, commercial information, and internet or other electronic network activity with payment processing providers, customer relationship management, consulting, e-mail, product feedback, helpdesk services, advertising networks and website analytics companies. You have a right to direct Antylia Scientific not to sell or share your Personal Information. We do not have actual knowledge that we have sold or shared Personal Information of individuals under the age of 16 for targeted advertising or cross-context behavioral advertising purposes.

 

3. Retention

 

We retain Personal Information we collect from you as long as is needed to fulfil the purposes outlined in this US Privacy Policy, and as further described in the Section titled "Data retention" of our Antylia Scientific Privacy Policy.

 

4. Children under the age of 16

 

Use of our Websites, products or services is not intended for and not directed at children under 16 years of age. We do not knowingly collect, sell, or share Personal Information from children under 16 and do not knowingly target our Websites, products or services to children under the age of 16. Persons under 16 years of age should not use or provide any Personal Information through our Websites, products or services. If we learn we have collected or received Personal Information from a child under the age of 16, we will delete that Personal Information in accordance with applicable law. If you believe we might have any information from or about a child under the age of 16, please contact us.

 

5. Your Privacy Rights

 

Subject to certain limitations (as defined in the CCPA or other applicable law), you have the following rights with respect to the Personal Information that we collect about you:

i. Right to Know. You may request information about what Personal Information we have collected about you, including:

  • The categories of Personal Information;
  • The categories of sources from which the Personal Information is collected;
  • The business or commercial purposes for collecting, selling or sharing your Personal Information;
  • The categories of Personal Information we disclosed, shared or sold about you; and
  • The categories of third parties to whom we disclosed, shared or sold Personal Information about you.

ii. Right of Access. You may request a copy of the Personal Information we have collected about you.

iii. Right of Correction. You may ask us to rectify inaccurate Personal Information, or, as appropriate, edit.

iv. Right of Deletion. You may ask us to delete the Personal Information that we have collected from you.

v. Right to Limit Processing of Sensitive Personal Information. You may ask us to limit the processing of sensitive Personal Information we process about you. We do not collect sensitive Personal Information, as defined by the CCPA, for the purpose of inferring characteristics about you. Accordingly, submitting a request to limit the use of your sensitive Personal Information is not required.

vi. Right of Non-discrimination. You have the right to be free from discrimination or retaliation related to your exercise of any of your privacy rights.

vii. Right to Opt-out of Sale or Sharing. As described above, we do not sell your Personal Information. Like many other companies, Antylia Scientific uses services that help deliver interest-based ads to you, and may disclose Personal Information to business partners for their use. Making your Personal Information (e.g., online identifiers, IP address, browsing activity, etc.) available to these third parties may be considered “sharing” under CCPA.

You may have the right to opt out of the sale or sharing of your Personal Information by contacting us through one of the contact methods described under the section titled “How to Contact Us” or by clicking on the link “Do Not Sell or Share My Personal Information” at the bottom of the page.

However, please note that your use of our Websites may still be tracked by us and our vendors or partners to perform functions that are necessary for our businesses, such as hosting our Website, products and services, ensuring there is no fraud (click-fraud, fraudulent or bot traffic), etc. These entities are contractually obligated to keep such information confidential, and will not use it for any purpose other than for the services they provide to us.

You can contact us with your request through one of the contact methods described under section 7 below titled “How to Contact Us”.

We may ask you to provide information that will enable us to verify your identity in order to comply with your request to exercise your privacy rights. Consumers in some states may also authorize an agent to make requests on their behalf. In particular, when a California consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request on their behalf. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request in accordance with the requirements of applicable law.

You may have the right to appeal our decisions made with respect to on your request. To appeal our decision on your request, you may contact us through one of the contact methods described under the section titled “How to Contact Us”. Please enclose a copy of, or otherwise specifically reference, our decision on your request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

You may also request information about our practices related to our disclosure of your Personal Information to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your Personal Information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. You can contact us with your request through one of the contact methods described under the section below titled “How to Contact Us”.

California’s Shine the Light law

If you are a California resident, you are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Data to third parties for their direct marketing purposes in the preceding calendar year. To request the above information, please email us at [email protected] or write to us at: 625 E Bunker Ct., Vernon Hills, IL 60061; ATTN: Legal Department with a reference to "CA Disclosure Information" and include your name, street address, city, state, and ZIP code. In your request, please attest to the fact that you are a California resident and provide a current California address. We will reply to valid requests by sending a response to the email address or physical address from which you submitted your request. Please note that we are not required to respond to requests made by means other than through the provided email address or mail address. Please note that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing and the relevant details required by the Shine the Light law will be included in our response.

 

6. Changes and Updates to this US Privacy Policy

 

Antylia Scientific may update this US Privacy Policy at any time in response to changing legal, technical or business developments. When we update this US Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

This US Privacy Policy was last changed on the date set forth at the top of this US Privacy Policy.

 

7. How to Contact Us

 

Please contact us if you have any questions or concerns about our collection or use of your Personal Information, or if you wish to submit a request to exercise your rights under Section 5 above, or if you have questions about our privacy practices, including if you need to access this Policy in an alternative format.

You may contact us using our e-mail address [email protected] or by registered mail at 625 E Bunker Ct., Vernon Hills, IL 60061; ATTN: Legal Department.