Privacy Policy

Published: November 8, 2022 Last updated: November 13, 2023

Last updated: October 10, 2022

Overview.

Goodwin Biotechnology Inc. (“GBI”) respects your concerns about privacy. This Privacy Policy (the “Policy”) describes the types of information GBI collects, how GBI use that information, how GBI secures it, and whether GBI shares it.

When you use GBI’s website (or any website operated by GBI), request information about GBI or its services, apply for a job, submit forms, or send email to GBI (collectively, the “Services”), you agree to our collection, use, disclosure, and transfer of information as described in this Policy.  You are therefore required to review this Policy carefully.

If you have executed a separate written agreement with GBI, where the provisions of such separate agreement conflict with the terms of this Policy, the terms of such separate agreement document shall control.

As used in this Policy, the term “personal information” means information that identifies a specific individual, which can be used to distinguish an individual from other individuals, or that relates to or describes a specific individual. In general, a person’s name, address, email address and telephone number are all personal information.

I. Information GBI Collects or Receives.

GBI will only collect, use, share, store, or otherwise process your personal information when GBI has an appropriate basis.  For example, GBI may process your personal information as necessary to facilitate our business or in connection with providing the Services, including processing a job application, or responding to your inquiry.  GBI may also process your personal information when necessary to comply with legal obligations, such as regulatory requirements, or for purposes of pursuing legitimate interests, if doing so is consistent with your rights and appropriate to the context, such as providing services or information you have requested, responding to your questions or concerns, and conducting reasonable monitoring of our websites to prevent misuse and fraud. Additionally, in certain cases, you may provide your explicit consent for certain processing of your personal information, such as when you sign a contract, or submit a job application. In those cases, GBI may process your personal information for any purpose disclosed to you at the time you provided your consent for such processing.

In general, GBI collects or receives information the following ways:

  1. You voluntarily provide information to GBI;
  2. GBI collects information automatically, such as through cookies in GBI’s website(s); or
  3. Other parties, such as agents of GBI, may provide information to GBI.

Each of these methods is described in more detail below.

A. Information You Voluntarily Provide to GBI.

You may provide your personal information to us when you choose to use a GBI website, when you do business with GBI, when you make an inquiry, apply for a job, or submit forms to GBI. Because GBI changes the offerings and features on its websites and other Services from time to time, the options you have in order to provide GBI with information also may change. The information you provide to GBI through its website may include your name, title, your contact details such as physical address and/or mailing address, your email address, telephone number, professional and employment-related information (including your practice name and specialty (if applicable)) and educational information, such as your resume, job title, education history, qualifications, cover letter, and any information you submit in connection with an application for employment through the Services, and any additional information you choose to provide us through the Services.

The following are some examples of situations in which you may provide information to us:

  • Requesting information about GBI or any of its services;
  • Doing business with or soliciting business from GBI;
  • Submitting employment applications or inquiries;
  • Submitting general inquiries, or sending any information through GBI’s website(s);
  • Subscribing to GBI notifications or newsletters;
  • Contacting GBI for any reason, such as by telephone or by email (including email sent through a GBI website or otherwise using any GBI email address).

 (2) Information Collected Automatically When You Use GBI’s Website(s).

When you access a GBI website, whether by computer, mobile phone, or other device, the website automatically collects information using technologies such as cookies. Automatically collected data may include, without limitation, information regarding your:

  • Geographical location and identification of your computer, mobile, or other device;
  • Bandwidth use and system and connection performance;
  • Operating system, browser type, and version numbers;
  • Length of visit and page views;
  • Referral source;
  • IP address or other unique identifier for your computer, mobile phone, or other device; and
  • Mobile carrier, if applicable.

The use of cookies is standard, and your web browser may default to accept cookies. This configuration can be altered in your browser settings, although if cookies are rejected, you might have trouble using some features of a GBI website. We do not allow third parties to track our website users across time or across other sites.  For more information about how GBI uses cookies, please see GBI’s “Cookie Policy” which is hereby incorporated by reference into this Policy.

(3) Information GBI Receives from Others.

In some cases, other parties provide GBI with information about you, such as agents of GBI who organize and implement GBI’s services (or practices submitting inquiries through the “contact us” form on a GBI website). GBI’s agents could include answering services, call centers, investigators, study coordinators, or other service providers who carry out functions related to GBI business. GBI will treat the information received from its agents and practices in accordance with this Policy. In no circumstances will GBI or its agents process sensitive personal information about you, such as information about your health, race, ethnicity, national origin, political opinion, religious or philosophical beliefs, trade union membership, genetic data, or information about your sexual orientation or sexual life without your consent.

II. How GBI Uses Your Information.

As a general matter, GBI uses your information to provide the Services, or information you request, or for any purpose you direct or to which you agree at the time you provide it.

Specifically, GBI may also use your information (i) for its internal business operations, (ii) operating, evaluating, debugging, identifying and repairing errors, effectuating similar functional enhancements, and improving its websites, products, and other services, (iii) protecting against malicious, deceptive, fraudulent, illegal, or other unauthorized activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity, (iv) protecting the legal rights, property, safety, and security of our organization, assets, workforce, users, clients, and others, including to protect the physical safety and/or wellbeing of any individual, (v) conducting research, (vi) to comply with law, other legal and regulatory obligations, such as those related to taxation, litigation, audit, or investigation, industry standards, legal process, or law enforcement authorities or other government officials’ requests, and (vii) to evaluate or participate in a potential or actual material change to our business, including a purchase, merger, joint venture, acquisition, bankruptcy, liquidation, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, (vii) to create aggregate or deidentified data, and (ix) as otherwise described in this section of the Policy.

III. When You Pursue or Enter a Business Relationship with GBI.

When you share personal information in pursuit or in furtherance of a business relationship with GBI, whether through the Services or otherwise (i.e., soliciting business, sending advertising correspondence or materials, or submitting a proposal), GBI may use your personal information for such purposes including, but not limited to:

  • To communicate with you, respond to your offers or requests, or provide you with updates and information;
  • To conduct evaluations of prospective agents, suppliers, or providers;
  • To obtain proposals, cost estimates, and to enter, track, and archive contracts;
  • To improve the quality of GBI business operations, products, or systems;
  • To enable agents to perform certain activities on GBI’s behalf; and
  • For internal administrative and compliance procedures, such as auditing and data analysis.

IV. When you Visit GBI’s Website.

When you visit or use any of GBI’s website(s) for any purpose, GBI uses the information collected automatically from our websites to:

  • Administer the GBI website and diagnose problems with web servers;
  • Count website users, measure traffic, and analyze trends;
  • Investigate security incidents;
  • Improve content and the delivery and effectiveness of the GBI website for website users; and
  • Understand referral sources and the effectiveness of advertisement and directory listings.

V. When you Submit an Employment Application or Inquiry.

If you submit an employment inquiry or application, GBI may use the personal information you submit for our recruitment and hiring purposes, including processing your application, and evaluating your qualifications.

VI. How GBI Shares Your Information.

GBI may share your personal information with business partners or contractors, agents, service providers, and other third parties that perform services on GBI’s behalf and under GBI’s instructions. These service providers are not authorized by GBI to use or disclose the information except as necessary to perform services on GBI’s behalf or comply with legal requirements. Where applicable, all service providers shall be under a contractual obligation to adhere to applicable privacy laws.

GBI may also disclose information about you for purposes described in the “How GBI Uses Your Information” section above, including (i) to protect against malicious, deceptive, fraudulent, illegal, or other unauthorized activity, and participating in any prosecution or enforcement of laws or agreements meant to prevent or punish such activity, (ii) to protect the legal rights, property, safety, and security of our organization, assets, workforce, users, clients, and others, including to protect the physical safety and/or wellbeing of any individual, (iii) to conduct research, (iv) to comply with law, other legal and regulatory obligations, such as those related to taxation, litigation, audit, or investigation, industry standards, legal process, or law enforcement authorities or other government officials’ requests, (v) the event of a potential or actual material change to our business including a purchase, merger, joint venture, acquisition, bankruptcy, liquidation, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

VII. Data Retention.

GBI stores personal information for as long as GBI reasonably needs it to fulfill the purposes for which it was collected. GBI will retain and use personal information as necessary to comply with GBI’s legal and regulatory obligations, resolve disputes, and enforce our agreements.

VIII. Your Choices.

GBI provides you with choices about whether to provide GBI with personal information and whether it is shared. For example, when you provide information to GBI through a GBI website, GBI generally only asks you for personal information that is necessary to fulfill the purpose for which the information is requested. You can choose not to give GBI the personal information GBI requested. However, in some cases, if you decide not to provide the personal information we request, we will not be able to respond to your request. In addition, we are required to seek your consent before we use your personal information for any purpose incompatible with the purposes identified in this policy. You may withdraw your consent given pursuant to this section at any time by sending an email to info@goodwinbio.com. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent.

Other examples of your choices include:

  • You can browse a GBI website without providing any personal information. GBI may collect some limited information automatically, as described above.
  • You may change your browser settings or take other steps to block, manage, or delete cookies. In some cases, blocking or disabling cookies may cause a website not to work as intended and some features may not be available. GBI’s websites do not respond to “do not track” browser signals at this time.

IX. How GBI Protects Personal Information.

GBI maintains appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing.

X. Transfers of Information.

As part of GBI’s operations, we may transfer information about you to any jurisdiction where we do business.  We will transfer your personal information for any of the purposes identified in this Policy to our service providers that may be located outside of the jurisdiction where you are located.  The laws in those jurisdictions may not provide the same level of data protection compared to the laws in your country.  However, we will treat your personal information as subject to the protections described in this policy.

When GBI transfers personal information from the European Economic Area (“EEA”), United Kingdom, or Switzerland to another party located outside the EEA, United Kingdom, or Switzerland, we will rely on a legal framework that provides appropriate safeguards, which could include the standard contractual clauses, binding corporate rules or another framework deemed adequate by the European Commission.

XI. Third-Party Interactions.

A GBI website may include contact information, telephone numbers or links to websites, call centers, applications, and services operated by third parties, either on our behalf or on their own behalf, that are subject to their own privacy policies. We encourage you to review those privacy policies, which apply to the information collected by those websites, call centers, applications, and services.

XII. Notices to Residents of the State of California.

The California Consumer Privacy Act (“CCPA”) regulates how GBI handles personal information of California residents in connection with GBI’s Services and gives California residents certain rights with respect to their personal information.

GBI is both a “business” and a “service provider” under the CCPA. This section of the Policy applies to information GBI collects in its role as a business—this is when GBI interacts directly with you on our own behalf and not on behalf of our customer.

When GBI acts as a service provider (for example, by providing GBI’s services to another company that you interact with), GBI follows the instructions of the business that engaged us with respect to how GBI processes your personal information. If you would like more information about how your personal information is processed by other companies, including companies that engage us as a service provider, please contact those companies directly.

Under the CCPA, you have the rights as specified in the Section below entitled “Certain Rights You May Have Regarding Your Personal Data,” subject to certain limitations.  You also have the right not to be discriminated against because you choose to exercise your rights under the CCPA. In particular, you have the right not to be denied goods or services and not to be charged a different price or to be provided with a different level or quality of goods or services.

XIII. Certain Rights You May Have Regarding Your Personal Data.

In accordance with the laws of certain jurisdictions, you may have certain rights and choices regarding the personal data GBI collects and maintains about you, and how GBI communicates with you.  In particular, you may have the following rights with respect to the Services you are using, subject to some limitations:

  • The right to request information about our use of your personal data (e.g., the pieces and categories of personal data we have, the categories of sources, the purposes for collection, the third parties with whom we have shared personal data, and the personal data we have disclosed);
  • The right to review and access your personal data;
  • The right to rectify/correct/update/modify your personal data in our possession;
  • The right to erase/delete, de-identify, anonymize or block your personal data;
  • The right to restrict our use of your personal data;
  • The right to object to our use, or certain types of disclosures, of your personal data;
  • The right to request the transfer of your personal data in our possession to a third party;
  • The right to receive your personal data in a usable format and transmit it to a third party (sometimes referred to as data portability); and
  • The right to lodge a complaint with your local data protection authority.

If you would like to exercise any of these rights, you may do so by contacting us as set forth in the “How to Contact Us” section below, subject to our verification as described below in the Verification section.

Where required by law, you also have the right to withdraw any consent you have given to uses of your personal data.  If you wish to withdraw consent that you have previously provided to us, you may do so by contacting us as set forth in the “How to Contact Us” section below, subject to our verification as described below in the Verification section. However, the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

Where required by law, GBI provides you with the ability to access, modify, or update some of your personal data held in the Services at any time.  If available through the Services, you may log in and make changes to your information, such as your password, your contact information, your general preferences, and your personalization settings.  If necessary, you may also contact us as set forth in the “How to Contact Us” section below, subject to our verification as described below in the Verification section and describe the changes you would like for us to make to the information you previously provided.

XIV. Verifications.

Before responding to a request for information about your personal data, GBI must verify the request. Verification is important to protect your information and to help confirm that GBI is responding to a valid request and providing the response to the correct individual.  The information GBI asks for to verify your identity may depend on your relationship with GBI.

When you exercise your rights under applicable laws, you may have the right to designate an authorized agent or representative to make a request on your behalf by providing the authorized agent with written permission to do so and verifying your identity with GBI as part of the request, or by providing the authorized agent with power of attorney pursuant to applicable law.  GBI will ask the individual submitting the request to verify that they are an authorized agent or representative.  When submitted by an authorized agent or representative, GBI will ask the authorized agent or representative to provide the name, email address and a description of the relationship with the individual who is the subject of the request and to certify that the representative has permission to submit the request, and GBI may request proof of your written permission.

XV. Additional Privacy Rights and Obligations (EEA, United Kingdom, and Switzerland).

This section sets out rights applicable only to the personal information of individuals located in the EEA, United Kingdom, or Switzerland, and our obligations regarding their personal information. GBI is committed to maintaining accurate, complete, and current records of personal information. If you are located in the EEA, United Kingdom, or Switzerland, you may have the right to access and review your personal information, and to request that GBI amend, correct, or delete personal information that is inaccurate, incomplete, or outdated. To the extent consistent with applicable law, GBI will, on request, provide you with confirmation regarding whether GBI or any of its agents may be processing your personal information, and will take commercially reasonable steps to:

  • Verify your identity before granting access to or making any changes to your personal information;
  • Confirm that your personal information is being processed according to this policy; and/or
  • Correct, update, amend, delete or otherwise remove any personal information found to be inaccurate, incomplete, or processed in a manner non-compliant with this policy.

If you would like to request access to or correction of your personal information, please submit your request by sending an email to info@goodwinbio.com. Please include your name, email address, and postal address in your request, and describe specifically the information that you would like to access or correct so that GBI may respond appropriately and promptly. GBI reserves the right to charge a reasonable fee to cover costs for providing copies of personal information requested under this section. Although GBI will make a good faith effort to provide you with access to your personal information, there may be circumstances in which GBI is unable to provide access, including but not limited to:

  • where the personal information is subject to legal privilege;
  • where the provision of access would compromise the privacy or legitimate rights of others; or
  • where the burden or expense of providing access is disproportionate to the risks to your privacy.

If you are located in the EEA, United Kingdom, or Switzerland then you have the right to restrict or object to GBI’s processing of your personal information. The right to restrict processing arises only in limited circumstances, for example, if you think GBI is processing inaccurate information. In addition, if GBI is required to restrict processing but the requirement is temporary, GBI may not be permanently obligated to adhere to your request. GBI will, however, let you know when the restriction is lifted. In cases where GBI’s basis for processing your information is the satisfaction of our legitimate interests, you may object to our processing. However, GBI will decline your request if GBI’s interest in continuing to process your information is sufficiently compelling to legally override your interest in the request, or GBI’s processing is necessary to establish, exercise, or defend a legal claim. To request a restriction or to object to processing, please submit your request by sending an email to info@goodwinbio.com.

In cases where GBI processes your personal information pursuant to your consent, you may contact GBI by email at info@goodwinbio.com to request that your consent be withdrawn. Individuals residing in the EEA, United Kingdom, or Switzerland or whose personal information is processed by GBI also have the right to obtain their personal information so they can transfer it to another party, or ask GBI to do so on their behalf, which GBI will do when technically feasible. This right is limited, and only arises when GBI’s processing of your information is automated and based on your consent or an agreement with GBI. To exercise this right, please submit your request by sending an email to info@goodwinbio.com.

Individuals residing in the EEA or Switzerland also have the right to lodge a complaint with a supervisory authority established in their country.

XVI. Updates to Our Privacy Policy.

This Policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this Policy when this Policy was last updated. Please review this Policy every time you access or use our website to make sure that you have reviewed the most recent version.

XVII. How to Contact Us.

GBI encourages individuals covered by this policy to raise questions, concerns, or complaints by sending an email to GBI at info@goodwinbio.com or via mail at Goodwin Biotechnology Inc., 1850 N.W. 69th Avenue, Plantation, Florida 33313, Attn: Compliance Officer.