PALETTE LIFE SCIENCES, INC. PRIVACY NOTICE

LAST UPDATED: July 24, 2020

This Privacy Notice is intended to describe how Palette Life Sciences, Inc., (“Palette”) collects, uses, and shares Personal Data that you submit to us and that we collect through our website www.barrigel.com (the “Site”). The Site provides a venue to obtain information about Palette’s Barrigel Product, radiation therapy, and our company.

INFORMATION WE COLLECT

For purposes of this Privacy Notice, “Personal Data” means any information relating to an identified or identifiable natural person. As described in detail below, we may collect certain Personal Data from or about you in connection with your use of, or your submissions to, the Site.

We may collect Personal Data as follows:

You are not required to provide all Personal Data identified in this Privacy Notice in order to use the Site; however, if you do not provide the Personal Data requested, we may be unable to provide some or all of the Site to you.

USE OF COOKIES AND SIMILAR TECHNOLOGIES

The Site uses cookies and similar technologies to improve user experience, for performance and analytics, and to improve our content, products, and services. We also use cookies and similar technologies for purposes of marketing and advertising.

A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track Personal Data previously entered by a web user on our site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. Cookies can remember login information, preferences, and similar information.

Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data.

We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.

If you want to block the use and saving of cookies from the Site on to the computers’ hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Site and its external serving vendors, or use the cookie control system, if available upon first visit. Please note that if you choose to erase or block your cookies, certain parts of our Site may not function correctly. For information on how to disable cookies, refer to your browser’s documentation.

Our Site may use the following technologies to implement cookies and pixels:

Please note that Google and Facebook have their own privacy policies which are independent from ours. We do not accept any responsibility or liability for these policies and procedures. Before using our website, please inform yourself about Google’s privacy policy (Link: http://www.google.com/privacy.html) and Facebook’s data policy (Link: https://www.facebook.com/about/privacy/).

HOW WE USE THE INFORMATION WE COLLECT

We may use Personal Data for a variety of different purposes as set out in further detail below. Subject to applicable law, the purposes for which we use and process Personal Data, and the legal basis for such processing, are set forth below.

In some cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your Personal Data:

HOW WE MAY DISCLOSE INFORMATION

We may disclose Personal Data as described in this Privacy Notice, including:

DE-IDENTIFIED OR ANONYMOUS DATA

We may create de-identified or anonymous data from Personal Data by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not subject to this Privacy Notice.

DO-NOT-TRACK

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. The online community has not agreed on what actions, if any, should be taken by the websites that receive the “do not track” signal, and therefore Do-Not-Track is not yet standardized. Please note that the Site does not alter its behavior or use practices when we receive a Do Not Track signal from your browser.

INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE

We do not knowingly collect information from minors under the age of 13 years without parental consent. If you become aware that an individual under 13 years of age has provided us with Personal Data without parental consent, please contact us at support@palettelifesciences.com. If we become aware that an individual under 13 years has provided us with Personal Data without parental consent, we will take steps to remove the data as permitted by law.

LINKS TO OTHER SITES

Our Site may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). We provide these links merely for your convenience. Palette has no control over, does not review, and is not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Notice does not apply to Third-Party Sites. We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.

EUROPEAN UNION DATA SUBJECT RIGHTS

The personal data of data subjects in the European Economic Area remain subject to this Privacy Notice even if personal identifying information is removed and the information is sent to us as coded information, provided that the key reattaching the code to your personal data is held by a third party. Once the key that can reattach your personal data to the coded data is destroyed, your personal data will no longer be subject to this Privacy Notice.

Palette is the data controller for Personal Data provided to us through your interactions with the Site. To find out our contact details, please see the “Contact Us” section below, which also provides the contact details of our EU Representative pursuant to Article 27 of the General Data Protection Regulation.

Data subjects in the European Economic Area and certain other jurisdictions may have certain rights under applicable data protection law, including the right to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, subject to applicable law, you also have the right to:

To exercise your rights, you may contact us as at support@palettelifesciences.com. As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law. To protect your privacy and security, we may take steps to verify your identity in order to respond to your request. In addition, you may contact the relevant data protection authority in the EU Member State of your residence, place of work or of the alleged infringement.

WITHDRAWING YOUR CONSENT

In most cases, we need to process certain of your Personal Data in order to fulfil our contractual obligations to you and for our legitimate interests. Where the basis of processing is legitimate interests, you have a right to object to the processing of your Personal Data. Please note that, subject to applicable law, we may continue to process your Personal Data even where you object if there are compelling legitimate grounds for processing that override your interests and rights, or where processing is necessary to establish, exercise, or defend legal claims.

Where consent is the basis of processing, you may at any time withdraw the consent you provided for the processing of your Personal Data for the purposes set forth in this Privacy Notice by contacting us at support@palettelifesciences.com, provided that we are not required by applicable law or professional standards to retain such information.

If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications. Alternatively, you may contact us at support@palettelifesciences.com to opt-out of direct marketing. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices and certain communications related to the provision of the Site.

Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Data, we may be unable to provide you some or all of the Site.

TRANSFER OF DATA

Please note that if you are visiting the Site from outside of the United States, your information may be transferred to, stored, and/or processed in this country. The United States data protection and other laws might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of Personal Data is necessary to provide you with the requested information and Site and/or to perform any requested transaction. By using any portion of the Site, you acknowledge and consent to the transfer of your information to our facilities in the United States.

DATA RETENTION

We will retain your Personal Data for as long as is necessary to provide the Site, or for such longer period as may be required or permitted by applicable law. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

SECURITY

Palette uses technical and organizational security measures designed to secure and protect Personal Data. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time. The most recent version of the Privacy Notice is reflected by the version date located at the top of this Privacy Notice. We encourage you to review this Privacy Notice often to stay informed of how we may process your information.

CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at support@palettelifesciences.com or by mail at the following address:

Palette Life Sciences, Inc.
27 E Cota Street
qbSanta Barbara, Santa Barbara County 93101

EU Representative Contact Information:
DE: +49 0 800 1813 334 / paletteeur@eversana.com
ES: +34 900 993 304 / paletteeur@eversana.com
FR: +33 (0) 800 000 013 / paletteeur@eversana.com
IT: +39 800 785 440 / paletteeur@eversana.com
UK: +44 080 823 4628 / paletteeur@eversana.com

All other EU countries: palettemc@dlss.com