Privacy Policy

1. Scope of This Policy

Simbryo Technologies, Inc. ("Simbryo," "we," "us," "our") respects your privacy and values your trust. The purpose of this Privacy Policy is to inform you of the treatment and handling of personal information that we may learn about you from using our website at https://www.simbryotech.com and any other websites that link to this Privacy Policy (collectively, the "Site"), from information you provide to our service providers, from purchasing services from us or engaging with our content, or by use of any of our services (collectively, the "Service"). If you have any questions regarding this information or our privacy practices, please contact us via the methods set out in the How to Contact Us section at the end of this Privacy Policy.

2. Agreement to Terms

By using or accessing our Service in any manner, you acknowledge that you accept the practices and policies outlined below and the policies outlined in our Terms of Use, and you hereby consent that we may collect, use, and disclose your personal information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy and our Terms of Use, then you should immediately discontinue use of the Service without providing us with any personal information.

3. Information We Collect

We may collect the following categories of personal information (a) directly from you (such as when you contact us or fill out our registration forms), (b) from third-parties (such as your health care provider or clinic), (c) from the device and browser that you use to access the Service, and (d) from cookies and similar technologies.

Identifiers. We may collect your first name, last name, postal address, Internet Protocol address, and email address.

Financial and Transactional Information. We may collect payment details (such as credit or debit card information), billing address, order history. We use authorized third-party payment processors for part of this process.

User-generated Content. We collect the information and content of communications that you share through the Service. This may include any information you choose to provide when you contact us.

Demographics and Characteristics. We may collect your gender, race, age, and birthday, if you voluntarily choose to include such information when you contact us or respond to our registration forms.

Health Information. We may collect certain health-related information from you and your healthcare provider. This may include information about your health background, your medical record number (MRN), details about your healthcare provider, information necessary to process your order, and information included in the biopsy sample and resulting test data. We use this information to fulfill your order, coordinate with your healthcare provider, process and analyze your test sample, and deliver test results to your healthcare provider. Some or all of this health information may be deemed Protected Health Information ("PHI") as defined by the Health Insurance Portability and Accountability Act ("HIPAA"). More information on how we use and share your PHI is described in the Health Information section below.

Audio-Visual Information. We may collect audio and visual recordings from videocalls when you agree to participate in a study.

Inferences. We may also draw inferences from the information that we collect that reflect your health background in providing the Service.

Device Information. We may collect device information when you use our Service. Device information may include your device type, browser type, online and/or unique identifiers, IP address, and geolocation information.

Internet Activity. We may collect information concerning your interaction with the Service, including when you access the Service and your browsing activity on the Service (such as which pages you visit, in what order, and for how long). This may also include "traffic data" or tracking information provided by the website's host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Service.

You are not required to provide all personal information identified in this Privacy Policy to use our Service or to interact with us, but certain functionality will not be available if you do not provide certain personal information. For example, if you do not provide certain personal information, we may not be able to perform the Service or respond to your requests.

4. Health Information

In the course of providing the Service, we may receive health information about you (i) directly from you, (ii) from your healthcare provider, or (iii) as part of the testing process. To the extent that such information constitutes PHI under HIPAA, Simbryo acts as a "Business Associate" to applicable "Covered Entities" (including your healthcare provider) as those terms are defined by HIPAA. In our role as a Business Associate, we may collect PHI as reasonably necessary to perform the Services requested by you. We will only disclose your PHI, directly to you, to Covered Entities for the healthcare operations relating to you, to subcontractors and vendors when necessary to perform the Services, or as required by applicable law.

5. Cookies

We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, or analytical (as discussed in more detail below). Cookies on the Site are generally divided into the following categories:

• Strictly Necessary Cookies. These are required for the operation of the Site. They include, for example, cookies that enable you to log into password-protected portions of the Site. These cookies are session cookies that are erased when you close your browser.
• Analytical/Performance Cookies. These allow us to recognize and count the number of visitors to the Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located).

We also use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. Google provides users with the ability to prevent their data from being used by Google Analytics — learn more by going to https://tools.google.com/dlpage/gaoptout.

In addition, we use Webflow to host our Site. Webflow places certain performance cookies to understand how users navigate the Site. For more information regarding Webflow cookies, visit https://webflow.com/legal/cookie-policy.

You can also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections "Help," "Internet Options," or "Settings." If you disable or delete certain cookies in your Internet browser settings, you may still access our Site, however, you might not be able to access or use important functions or features of our Site, and you may, for example, be required to re-enter your log-in details.

Do-Not-Track Signals. At this time, we do not recognize automated "do-not-track" browser signals.

6. Children's Privacy

The Service is not intended for users under the age of 16 and Simbryo does not knowingly collect personal information from individuals under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Service without permission, please notify us immediately by contacting us as detailed in the How to Contact Us section below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child's privacy online.

7. Our Use of Personal Information

We collect and use your personal information for the following purposes:

• Providing the Service to you and providing the services requested by, or reasonably anticipated within the context of our relationship with, you;
• Managing our relationship with you, and responding to your inquires or requests, and requesting feedback;
• Providing relevant promotional materials or other marketing;
• Administering promotions, studies, or surveys;
• Improving the Service, including testing, research, development, and internal analytics;
• Analyzing use of the Site;
• Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible; and
• Complying with legal and regulatory obligations.

8. Our Disclosure of Personal Information

We may share your personal information with the following third parties:

• Service providers, including web hosting providers, payment processors, contact management software providers, customer relationship management providers, online form and survey providers and, in certain limited circumstances, with outside testing laboratories. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
• Your healthcare provider. We may share your personal information with your healthcare provider as necessary to facilitate the testing process. This includes providing your healthcare provider with the materials needed to collect your biopsy sample, sharing relevant order and testing details, and delivering the test results for your healthcare provider to review and discuss with you. We may also communicate with your healthcare provider to clarify testing requirements or support clinical coordination related to your care.
• With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
• Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.

Information that is Not Personal Information. We may create aggregated, de-identified or anonymized information from the personal information that we collect about you, including by removing information that makes the data personally identifiable to a specific individual. Additionally, we may de-identify physical samples, such as biopsy materials, which may be archived or cryobanked for future use. These de-identified samples may be shared, sold, or licensed to other institutions or companies for research and development purposes. We may use such aggregated, de-identified or anonymized information and physical samples for our lawful business purposes, including to analyze, build, and improve the Service, conduct research, and promote our business, provided that we will not share such information or samples in a manner that could identify you.

9. Your Privacy Choices

If you no longer want to receive our newsletters, emails, or other marketing communications, you may unsubscribe at any time by following the unsubscribe options in the communication itself, or by emailing us at [email protected].

Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your purchases placed through the Service.

You may request we delete or correct certain personal information that we hold about you by emailing us at [email protected]. When you make such a request, we may require you to verify your identity by providing us with your email address and other personal identifying information.

10. Security

We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.

11. Additional Disclosures for Residents of Canada

This section contains additional disclosures for residents of Canada. If you wish to request access to or correction of other personal information, or to opt-out of the processing of your personal information or request that we delete your personal information, you may contact us at [email protected] with the subject line "Canada Privacy" so that we can get your email to the right team. You may also contact us for information about how foreign-based service providers process your personal information or if you have any questions or complaints about the manner in which we treat your personal information.

We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.

12. Links to Other Websites

For your convenience, we may link to third-party sites and services, or otherwise display third-party content through our Service to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.

13. Effective Date and Changes to This Privacy Policy

This Privacy Policy is effective as of the date at the top of this policy. Simbryo has the discretion to update this Privacy Policy at any time. When we do, we will revise the effective date at the top of this page. We encourage users to frequently check this page for any changes and to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Service. In the event of a material change to this Privacy Policy, we will provide a message through our website or via email informing you of the change.

14. How to Contact Us

If you have any questions about this Privacy Policy or our Service, please contact us at [email protected].