Thank you for your interest in Calico Life Sciences LLC (“Calico”). Calico is sensitive to privacy issues, and it is important to us to protect the information provided to us (“Personal Information”). As you visit our website and learn more about our company, please take a moment to review this Privacy Policy, which explains what Personal Information we collect and how we use that information.

This Privacy Policy applies to the Personal Information processed by Calico through our research, business and human resource operations, our websites and mobile applications.

Information we collect

The categories of Personal Information we may collect and our privacy practices depend on the nature of the relationship you have with Calico and the requirements of applicable law. We endeavor to collect information only relevant for our business needs.

• Information you submit. We collect information whenever you provide it to us directly, such as when you submit a job application, resume, or curriculum vitae or enroll in an event or program. We also collect information you submit directly via email or when you click on our website links such as “press@calicolabs.com”.
• Research data. Calico processes information for research, including, for example from bio and tissue banks, third party datasets and/or data repositories, other collaboration partners, and in the context of clinical trials. Such information may be collected by Calico and/or by others in a manner consistent with any consents signed by the individuals to whom the information relates (such as sample donors and research participants), as well as regulatory and data protection requirements.
• Human Resources Information. Calico collects information from prospective, current, and former employees, and independent contractors (“Human Resources Information”). The Human Resources Information we may collect is as follows:
  • From Prospective Employees—Name, title, address, phone number, email address, language abilities, and information that may be recorded on a CV or application form.
  • From Current and Former Employees—Passport number, driver’s license number, social security number (or other government-issued identification), contact information of third parties to be notified in case of emergencies, bank details for bankroll, beneficiaries under insurance policies, and details of health and disability, medical leave, and parental leave.

• Cookies, local storage, and log information. We use various technologies to collect and store information when you visit our website. This may include storing one or more cookies, small files containing a string of characters, to your device when you visit a website. Cookies may also store user preferences and other information. We may also collect and store information using mechanisms such as browser web storage (including HTML5) and application data caches.

When you view content provided by Calico on our website, we may automatically collect and store certain information in server logs. This may include: Internet protocol address, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, and cookies that may uniquely identify your browser.

How we use information we collect

We primarily use the information to advance our research or to support our relationship with you.  We may also use information to develop, maintain, protect, and improve our web site and to protect Calico and our users and partners. Specific reasons we may process and use the information include:

• Administrative purposes. Calico may use the information collected for its administrative purposes, including, without limitation, to: (a) measure interest in Calico’s research and our website content; (b) comply with regulatory requirements; (c) manage our agreements and your relationship with us; (d) verify or maintain data integrity or quality; (e) process payments and transactions; and (f)  detect and prevent potentially prohibited or illegal activities, such as malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
• Human Resources Management. We store and use the Human Resources Information we collect for a wide variety of business purposes including, for the types of employees noted:
  • For Prospective, Current and Former Employees—Application processing, compensation analysis (including bonus and long-term incentive administration), job grading activities, regulatory compliance, internal and/or external or governmental compliance investigations, job grading activities, internal or external audits, litigation evaluation, prosecution and defense; diversity and inclusion initiatives; workflow management, assigning, managing and administering projects; Human Resources administration and communication, emergency contacts and services, compliance with statutory requirements, compensation analysis, including monitoring overtime and compliance with labor laws and company recognition programs; performance and employee development management, organizational development and succession planning, benefits and personnel administration, absence management, and restructuring and relocation.
  • For Current Employees—Helpdesk and IT support services, network and device security, employee safety, and processing of employee expenses and travel charges.
  • Human Resources Information that Calico receives in connection with the employment relationship will only be used for employment-related purposes. If Calico intends to use this information for any other purpose, the Company will provide you with an opportunity to opt-out of such uses.

• Site analytics and improvement. Calico uses cookies to identify return visitors, record user preferences, and measure the effectiveness of our site.  We, as well as third parties that provide content or other functionality, may use cookies, pixel tags, local storage, and other technologies to automatically collect information.  Our uses of these Technologies fall into the following general categories:
  • Operationally Necessary. This includes Technologies that identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance Related.  For example, example we may use Technologies to assess the performance of our websites or mobile applications, including analytic practices to help us understand how our visitors use websites and mobile applications;
  • Functionality Related.  For example, we may use Technologies that allow us to offer you enhanced functionality when accessing our websites or mobile applications.  This may include identifying you when you sign in or keeping track of your specified preferences, interests, or past items viewed;
  • We may use Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site to aid website content development. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit this site. Google Analytics does not recognize or respond to browser-initiated Do Not Track (“DNT”) signals, a privacy preference that users can set in certain web browsers. You can opt out of tracking and Google Analytics processing of data generated by your use of the Services by opting out here.
  • Calico may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. Calico will collect information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings, and the operating system of your device, to help customize the appearance of website information to your device.

• Other uses. Calico may also use the information we collect to: generally manage individual information and accounts; respond to questions, comments and requests; provide access to certain areas and features of the Calico sites; ensure internal quality control; verify individual identity; enable individuals to register for events or participate in seminars; communicate about individual account and activities; at Calico’s discretion, make changes to any Calico policy; tailor content presented to individuals; process applications and transactions; comply with law or regulatory requirements; undertake activities to verify or maintain the quality or safety of a service, and to improve, upgrade, or enhance the service; undertake internal research for technological development and demonstration; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity; debugging to identify and repair errors that impair existing intended functionality; and for purposes disclosed at the time that individuals provide information or otherwise with consent.

Transparency and choice

Where you have consented to Calico’s use of your Personal Information or sensitive Personal Information, you may withdraw that consent at any time and opt out by following the directions provided in the consent you provided (for example, within the informed consent form associated with a clinical trial in which you participate) or, if no such directions were provided, by contacting Calico at privacy@calicolabs.com. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out.

Information we share

We do not sell Personal Information or share it with companies, organizations and individuals outside of Calico unless one of the following circumstances applies:

• With your consent. We will share Personal Information with companies, organizations, or individuals outside of Calico when permissible under our partner agreements or we have your consent to do so. We require opt-in consent for the sharing of any Personal Information relating to sensitive Personal Information (i.e., confidential medical facts, racial or ethnic origins, political or religious beliefs, or sexuality).
• Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
• With our business partners. We share Personal Information with our business partners, such as companies with which we jointly administer research projects.
• Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
• For external processing. We provide Personal Information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.With respect to onward transfers to Agents under the Data Privacy Framework, the Data Privacy Framework requires that Calico remain liable should its Agents process Personal Information in a manner inconsistent with the Data Privacy Framework Principles.
• Business transactions. We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, purchase or sale of assets, transition of service to a provider, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, Calico will endeavor to direct the transferee to use Personal Information in a manner that is permitted by law and/or contract and/or consistent with this Privacy Policy.

Rights of Access, Rectification, Erasure and Restriction

General
You have certain choices about your Personal Information. Where you have consented to the processing of your Personal Information, you may withdraw that consent at any time and prevent further processing by contacting us as described below.  Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Services and for other legal purposes as described above.

Your Privacy Rights
In accordance with applicable law, you may have the right to:

Access to/Portability of Personal Information about you consistent with legal requirements.  In addition, you may have the right in some cases to receive or have your electronic Personal Information transferred to another party.

Request Correction of your Personal Information where it is inaccurate or incomplete.  In some cases, we may provide self-service tools that enable you to update your Personal Information or we may refer you to the controller of your Personal Information who is able to make the correction.

Request Deletion of your Personal Information, subject to certain exceptions prescribed by law.

Request restriction of or object to processing of your Personal Information.

To make a privacy rights request, please use the contact information located at the end of this Privacy Policy. We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

Children’s Information
Calico services are not directed to children under 16 (or other age as required by local law), and we do not knowingly collect Personal Information from children.  If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below.  If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

Data Privacy Framework

Calico Life Sciences LLC complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Calico Life Sciences LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  Calico Life Sciences LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.  Click here to read more about Calico’s Adherence to the EU/US Data Privacy Framework.

If you are located in the European Economic Area, the United Kingdom, or Switzerland you may seek confirmation regarding whether Calico is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been processed in violation of the Data Privacy Framework Principles. Where otherwise permitted by applicable law, you may use any of the methods set out in this Privacy Policy to request access to, receive (port), object to processing (including in some cases automated decision making and/or profiling), restrict processing, seek rectification or request erasure of Personal Information held about you by Calico. 

Although Calico makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Calico is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Calico determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. In situations where another method of making requests applies (such as in the context of research), we will provide you with information about how to make requests at the time you provide Personal Information to us. Such requests will be processed in line with local laws. 

International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

Retention

Calico retains the Personal Information we receive as described in this Privacy Policy for as long as you use our sites or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, comply with applicable laws, and for any additional period of time as specified to you at the time you provide Personal Information to us.

Information Security

The security of all Personal Information provided to Calico is important to us, and Calico takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Calico strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to Calico, and you do so at your own risk. If you have reason to believe that your Personal Information is no longer secure, please promptly notify Calico at privacy@calicolabs.com. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

Supplemental Notice for California Residents

Application

Our Privacy Policy applies to information we collect on our website and use in the course of our business. It applies to all Calico owned entities and any additional U.S. subsidiary, affiliate or branch of Calico that we may subsequently form. All individuals whose responsibilities include access to or use of information on behalf of Calico are expected to protect that information by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC and other jurisdictions.

Our Privacy Policy does not apply to services offered by other companies or individuals, or other sites linked from our website. Our sites may contain links to other websites for your convenience and information. Calico does not control such third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Calico does not endorse or make any representations about third-party websites. Any Personal Information you choose to give to unrelated third parties is not covered by this Privacy Policy. Calico encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their users’ Personal Information with Calico; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

Our Privacy Policy does not cover the information practices of other companies and organizations who may advertise our business or research, and who may use cookies, pixel tags, and other technologies to serve and offer relevant ads.

Calico will comply with agreements that limit how we use information provided to us.

Other Important Information & Changes to this Privacy Policy

Calico may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Privacy Policy, Calico will notify you as required by applicable law. Calico encourages you to review this Privacy Policy periodically to be informed regarding how Calico is using and protecting your information and to be aware of any policy changes. Any changes to this Privacy Policy take effect after being posted or otherwise provided by Calico.

Questions & Enforcement

If after reviewing this Privacy Policy, you would like to submit a request, exercise your rights, appeal our decision related to the exercise of your rights, or if you have any questions or privacy concerns, please contact:

Privacy Officer
Calico Life Sciences, LLC
1170 Veterans Blvd.
South San Francisco, CA 94080

Email: privacy@calicolabs.com
Privacy Request Phone Line: (855) 950-1034

Calico will address your concerns and attempt to resolve any privacy issues in a timely manner.

Privacy Policy Effective Date: August 16, 2023