Decoding Bio, Inc. General Privacy Notice

Last updated: February 13, 2024

Decoding Bio, Inc. and its affiliates (“Decoding Bio”, “we”, “our”, “us”) recognise their obligations under applicable privacy and data protection laws, including the United Kingdom’s Data Protection Act 2018 (“DPA”), the European Union’s General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), in relation to the processing of personal data about clients, prospective clients and other individuals that we obtain through our website at www.Decoding (the “Site”) and in connection with the products and services we provide (together, the “Services”). If you are located in the United Kingdom (“UK”) or the European Union (“EU”), this Privacy Notice is for informational purposes only. If you are located in the USA or otherwise outside the UK or EU, by using the Site you consent to the use of your personal data and agree to the terms of this Privacy Notice.

Depending on where you are located and your interactions with us and/or the Services, certain processing of your personal data by Decoding Bio may be subject to the DPA, the GDPR or the CCPA. For example, this may be the case where Decoding Bio processes the personal data of its clients or users of the Site in the UK and the EU (“UK/EU Processing”) or of clients or users of the Site in California (“CCPA Processing”). This Privacy Notice makes clear where its disclosures apply to the UK/EU Processing or to the CCPA Processing. All other disclosures in this Privacy Notice relate to personal data to which the DPA, the GDPR and the CCPA do not apply, as well as to the UK/EU Processing and the CCPA Processing.

Collecting your personal data

We may collect and process the following personal data about you:

  • Your name, username and password.
  • Contact details, such as your personal or work postal address, email address and phone number.
  • Financial information, where you enter into contracts or other arrangements with us.
  • Information about your communications with us, including the personal data you provide to us in emails or in conversations with our employees, contractors and vendors.
  • Your marketing preferences, including any consents you have given us.
  • Information related to the browser or device you use to access the Site, your computer and browser type, and your IP address and cookie preferences.

We may also receive personal data from third party sources, such as where our trusted suppliers provide web analytics and reporting services. We also receive confirmation of payment and related details for payment validation and fraud prevention purposes.

When you apply for an open position at Decoding Bio, we use Lever, a third-party recruiting app, and your resume and other personal data will be processed via Lever. Please consult the Lever Privacy Center for Lever’s privacy policy.

If you provide personal data to us about any person other than yourself, such as your employees, you must ensure that they understand how their personal data will be used, and if required by applicable law, that they have given their permission for you to disclose it to us and for you to allow us, and our outsourced service providers, to use their personal data.

Using your personal data

We may collect and process the following personal data about you:

Purpose of Processing

  • Verifying your identity.
  • Communicating with you in relation to the Services.
  • Providing the Services to our clients and other individuals.
  • Promoting the Services to clients, potential clients and other individuals and advising you of news and industry updates.
  • Monitoring the use of the Site and using personal data to help us improve and protect the Services, both online and offline.
  • Investigating any complaints received from you or others about the Services.
  • In connection with legal claims and for compliance, regulatory and investigatory purposes.
  • Sending you direct marketing by email in relation to the Services.
  • On other occasions where we ask you for consent, we will use your personal data for the purpose(s) that we explain at that time.
  • In response to requests from government law enforcement authorities conducting an investigation.

Legal Basis

  • Where necessary to fulfill a contract or purchase, or to take steps linked to a contract or purchase.
  • Where necessary for Decoding Bio’s or another party’s legitimate interests and where those interests are not overridden by your data protection rights.
  • Where you give us your consent.
  • Where necessary to comply with a legal obligation.

UK/EU Disclosure: Where we require personal data to comply with our legal or contractual obligations, the provision of such personal data is mandatory. If it is not provided, then we may not be able to provide the Services. In all other cases, the provision of requested personal data is optional.

Media Contacts

Pablo Lubroth
Decoding Bio

Sharing your personal data

We may share your personal data with other members of the Decoding Bio group to administer and manage group functions, including the provision of the Services to you and in the course of audits. Your personal data may be shared with companies providing services under contract to Decoding Bio, such as email marketing vendors and IT hosting and/or IT maintenance providers. We may also disclose your personal data to government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable law.

UK/EU Disclosure: Your personal data may be processed in, and accessed from, jurisdictions outside the UK and/or EU by other members of the Decoding Bio group and by the third parties with which we share your personal data. Specifically, your personal data will be transferred to Decoding Bio entities and vendors in the USA. When we transfer your personal data within the Decoding Bio group, or to organisations outside the Decoding Bio group, we will do so in accordance with the DPA and the GDPR (as applicable), including through the use of standard contractual clauses that have been approved by European Commission or the Information Commissioner's Office ("ICO"), a third party's binding corporate rules or where we are entitled to rely on one of the other safeguards permitted by the DPA or the GDPR (as applicable) or other applicable law.

CCPA Disclosure: We may disclose the following categories of personal data to our service providers for the performance of business services on our behalf: (i) identifiers, including your name, username and password, and contact details, such as your personal or work postal address, email address and phone number; (ii) commercial information, including your marketing preferences and any consents you have given us; (iii) internet or other electronic network activity information, including information related to the browser or device you use to access the Site, your IP address and cookie preferences; and (iv) audio, electronic and visual information, including your communications with us and the personal data you provide to us in email or in conversations with our employees, contractors and vendors. We do not sell your personal data and have not sold your personal data in the last 12 months, and we do not sell the personal data of minors.

Your rights

UK/EU Disclosure: You are entitled to ask Decoding Bio for a copy of your personal data, to correct, delete or restrict processing of it and to obtain the personal data you provide in a structured, machine readable format and ask us to share (port) this personal data to other organisations. You may also have the right to object to processing in some circumstances, such as where Decoding Bio relies on its legitimate interests to process your personal data, and the right in some circumstances not to be subject to automated individual decision-making (including profiling). Where we have asked for your consent, you may withdraw it at any time. If you ask to withdraw your consent to Decoding Bio processing your personal data, this will not affect any processing which has already taken place but this may affect our ability to process your personal data in accordance with this notice. These rights may be limited: for example, if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete personal data which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make. If you are not satisfied with our response, or of our processing of your personal data, you have the right to complain to the ICO or a regulator in the country in the EU where you live, work or where you believe the breach of the DPA or the GDPR occurred.

CCPA Disclosure: If you are a California resident, you may be entitled to request access to the personal data that Decoding Bio collects about you, to request that Decoding Bio deletes your personal data and to opt out of the sale of your personal data. The CCPA prohibits Decoding Bio from discriminating against you for exercising your applicable CCPA rights. Under California Civil law, Californians are entitled to request information relating to whether a business (i.e., Decoding Bio) has disclosed personal data to any third parties for the third parties' direct marketing purposes. If you are making a request for access, we may not be able to provide specific pieces of personal data if the disclosure creates a substantial, articulable and unreasonable risk to the security of your personal data, your account with us or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your personal data again before your request is submitted.If you wish to exercise your rights, we may need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, asking you to provide a signed declaration that you are the individual whose personal data is the subject of the request. If it is necessary to collect additional information (including personal data) from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If you make a request through an authorised agent, we will require written proof that the agent is authorised to act on your behalf. We will process your request within the time provided by applicable law. If you wish to exercise any of your rights under applicable law, please contact us using the details below.

Retaining your personal data

UK/EU Disclosure: Decoding Bio will keep the personal data we process as described in this Privacy Notice to comply with our legal and contractual obligations, or to communicate with you because you still have another connection with Decoding Bio. Where we process personal data for marketing purposes or with your consent, we process the personal data until you ask us to stop and for a short period after that (to allow us to implement your request). We keep a record of the fact that you have asked us not to send you direct marketing or to process your personal data so we can respect your request in future. Decoding Bio may be required by law to hold personal data for specific periods. In other cases, Decoding Bio will retain your personal data for an appropriate period after our relationship ends to protect ourselves from legal claims or to administer our business.

Updates to this Privacy Notice

This Privacy Notice may be updated periodically. We will update the date at the bottom of this Privacy Notice accordingly. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Privacy Notice as required by applicable law. Any updated version of this Privacy Notice will be effective as of the date set out below. If you are located in the USA or otherwise outside the UK or the EU, by continuing to use the Services after such updates you expressly agree to the terms of the updated Privacy Notice.

Contact Us

We hope that we can satisfy questions you may have about the way we process your personal data. If you have any concerns about how we process your personal data, please contact us using the details below.The controller for your personal data is:

Media Contacts

Pablo Lubroth
Decoding Bio