Effective Date: August 20, 2020
Kalderos, Inc. (“Kalderos”, “our”, “we”, or “us”) is a life sciences technology company. We build web software and offer services that assist life science businesses (“Customers”) with their strategic and operational goals. As part of our agreements with our Customers, we may obtain information from and about healthcare providers, government agencies, and other persons and entities with which our Customers may have business dealings (“Business Partners”). Some of this information includes information about individuals maintained and/or processed by these Business Partners. We may also collect Personal Information from individuals who simply browse our websites and applications (“Visitors”).
1. Personal Information We Collect
This section describes the categories of Personal Information we may have collected about you in the last 12 months, and the categories of Personal Information we may continue to collect about you (Please note that the types of Personal Information listed in each category are examples only; they are not exhaustive.):
Contact information and identifiers, such as name, date of birth, social security number, address, email address, and phone number.
Professional or employment-related information, such as information about the companies for which individuals work and their titles and business contact information. Additionally, when you apply for employment with Kalderos, we may ask for your Personal Information, including your name, email address, phone number, copies of your resume or CV, and any other information required to verify your qualifications.
Device and online identifiers and Internet or other electronic activity information, such as IP address, operating system and information about the provider or browser used, date and time of visit to the website, pages visited, and information associated with browsing history.
Health insurance information, such as information submitted on a health insurance claim.
Location data, such as information derived from IP addresses.
Audio and visual information.
Other information you provide to us, such as information you choose to communicate to us or transmit through the Sites.
2. How We Use Personal Information
We may use the Personal Information described above for multiple internal and external purposes, including to:
Provide the Sites and Kalderos’ products and services
• Communicate with our Customers or Business Partners regarding account activities, new version and product offerings, or other communications relevant to the Sites and our products and services
• Consider you for employment with Kalderos
• Administer the Sites, maintain our systems, and troubleshoot
• Protect and secure our Sites, operations, and personnel
• Facilitate product and service development and new offerings
• Facilitate our business operations and needs, defend our rights and legal claims and comply with law, our policies, and legal requests
• Reorganize or transition our business, such as in connection with a merger, acquisition, or sale of all or a portion of our assets or business
If you contact us by email or by filling-out a registration form, we may keep a record of your contact information and correspondence, and may use your email address, and any information that you provide to us in your message, to respond to you.
If you decide at any time that you no longer wish to receive such information or communications from us, you may email us at email@example.com and request to be removed from our list.
If you are a Customer or a Business Partner of Review, Request, or Verify, you may review and update the Personal Information in your profile on the Sites by logging in and editing such information. If you decide to delete all of your information, we may cancel your account. We may retain an archived copy of your records to the extent required by law, or to the extent permitted by law when needed for reasonable business purposes.
3. Sharing Personal Information
In the last 12 months, we may have disclosed each of the categories of Personal Information above with third parties for a business purpose and may continue to do so. The categories of third parties with which we share personal information include:
• Business partners
• Law enforcement, governmental authorities, or other third-parties as required by law, in response to legal requests, to protect our rights and interests, or for the protection of others
• Third parties who may acquire all or part of our business or act as successors in interest to our business
We may also disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, our Sites or de-identified data, such as overall patterns or demographic reports.
4. Children’s Personal Information
The Sites are not designed for, directed to, or intended to be used by children under the age of 18. If we obtain actual knowledge that a child under the age of 18 is using the Sites, we will take steps to delete such information as soon as possible.
Kalderos maintains reasonable physical, electronic, and procedural safeguards designed to protect Personal Information. We cannot, however, guarantee the security of Personal Information.
If you are a Customer or a Business Partner and you have an account with us, your account is protected by a password that you select. It is your responsibility to protect your password appropriately and to limit access to your computer or device and browser by, among other things, signing off after you have finished accessing your account.
6. Third Party Hosting, Serving and Storage
KALDEROS MAY CONTRACT WITH A VARIETY OF THIRD PARTIES, INCLUDING SUPPLIERS, PROVIDERS, AND VENDORS, TO PROVIDE FOR OUR HOSTING, AUTHENTICATION, SERVING, STORAGE, COMMUNICATION, AND TELECOMMUNICATION NEEDS, ETC., INCLUDING WITHOUT LIMITATION STORAGE OF OUR USERS’ PERSONALLY IDENTIFIABLE INFORMATION. KALDEROS SHALL NOT BE RESPONSIBLE OR LIABLE, AND HEREBY DISCLAIMS ALL RESPONSIBILITY AND LIABILITY, FOR CULPABLE (INCLUDING WITHOUT LIMITATION NEGLIGENT) ACTS OR OMISSIONS BY THESE THIRD PARTIES.
Through the use of our Sites, third party services may place cookies on the Visitor's browser and may send their own cookies to the Visitor's cookie file. Some of these services may include, but are not limited to: Google, Intercom, Hubspot, LogRocket, Pendo, and other social networks, security firewalls, analytics companies and service providers. These services may also collect and use identifiers such as IP Address, HTTP Referrer, Unique Device Identifier and other non-personally identifiable information and server logs. You may opt-out from Google’s cookies using their Ad Settings. You may also use the Network Advertising Initiative opt-out page to opt-out of some third party cookies.
8. Use of Tracking Pixels
Kalderos collects Personal Information through the use of tracking pixels. A tracking pixel is a transparent graphic image that is placed on a website and, in combination with a cookie, allows us to collect information regarding the use of the Sites that contains the tracking pixel.
We may also work with ad networks and ad delivery platforms that place retargeting pixels on Visitors’ devices to gather information about Visitors’ online activities, such as browsing histories and demographic information. This information can be aggregated into audience segments, which help deliver relevant advertising to Visitors visiting our Sites and third-party websites that use the same pixels. Specifically, we may use the tracking pixels of a few large ad platforms (Twitter, Hubspot, LinkedIn, Google Ads, Facebook). To learn more about Google Ads, please visit https://policies.google.com/privacy. To learn more about Hubspot, please visit http://www.legal.hubspot.com/privacy-policy. To learn more about Twitter, please visit https://support.twitter.com/articles/20170514. For further information about LinkedIn’s privacy practices, please visit https://www.linkedin.com/legal/privacy-policy. To learn more about Facebook’s privacy practices, please visit https://www.facebook.com/policy.php.
9. Do-Not-Track Requests
“Do Not Track” signals are options available on browsers to tell operators of websites that users do not wish to have your online activity tracked. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
10. Third Party Sites
11. Your Rights Under California Law
Rights Under the CCPA
Individuals whose Personal Information is covered by the CCPA have the right, subject to certain limitations, to: (i) request access to the Personal Information we collect and share about you and (ii) request that we delete the Personal Information we have collected from you.
Your Right to Request Disclosure of Information We Collect and Share About You
Individuals whose Personal Information is covered by the CCPA have a right to request that Kalderos provide the following information:
• The categories of Personal Information that Kalderos has collected about you.
• The categories of sources from which Kalderos collected the Personal Information.
• The business or commercial purposes for which Kalderos collected and/or sold the Personal Information.
• The categories of any third parties with which Kalderos shared the Personal Information.
• The specific pieces of Personal Information Kalderos collected over the past 12 months.
Individuals whose Personal Information is covered by the CCPA may also submit a request that Kalderos provide the following additional information:
• The categories of Personal Information, if any, Kalderos has sold about you, categories of third parties to which Kalderos sold that Personal Information and the categories of Personal Information sold to each type of third party.
• The categories of Personal Information that Kalderos has disclosed for a business purpose.
Our responses to any of these requests will cover the 12-month period preceding our receipt of the request.
Your Right to Request the Deletion of Personal Information We Have Collected from You
Individuals whose Personal Information is covered by the CCPA may also request deletion of information covered by the CCPA. Upon receiving and verifying such request, Kalderos will delete the Personal Information that we have collected about you, unless that information is necessary for Kalderos to:
• Complete the transaction for which we collected the information;
• Provide you with a good or service you requested;
• Perform a contract Kalderos entered into with you;
• Detect security incidents;
• Maintain the functionality or security of Kalderos’ systems;
• Comply with or exercise rights provided by the law; or
• Use the information internally in ways that are comparable with the context in which you provided the information to Kalderos or that are reasonably aligned with expectations based on your relationship with Kalderos, among other things.
We may also retain information where another exception to the deletion requirements in Cal. Civ. Code § 1798.105(d) applies.
Please note that if you or your authorized agent request that we delete your Personal Information, you may no longer be able to access or use certain parts of the Sites.
Sales of Personal Information
We do not sell Personal Information.
Our Process for Responding to Requests for Access or Deletion under the CCPA
If you are a California resident, to exercise your CCPA rights and submit your requests, please send an email to firstname.lastname@example.org or contact Kalderos at (844) 930-2322.
Requests for disclosures are generally free, and we will not discriminate against you for exercising your rights. However, please note that Kalderos primarily operates as a service provider to other companies and in a business-to-business context. Accordingly, we may not be able to respond directly to your request, though we will seek to provide you an explanation of the basis for a denial of your request.
Before responding to your request, we will need to verify your identity based on information we maintain about you. The specific verification data we may request will vary depending on your relationship with us and the nature of your request. You may place a request through an authorized agent, however you will also need to verify the agency request as well. Requests that relate to a household must be placed through a verified request from each member of the household. For any request, if we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
Shine the Light Law
California’s “Shine The Light” law permits California customers to annually request and obtain information free of charge about what Personal Information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not disclose your Personal Information to third parties for the third parties’ direct marketing purposes.
11. International Users
12. Contact Us
If you have any questions or concerns, please contact us at email@example.com or contact Kalderos at (844) 930-2322.